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HomeMy WebLinkAbout06-5880' ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee under the :CIVIL DIVISION Pooling and Servicing agreement dated as of April 1, :Cumberland County 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Thelma Steidle 2600 Yale Avenue NO • ??, 0 CIU? C T/?. Camp Hill, PA 17011 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other Plaintiff. You may lose money corlpropertylor requested by the other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requtede q perder dinero o sus propiedadeslunotros esta deman emanda. Puede derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO VAYA EN 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, PERSONA 0 LLAME PABAJOE PARA AVERIGUARFDONDE SE DIRECCION SE CONSEGUIR ENCUENTRA ESCRITA ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: New Century Mortgage Corporation Assignments of Record to: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Recording Date: LODGED FOR RECORDING 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g)• The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 2600 Yale Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Camp Hill COUNTY: Cumberland DATE EXECUTED: 12/23/03 DATE RECORDED: 12/31/03 BOOK: 1849 PAGE: 4895 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 9/20/06: Principal of debt due $181,209.17 Unpaid Interest at 9.45% from 1/1/06 to 9/20/06 (the per diem interest accruing on this debt is $47.54 and that sum should be added each day after 9/20/06) 12,503.02 Title Report 325.00 Court Costs (anticipated, excluding 280.00 Sheriff's Sale costs) Escrow Overdraft/(Balance) sum on this shouldaccount is h $49.42 hand escrow be added on the first of each 593.00 month after 9/20/06) Late Charges (monthly late charge of 76.86 should be added in accordance with the terms of the note 250.26 each month after 9/20/06) Attorne s Fees (anticipated and actual to 5% oy principal) 9,060.46 TOTAL $204,220.91 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been seat to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $204,220.91 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 LEGAL DESCRIPTION SITUATE IN THE CTS LOT, OR PIECMBERL Np, AND STATE OF. TRA ALL THAT CE C kW IU , COUNTY OF C H OF AND DESCRIBED AS FOLLOWS: ?NUE AND BOROU G V ANIA, BOUNDED R OF Y ALE A pENNS? NORTHWEST CORNS RLY DIRECTS N POINT AT THE THENCE IN ANORTHE I BEGINNING AT A ET; TY-SIXT H STREE Y UTH TWENTY-SIXTH INEREOF SOUTII TWENTHENCE IN A FEE IAL y ALONG WE y EFII?NVE (145) FEET TO A POINT; TWENTY (20) THE LINE OFUTHER ERELy DIRECTION ALONG. RED FORT SOUTHERN N.?ONED H RECTION ALONG THE THNNCE 1 A SO INAFTER 1VIE TON POINT; PLAN OF LOTS H NIJE; THNNCE IN AN FIFTY (50) FEET 8 OF THE TO YALE AVE FIFTY LINE OF LOT NOY-FIVE (145) FEET HERN LINE OF YALE A?NUE THE D FORT NORT ONE HUNDRE CTION ALONG THE EASTERLY Dill PLACE OF BEGINNING' r . (50) FEET T , 01-21-0271-568 TAX PARCEL NUMBF (Page 1 of 5) TLitt Loan SeNidng" 7/24/2006 Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 www.littordoan.com ACT 91 NOTICE TAII-C-lu-JACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can hel ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and nbone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of the Notice. If you have any questions you may call the Pennsylvania Housing Finance Agenev toll free at (8001342-2397. Persons with impaired hearing can call (7171780-1869. 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJQNTO ES DE SUMA RUPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A (Page 2 of 5) HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 11817699 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ASSISTANCE WILL BE DENIED. 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 of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the 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 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 addresses and telMhone numbers of designated consumer credit counseling agencies for the coon in which the roe is 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. 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 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 (Page 3 of 5) 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 can T still apply COLLECT HE Mortgage DEBT. Assistance.) (If you have filed bankruptcy, y pP Y for aY HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2600 Yale Avenue, 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: 2/1/2006 through 7/1/2006 at $1,586.62 totaling $9,519.72 Other charges Late charges $76.86 Deferred late charges $317.67 NSF charges $0 Deferred NSF charges $0 Suspense balance $0 TOTAL AMOUNT DUE AS OF THIS DATE $9,914.25 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. HOW TO CURE THE DEFAULT - 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 $9,914.25 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: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 outstanding balance of this 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 your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins incurred, legal proceedings against you, you will still be required to pay the reasonable attorney's fee that. were actually 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 if they exceed $50.00. Am, attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDERREMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. (Page 4 of 5) -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 paying 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 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 Sheriff s Sale of the mortgaged property could be held would be approximately 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 be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number. (713) 966-8906 Contact Person: Default Administration Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to 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 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 BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland (Page 5 of 5) CCCS of Western 'Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717(541-1757 (888)511-2227 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717)234-5925 FAX(717)234-9459 Financial Counseling Services dams Countv Housing Authority 139-143 Carlisle St Gettvsburg,PA 17325 (717)334-1518 FAX(717)334-8326 of Franklin 31 West 3rd Street Wavnesboro, PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle, PA 17013 (717)243-3818 FAX(717)731-9589 Community Action Comm of the Capital Region 1514 Derrv Street Harrisburg, PA 17104 (717)232-9757 FAX(717)234-2227 V E R I F I C A T I O N 4 1 4. Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Q D 1. ?l ) ? 1 KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQUIRE I. D. 92207 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717) 761-7573 sbkope(cD-kopelaw.com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, : NO.2006- CIVIL TERM ?p 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NOTICE TO PLEAD To: Plaintiff: YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED PRELIMINARY OBJECTIONS WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. KOPE & ASSOCIATES, LLC Shane B. Date: November 20, 2006 KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQUIRE I.D. 92207 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717) 761-7573 sbkopeC&-kopelaw.com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, : NO. 2006-5441 CIVIL TERM 2600 Yale Avenue Camp Hill, PA 17011, Defendant. PRELIMINARY OBJECTIONS AND NOW, comes Defendant, Thelma Steidle (hereinafter "Defendant" and /or "Steidle"), by her counsel, Kope and Associates, LLC, and assert the following Preliminary Objections to Plaintiffs Complaint on the grounds of lack of conformity to rule of court: 1. Plaintiffs Complaint purports to state a cause of action arising out of a written contract; specifically, the Mortgage Agreement concerning 2600 Yale Avenue, Camp Hill, Cumberland County. A copy of plaintiffs complaint is attached as Exhibit "A". 2. Pa.R.C.P. 1019(h) requires the plaintiff to attach to the Complaint the document or material part thereof upon which the Complaint is based. 3. No written document of this nature was attached to the Complaint in this action. 4. It is particularly necessary for this document to be attached to Plaintiffs Complaint, as Plaintiff is making a significant claim for attorney's fees therein. 5. Because a claim for attorney's fees in not properly raised in a Complaint unless otherwise provided by statutory authority, agreement of the parties or some other recognized exception (See Equibank v. Miller, 422 Pa.Super. 240, 619 A.2d 336, 338 (1993)), the Mortgage Agreement must be attached so the Defendant can prepare a proper response to this averment. 6. In addition to attorney's fees, the Complaint seems to indicate that Defendant is responsible for other fees based upon the terms of the Mortgage Agreement. 7. Without the Mortgage Agreement, the Plaintiff cannot draft an adequate response to these allegations, as well. WHEREFORE, Defendant, Thelma Steidle, respectfully request that Plaintiffs Complaint be dismissed. KOPE AND ASSOCIATES, LLC By: SH Page 2 of 2 WE HEREI WITHI CORRECT,cm UDREN LAW OFFICES, P.C. ATTORNEY FO'. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 ? WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust ?COURT OF COMMON PLEA Company as Trustee under the ECIVIL DIVISION Pooling and Servicing - agreement- -da-te-d--as---.of_Ap - U_1-,-- _ _Cumberland County 2004, GSAMP Trust 2004-NCI 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. A FF ak, Thelma Steidle 2600 Yale Avenue NO. CC. Camp Hill, PA 17011 Defendant(s) JQQ c.? COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE ---C .'"'tier"' a-C^ Ra-r AssoCia i on _?_ -------- 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 TRUE COPY FROM RECORD EXHIBIT - 910 8 n Todka y wham, ! '8 unto SAt"1w nd 1118 of saI4 tat c aft P8. A AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importar_tes para usted. , LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIMM EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part.. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. A/ Marv J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-54M 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: New Century Mortgage Corporation Assignments of Record to: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI Recording Date: LODGED FOR RECORDING 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 2600 Yale Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Camp Hill COUNTY: Cumberland DATE EXECUTED: 12/23/03 DATE RECORDED: 12/31/03 BOOK: 1849 PAGE: 4895 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by.said Mortgage, together with other charges authorized by --aim-mortgarjQ motet 1 be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 9/20/06: Principal of debt due $181,209.17 Unpaid Interest at 9.450 from 1/1/06 to 9/20/06 (the per diem interest accruing on this debt is $47.54 and that sum should be added each day after 9/20/06) 12,503.02 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $49.42 and that sum should be added on the first of each month after 9/20/06) 593.00 Late Charges (monthly late charge of $76.86 , should be added in accordance with the terms of the note each month after 9/20/06) 250.26 Attorneys Fees (anticipated and actual to St of principal) 9,060.46 TOTAL $204,220.91 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsy vania - - Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $204,220.91 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney T.D. No. 04302 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT, LOT, OR PIECE OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS. BEGINNING AT A POINT AT THE NORTHWEST CORNER OF YALE AVENUE AND SOUTH TWENTY-SIXTH STREET; THENCE IN A NORTHERLY DIRECTION , . ALONG THE WESTERN LINE OF SOUTH TWENTY-SIXTH STREET ONE HUNDRED FORTY-FIVE (145) FEET TO A POINT; THENCE IN A WESWERLY DIRECTION ALONG THE SOUTHERN LINE OF A TWENTY (20) FEET ALLEY FIFTY (50) FEET TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE LINE OF LOT NO.8 OF THE PLAN OF LOTS HEREINAFTER MENTIONED ONE HUNDRED FORTY-FIVE (145) FEET TO YALE AVENUE; THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF YALE AVENUE FIFTY (50) FEET TO THE PLACE OF BEGINNING. TAX PARCEL NUMBER: 01-21-0271-568 .: (Page 1 of 5) f Lon Loan StTViCiT)9"" 4828 Loop Central Drive Houston, TX 77081 ?elephone (800) 999-8501 Fax (713) 966-8906 www.1ittonloan.com 7/24/2006 Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on vour 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 EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. Counseline Agency. The name, address and Phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. If you have any auestions. you max call the Pennsylvania Housing Finance Agencv toll- free at (800) 342-2397 Persons with impaired hearing can call (717) 78o-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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA AIPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLA MADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDR IIR SU HIPOTECA. FXHtB1T A (Page 2 of 5) HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 11817699 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S 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 of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the 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 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 addresses and telephone numbers of designated consumer credit counseling agencies for the coumv in which the p-mR= is 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. 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 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 WURFOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO... SO OR IF YOU.DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. (Page 3 of 5) 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 Bring it un to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: V-;V?49; 2600 Yale Avenue, -? IS SERIOUSLY IN DEFAULT because. j' A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months anthe amounts are now past due: 2/1/2006 through 7/1/2006 at $1,586.62 totaling $9,519.72 Other charges Late charges $76.86 !_ ?t{ ' Deferred late charges $317.67 /,"?'? ? NSF charges f $0 Deferred NSF charges $0 Suspense balance $0 TOTAL AMOUNT DUE AS OF THIS DATE $9,914.25 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default HOW TO CURE THE DEFAULT --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 $9,914.25 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: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 outstanding balance of this 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 your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off 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 fee 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 _actua_llh,_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. Ifffyou wife the dcTaiult within--the IlfaM (30YDA-Y period, you will not be required to pay attorney's fees. X Lv f OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums du er the mortgage. Z ?, _ la ox, n4 WW (Page a of 5) 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 Sheriffs Sale. You may do so by paying 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 arty other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements 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 Sheriff's Sale of the mortgaged property could be held would be approximately 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 be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: . LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number. (800) 999-8501 Fax Number. (713) %6-8906 Contact Person: Default Administration Department 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to 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 HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE T HIES 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 BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland Page. 5: of 5) CCCS of Western Pennsvlvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717(541-1757 (888)511-2227 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717)234-,5925 FAX(717)234-9459 Financial Counseling Services of Franklin 31 West 3rd Street Wavnesboro, PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle, PA 17013 (717)243-3818 FAX(717)731-9589 Communitv Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 FAX(717)234-2227 Adams Countv Housing Authority 139-143 Carlisle St Gettvsbum, PA 17325 (717)334-1518 FAX(717)334-8326 l A? V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. VERIFICATION I, Thelma Steidle, the Defendant in this matter, have read the foregoing Preliminary Objections to the Plaintiff's Complaint. I verify that my averments in these Preliminary Objections are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: ?D a, 0?21? J --'C' The ma Steidle CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on November 20, 2006, 1 served a true and correct copy of the foregoing Preliminary Objections to Plaintiffs Complaint via first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (Attorney for Plaintiff) KOPE & ASSOCIATES, LLC S sq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I . D. 92207 (Attorney for Defendant) f 7 r-. ? j. ? -. ' :"l '--f __ __,..? i`•J ^' ?? ?....1 7 ?„? ?} ._._. ,'7 _ :? SHERIFF'S RETURN - REGULAR CASE NO: 2006-05880 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS STEIDLE THELMA VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEIDLE THELMA the DEFENDANT at 2032:00 HOURS, on the 18th day of October , 2006 at 2600 YALE AVENUE CAMP HILL, PA 17011 by handing to THELMA STEIDLE 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: So Answers: Docketing 18.00 Service 13.20 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41.20,,/ 10/19/2006 UDREN LAW OFFICE Sworn and Subscibed to By: before me this day -deputy h iff of A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 080003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee COURT OF COMMON PLEAS under the Pooling and Servicing agreement dated CIVIL, DIVISION as of April 1, 2004, GSAMP Trust 2004-NCl Cumberland County Plaintiff € MORTGAGE FORECLOSURE V. Thelma Steidle TERM, € NO. 06-5880 CIVIL TERM Defendant(s) PRAECIPE TO DEEM PRELIMINARY OBJECTIONS MOOT PURSUANT TO Pa.R.C.P.1028(c)(1) TO THE PROTHONOTARY: Kindly mark Defendant's Preliminary Objections moot, pursuant to Pa.R.C.P. 1028(c)(1), as Plaintiff has amended its Complaint. UDREN LAW OFFICES,P.C. BY: Mark J. *ei ATT Y UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as € COURT OF COMMON PLEAS Trustee under the Pooling and Servicing CIVIL DIVISION agreement dated as of April 1, 2004, GSAMP Cumberland County Trust 2004-NC 1 Plaintiff V. Thelma Steidle NO. 06-5880 CIVIL TERM Defendant CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of the Praecipe To Deem Defendant's Preliminary Objections Moot, and Amended Complaint in Mortgage Foreclosure pursuant to Pa.R.C.P. 1028(c)(1) upon the following person(s) named herein at their last known address or their attorney of record by Regular First Class Mail: Date served: January 22, 2007 TO Shane B. Kope, Esquire KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 UI B) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pl"dings@udren.com Deutsche Bank National Trust Company as € COURT OF COMMON PLEAS Trustee under the Pooling and Servicing CIVIL DIVISION agreement dated as of April 1, 2004, GSAMP Trust 2004-NC 1 Cumberland County Plaintiff V. Thelma Steidle NO. 2006-5141 CIVIL TERM Defendants AMENDED COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO Pa.R.C.P.1028(c)(1) YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 Plaintiff, Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI, by and through undersigned counsel by way of Amended Complaint hereby says: Plaintiff is the Corporation designated as such in the caption and is the Plaintiff by virtue of the following recorded assignments, attached hereto as Exhibit "A": Assignor: New Century Mortgage Corporation Assignments of Record to: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI Recording Date: November 27, 2006, Book 0732, Page 1625 2. Defendant is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner and mortgagor of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant, Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). Attached hereto is a copy of Note and Mortgage marked as Exhibits "B"and "C". The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 2600 Yale Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Camp Hill COUNTY: Cumberland DATE EXECUTED: 12/23/03 DATE RECORDED: 12/31/03 BOOK: 1849 PAGE: 4895 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 9/20/06: Principal of debt due $181,209.17 Unpaid Interest at 9.45% from 1/1/06 to 9/20/06 (the per diem interest accruing on this debt is $47.54 and that sum should be added each day after 9/20/06) 12,503.02 Title Report 325.00 Court Costs (anticipated, excluding Sheriffs Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $49.42 and that sum should be added on the first of each month after 9/20/06) 593.00 Late Charges (monthly late charge of $76.86 should be added in accordance with the terms of the note each month after 9/20/06) 250.26 Attorneys Fees (anticipated and actual to 5% of principal) 9.060.46 TOTAL $204,220.91 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will only be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "D", and made part hereof, and defendant have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant herein in the sum of $204,220.91 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. r yr /? U,DREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 VERIFICATION The undersigned, the Plaintiff in the within action, or the servicing agent of Plaintiff, and being authorized to make this Verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the within Amended Complaint are taken from the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Litton Loan Servicing, LP By: 1 v Name: Mart; N a Title: Jrv1 Dated: ?tEwr ??' ? ?d / Litton Loan Servicing LP Attomey in Fad ?kh?b"?tA ?.2 ?51. kA-11 an (f,dv j+ viOO 90LA "3 RECORD AND RETURN TO C-Bass Lo sset Management, LLC c/o Litton ban Servicing, LP 4828 L p Central Drive HOust ,Texas 77081 Post ue Dilieence Dent. - 7th Floor Loan Number:0001269721 Recording Requested By/Return To: 11,61-I&`t4 Parcel Number: 01-21-0271-566 X0 6 Q 27 An 10 02 ON ASSIGNMENT OF MORTGAGE *It For. Value Received, the undersigned holder of a Mortgage (herein "Assignor") whose address is 18400 VON KARMAN, SUITE 1000, IRVINE, CA 92612 :)& Deutsche Stank National Trust , does hereby grant, sell, assign, transfer and convey, unto Company, as Trustee under the Pooling and Servicing Agreement a corporation organized and existing under the laws of dated as of April 1, 2004, GSAMI(herein "Assignee"), whose address is Trust 2004-NC1 a certain Mortgage dated December 23, 2003 , made and executed by THELMA STEIDLE A SINGLE WOMAN AS SOLE AND SEPARATE PROPERTY whose address is 2600 YALE AVENUE CAMP HILL, PENNSYLVANIA 17011 to and in favor of v'vNEW CENTURY MORTGAGE CORPORATION" and given to secure payment of One Hundred Eighty-Four Thousand, Four Hundred Fifty and No/100 ------ --------------------($ 184,450.00 ) (Include the Original Principal Amount and Maturity Date of Note(s)) which Mortgage is of record in Book, Volume, or Liber No. I` 'A"i , at page LASIS (or as No. ) of the Records of CUMBERLAND e,a-c- dak_ is/31/o County, Commonwealth of Pennsylvania, together with the note(s) and obligations therein described and the money due and to become due thereon with interest, and all rights accrued or to accrue under such Mortgage. TO HAVE AND TO HOLD the same unto Assignee, its successor and assigns, forever, subject only to the terms and conditions of the above-described Mortgage. Pennsylvania Assignment of Mortgage (IM -995(PA) (9512) 12/95 VMP MORTGAGE FORMS - (800)521-7291 Page 1 of 3 Initials: - BKO73i%Pb` i 625 IN WITNESS WHEREOF, the undersigned Assignor has executed this Assignment of Mortgage on January 6, 2004 P'?? ?1 APF12:Z-NEW CEN R MORTGAGE Witness (Assignor) By: Witness ignature} „i ,;;,;,Magri I' ame a Shippi g Manager Attest " J K iu f'?J r Seal: - 3 ?? ? ? '- 1 X95 .' ?= This Instrument Prepared By: NEW CENT.tIAlLkO?,GAtPORATION address: 18400 VON KARMAN, SUITE 1000, IRVINE, CA 92612" tel. no.: 1(800) 967-7623 State of California %trrfi4;t;?tt County of ORANGE On January 6, 2004 , before me Er i k eyes personally appeared Magda Villanueva , personally known to me (or proved to me on the basis of satisfactory evidence) to be a person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/sh ey executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the trument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS mvk&d and official seal. Erika Reyes -995(PA) (9512) -1163B (9605) Page 2 of 3 O O BK0732PG 1626 CALIFORNIA ALL-PURPOSE ACKNOWLEDGEMENT STATE OF CALIFORNIA COUNTY OF ORANGE On January 6, 2004 before me the undersigned Erika Reyes, A Notary Public in and for Orange County and the State of California, personally appeared Magda Villanueva, A.V.P./ Shipping Manager of New Century evidence to be the persons whose names are subscribed to the within instrument and acknowledged to me that their authorized capacities, and that by their signatures on the instrument the persons, or the entity upon behalf of which the persons acted, executed the instrument. Witness my hand and official seal ' ERIKA REYES a . Commission # 1455d01 w Notary Public • Calitornia 5 '` '` M Orange County y Comm. Expires Gec 9, 2?7 r Signature of Notary Public Erika Reyes COMMISSION # 1455401 COMMISSION EXPIRES: December 9,2007 BK0732K1627 Certificate of Residence I do hereby Certify that the precise address of the assignee is: C/O Litton Loan Servicing 4828 Loop Central Drive Houston, TX 77081 Name: pril Allen Title: Legal Assistant B 073?PG 1626 i l LEGAL DESCRIPTION ALL THAT CERTAIN TRACT,?LOT, OR PIECE OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWEST CORNER OF YALE AVENUE AND SOUTH TWENTY-SIXTH STREET; THENCE IN A NORTHERLY DIRECTION ALONG THE WESTERN LINE OF SOUTH TWENTY-SIXTH STREET ONE , . HUNDRED FORTY-FIVE (145) FEET TO A POINT; THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE OF A TWENTY (20) FEET ALLEY FIFTY (50) FEET TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE LINE OF LOT NO.8 OF THE PLAN OF LOTS HEREINAFTER MENTIONED ONE HUNDRED FORTY-FIVE (145) FEET TO YALE AVENUE; THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF YALE AVENUE FIFTY (50) FEET TO THE PLACE OF BEGINNING. :01-21-0271-568 in Curnt? clan fy, z _. 7`! ?I?,6?+ i3 ;Page 1 of 16) CERTIFIED COPY Prepared By: Return To: NEW CENTURY MORTGAGE CORPORATION NEW CENTURY MORTGAGE CORPORATION 18400 VON KARMAN, SUITE 1000 IRVINE, CA 92612 Parcel Number: 01-21-0271-566 (Space Above This Line For.Recwdiag Datal MORTGAGE DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16. (A) "Security Instrument" means this document, which is dated December 23, 2003 together with all Riders to this document. (B) "Borrower" is THELMA STEIDLE , A SINGLE WOMAN AS SOLE AND SEPARATE PROPERTY Borrower is the mortgagor under this Security Instrumcia . (C) "Lender" is NEW CENTURY MORTGAGE CORPORATION Lender is a CORPORATION 0001269721 PENNSYLVANIA - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 (I 6(PA) (oooa) <? - _ ?.` Papa 1 01 1s InHlab: VMPMORTGAGE FORMS -(800)521-7201 1111 Lllif1iii G (Page 2 of 16) 0 0 organized and existing under the laws of CALIFORNIA Lender's address is 184DO VON KARNAN, SUITE 1000 IRVINE, CA 92612 Lender is the mortgagee under this Security Instrument. (D) "Note" means the promissory note signed by Borrower and dated December 23, 2003 The Note states that Borrower owes Lender One Hundred Eighty-Four Thousand, Four Hundred Fifty and No/100 ----------------- ------------------ Dollars (U.S. $ 184,450. 00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than January 1, 2034 (E) "Property" means the property that is described below under the heading "Transfer of Rights in the Property." (F) "Loan" means the debt evidenced by the Note, pks interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: ® Adjustable Rate Rider C] Condominium Rider ? Second Home Rider [J Balloon Rider R Planned Unit Development Rider ? 1-4 Family Rider EJ VA Rider Biweekly Payment Rider ® Other(s) [specify] Prepayment Rider Arm Rider Addendum (H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non-appealable judicial opinions. (1) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (J) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such teen includes, but is not limited to, paint-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (K) "Escrow Items" means those items that are described in Section 3. (L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. (N) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (u) any amounts under Section 3 of this Security Instrument. (®0(PA) (ooos) 0001269721 lnltlarc: Pape 2 of to Form 3039 1101 Page 3 of 16) 0 0 (0) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from titne to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note'and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender: (i) the rep yment of the Loan, and all renewals, extensions and modifications of the Note, and (ii) the performance T Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located in the COUNTY [Type of Recording Jurisdiction] of CUMBERLAND (Name of Recording Jurisdiction): SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF. which currently has the address of 2600 YALE AVENUE CAMP HILL [streetl [city), Pennsylvania 17011 MP Code) ("Property Address"): TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the .1ftperty.,, 0001269721 Inltlel@: ? _ 6(PA) (0000) Page 3 of 18 Form 3039 1/01 Page 6 of 16) 0 0 BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will dgfend.generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property- UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender. (a) cash; (b) money order, (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security instrument or performing the covenants and agreements secured by this Security Instrument 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in S 0001269721 • 1nlNals: ( -B(PA) (0000) Papa 4 of t9 Form 3039 1/01 ?age 5 of 16) 0 0 full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied fast to any payment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain pri6rity over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section' 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Leader Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal'agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the 0001269721 mnan: (D e(PA) (0008) Page 5 of 1s Form 3039 1101 ?age 6 of 16) 0 . 0 Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, att defined under RESPA, bender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as•required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall Oay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all ", assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the team of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and certification services and subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. 0001269721 tnRVatt: (j ®6(PA) toooat Page aof is Form 3039 1/01 Page 7 of 16) a 0 If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such cgvemge shall cover Lender, but might or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender stall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shalt be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. 0001269721 Inhlal . ?®6(PA) (ooop Papa 7 of 18 Form 8039 1101 ,age 8 of 16) 0 0 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration. Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. 9. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process. Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. ( ;8(PA) (oooa) InnialaC?- Papa 8 of 16 0001269721 Form 3039 1/01 kage 9 of 16) 0 0 Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. 'T'hese amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merge' in writing. 10. Mortgage Insurance. If Lender required Mortgagq Insurance as a condition of making the Loan, Borrower shag pay the premiums required to maintain the Mortgage insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to matte separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance•in effect or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. new agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance premiums). As a result of these agreements, Lender, any purchase' of the Note, another insurer, any reinsurer, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is often termed "captive reinsurance." Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they wit[ not entitle Borrower to any refund. 0001269721 InNtal U 4 =06(PA) (ooo9) Papa 9 of 16 Form 3039 1101 ?age 10 of 16) 0 0 (b) Any such agreements will not affect the rights Borrower has - if any - with respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may indude the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. In the event of a partial taking, destruction. or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of { 0001269721 Innlal? ?®8(PA) (oooa) Pape 1001 16 Form 3039 1101 ,age 11 of 16) • r Lender's interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 0001269721 InlHal dM-S(PA) (0009) Page 1t of 16 Form 3039 1101 ;Page 12 of 16) 0 0 15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only one designated notice address under this Security Instrvthent at any one time. Any notice to lender shall be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security Instrument. 16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. In the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security Instrument or the Note which can. be given effect without the conflicting provision. As used in this Security Instrument (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument. 18. Transfer of the Property or a Benerrcial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without lender's prior written consettt, Lender may require immediate payment in full of all sums secured by this Security Instrument However, this option shall not be exercised by lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) five days before sate of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all C 0001269721 muf b (0 6(PA) (0006) Page 12 of 18 Form 34241 1101 ;Page 13 of 16) 0 expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Pfoperty and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall'remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be soli one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the LA= is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or Lender has noted the other party (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shalt be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. C 0001269721 tnitial$ ®8(PA) (aoo8? Page 13 ot 16 form 3032 1101 ?age 14 of 16) 0 0 Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower teams, or is notified by any governmental or regulatory authority, or any privatb party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lander shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not price to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the stuns secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. 23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 2S. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument 26. Purchase Money Mortgage. If any of the debt secured by this Security instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 0001269721 lnldalf• ( j.G(PA) (0008) Papa U of 16 Form 3039 1101 4e 15 of 16) CE.R.lIF IED COPY. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security instrument and in any Rider executed by Borrower and recorded with iL Witnesses: (Seal) THELMA STEIDLE -Borrower N _ (Seal) -Borrower (Seal) (Sew) -Borrower -Borrower (Seal) -Borrower _ (Seal) -Borrower ®-G(PA) (oooa) m Page 15 01 18 _ (Seal) -Borrower _ (Seal) -Borrower 0001269721 Form 3039 1101 Page 16 of 16) • G CER1IF Ito COPY Certificate of Residen I, M?4 .OIYAA1'-- do hereby certify that the correct address of the within-named Mortgagee is 16,400 VON KARNAK, SUITE 1000 IRVINE, CA 52612 Witness my hand this Z3 day of Agent of Mortgagee 1 COMMONWEALTH OF PENNSYLVANIA, C(&r"% /LL0-3t' County ss: ; On this, the Z3rd day of b£c.-*- N, 3?-- 2 C , before me, the undersigned officer, personally appeared I S of.- known to me (or satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that he/she/Mey executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: 2gMMONWF.ALTH OF PENNSYLVANIA Title of Officer NOTARIAL SEAL GINNY L DALE, NOTARY PUBLIC Kp arrON. W2 M4 COUNTY MY COMMISSION pePIRE6 JUNE 11, 2007 0001269721 In1INls• ,-E(PA) (0009) Pago 1a of is Form 3039 1/01 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT, LOT, OR PIECE OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS.: 0 BEGINNING AT A POINT AT THE NORTHWEST CORNER OF YALE AVENUE AND SOUTH TWENTY-SIXTH STREET; THENCE IN A NORTHERLY DIRECTION ALONG THE WESTERN LINE OF SOUTH TWENTY-SIXTH STREET ONE , . HUNDRED FORTY-FIVE (145) FEET TO A POINT; THENCE IN A WES?ERLY DIRECTION ALONG THE SOUTHERN LINE OF A TWENTY (20) FEET ALLEY FIFTY (50) FEET TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE LINE OF LOT NO.8 OF THE PLAN OF LOTS HEREINAFTER MENTIONED ONE HUNDRED FORTY-FIVE (145) FEET TO YALE AVENUE; THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF YALE AVENUE FIFTY (50) FEET TO THE PLACE OF BEGINNING. TAX PARCEL NUMBER: 01-21-0271-568 I •? f r xl,ib?t C Wge 1 of 5) 2 YEAR RATE LOCK I t. ' ADJUSTABLE RATE NOTE + i (LIBOR Six-Month Index (As Published In The Wall Street Journan -Rate Caps) THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE +i AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE: AT ANY ONE TIME AND THE MAXIMUM RATE I MUST PAY. PENNSYLVANIA , i (;• : ?' ; I;i December -23 , 2003 ! ' CAMP HILL' [Date] (city) [slate) ' 2600 YALE AVENUE CAMP HILL, PENNSYLVANIA 17011 (Property Address) , ' • , 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 184,450. 00 (this amount'is called "Principal"), plus interest, to the order of Lender. Lender is ! '' ' i • " NEW CENTURY MORTGARE CORPORATION r i I will make all payments under this Note in the form of casts, check or money order. ; I understand that Lender may transfer this Note. Lender or anyone who takes this Note by trans1 1. fer and', who is entitled to; receive payments under this Note is called the "Note Holder." 1 + I I ?? + ?' ? , , ? ', +111 2. INTEREST i . Interest will be charged on unpaid Principal until the full amount of Principal has been paid. I will pay interest at•a yearly rate of 7.9500 The interest rate I will pay may change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both .before and after any default described in Section 7(B) of this Note. + 3. PAYMENTS , (A) Time and Place of Payments I will pay Principal and interest by making a payment every month, j ; I will make my monthly payments on the first day of each month beginning on February 1; 2004 I will make these payments every month until I have paid all of the principal and interesi and any other changes. described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be I applied to interest before Principal. If, on January 1, 2034 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 18400 VON KARMAN, SUITE 1000 I i I •' IRVINE, CA 92612 ' or at a different place if required by the Note Holder. ' (B) Amount of My Initial Monthly Payments t I This aciount Each of my initial monthly payments will be in the amount of US. $ 1;347.01. may change. (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid Principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance,with Section 4 of this Note. +his is a•eerfitied 1Ftl9 I j I . • ? ? ! ' ' . and.rorredt 120 1, : ! ? + original } I + MULTISTATE ADJUSTABLE RATE NOTE- LIBOR SIX-MONTH INDEX (AS PUBLISHED IN THE L TRa ETJOURNAL) Single Family -'Fannie Mae UNIFORM INSTRUMENT + , . t + ?_-?_nnn??Ct17.91?+ • 4=-838N looosi Form 35201!01 m li JwB ? VMP MORTGAGE FORMS - (800)521-7 1 !j Papa t of t InltlaU r ` .,1 I loolowl so N ito, ¦.¦., .., . I f? 'alje 2 of 5) I ` ? I 4. INTEREST, RATE AND MONTHLY PAYMENT CHANGES. (A) Change Dates ! 1 ! ' , ' ' I The interest rate I will pay may change onjthe first day of 'January 2006 i , and on that day eery' 6th month thereafter. Each date on which my interest rate could change is called a "Change Date," (B) The Index ; ' • Beginning with the first Change Date, mylmterest rate will be based on an Index. The "Index" is the average of rrrterbank offered rates for six month U.S. dollar-denominated deposits in the London market ("LIBOR"), as published in The Wall Street Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in . which the Change Date occurs is called the "Current Index." If the Index is no longer available, the Note Holder will choose a new index that is based upon comparable information. The Note Holder will give me notice of this choice. ! S (C) Calculation of Changes Before each Change Date, the Note Holder will calculate my new interest rate by adding Six ;and { Three-Quarters ' percentage points ( 6.7500 %) to the Current Index. The Note Holder will then round the result of this addition to the nearest one-eighth of one percentage point (0.125%). { Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date. The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid Principal that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate,in substantially'egt,W ; payments. The result of this calculation will be the new amount of my monthly payment. (D) Limits on Interest Rate Changes The interest rate I am required to pay at the first Change Date will not be greater than ' 9.4500 or less than 7.9500 ?. Thereafter, my interest rate will never be increased 'or decreased on any single Change Data by more than One and One-Half percentage point(s) ( 1.500 , '{. %) from the rate of interest I have been paying for the preceding 6 months. My' interest rate will never be greater than 14.9500 (E) Effective Date of Changes My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly .payment beginning on the first monthly payment date after the Change Date until the amount of my monthly payment changes again. ' . (F) Notice of Changes The Note Holder will deliver or mail to me a notice of any changes in my interest rate and the amount of my monthly payment before the effective date of any change. The notice will include information required by law' to be given to me and also ' the title and telephone number of a person who will answer any question I may have regarding the notice. ' 5. BORROWER'S RIGHT TO PREPAY t I have the right to make payments of Principal at any time before they are due, A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under this Note. I may make a full Prepayment or partial Prepayments without paying any Prepayment charge! The;Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. ,However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount before applying my Prepayment to reduce the ; Principal amount of this Note. If I make a partial Prepayment. there will be no changes in the due dates, of my tmonthly payments unless the Note Holder agrees in writing to those changes. My partial Prepayment may reduce the amount of my 1 monthly payments after the fast Change Date following my' partial Prepayment. However, any reduction 'due to my partial Prepayment may be offset by an interest rate increase. ! r ! i' I ' ; i 6. LOAN CHARGES { I { i ' I If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other, 1 loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a),'any such loan charge j shall be reduced by the amount necessary to reduce the charge to the permitted, limit; and (b) any sums already collected from ' me that exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the, i Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated I as a partial Prepayment ;:0001259i21 j 1 ! [ , ' form 3 1101'1 i -838N (00l)5) S Pape 2 01 a Inltla + e I , t 't ' f ' ? ! ® 3 of 5) 7. 'BORROWER'S FAILURE TO PAY AS REQUIRED a ' (A) Late Charges for Overdue Payments. If the Note Holder has not received the full amount of any monthly payment by the end of 15 _ f calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.00 % of my overdue payment of principal and, interest. I will pay this late charge promptly but only once on: each late payment. I (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal that has not; been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the, notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder ' Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. t t (E) Payment of Note Holder's Costs and Expenses' If the Note Holder has required me to pay immediately in full as described above, the Note Holder,will have the''right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. ?• ' 8. GIVING OF NOTICES } Unless applicable law requires a different method, any notice that must be given to me under `this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Unless the Note Holder requires a different method, any notice that must be given to the Note Holder under this Not, will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address; 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises: made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or etidatt'ser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of theamounts owed under this Note. ' ,. 10. WAIVERS I and any other person who has obligations under this Note waive thelrights'of Presentment and Notice of Dishonor.' "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means, the right to require the Note Holder to give notice to other persons that amounts due have not been paid, 11. UNIFORM SECURED NOTE ; r This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the; Note Holder under this Note, a Mortgage; Deed of Trust, or Security Deed (the "Security Instrument"),, dated the same date as this Note, protects the Note Holder from possible losses that might result if I do not keep the promises that I make in this Note.. That Security Instrument describes how and under what conditions 1 may be required to make immediate payment in, fullof all ' amounts I owe under this Note. Some of those conditions read as follows: ' .1 l ;' + jI , 0001269721 ` ' Form Of i®838N coos 1 + Pa e 3 of t ' l 1 , 0. ' Inttlale• + i. l , E. atle 4 of 5) Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest m tfiel . Property" means any legal or beneficial interest in the Property, including, but not limited to,{ those btateficiall . ' interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent ! of which is the transfer of title by Borrower at a future date to a purchaser. j. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a ,.'' natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior, written consent;'' ' Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option f ' shall not be exercised by Lender if such exercise is prohibited by Applicable Law. Lender alto; shall not exercise this option if (a) Borrower causes to be submitted to Lender information required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (b) Lender reasonably derxinines'that Lender's : '. security will not be impaired by the loan assumption and that the risk of a breach of any covenant or agreement in this Security Instrument is acceptable to Lender: To the extent permitted by Applicable Law, Lender may charge a .reasonable fee as a condition to Lender's ; . conser?t to the loan assumption. Lender also tray require the transferee to' sign an assumption agreement that is v i acceptable to Lender and that obligates the transferee to keep all the promises and agreements'made in the Note and ' in this Security Instrument. Borrower will continue to be obligated under the Note and this Security Instrument' ' unless Lender releases Borrower in writing. j ` I . ' ;?+: •r If Lender exercises the option to require immediate payment in full, :Lender shall give Borrower notice of : •. acceleration. The notice shall provide a period of not less than 30 days ` from the date the notice is given vi ' ( accordance with Section 15 within which Borrower must pay all sums secured by this Security-instrument. IP, ' Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted byf' ; ! this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. , I 1 iI ?, , •''? i j 1 AI?, 111 (Seal) I (Seal) THELMA StEIDLE } Borrower t' 'I'; ?•Bmrower f , f t Itf!i. (Seal) ` f i t. t (Seal) . Borrower 1-Borrower • j (S?) t ! , i ,'Seal) r -Borrower -Borrower 1 (Seal.) , (Seal) 4 -Borrower ;-Borrower .I 7 i 1 1 i r• , i ! I 1 I , ?835N tooo5) Papa 4 or 4 . I 1 s i , i • 1 .1 i, •• 1 E , , . , i ' I ? i ? , i ? 1 ? •' (Sign OriginsI Only] i I , ' 1 f f,# • 1 1 . 4 E. ttt ! 0001269721: j Form 3520 1/01 t Il . ' I , I I t i i i i i I i1 f , i I 1 .1 ( t 1 i •t 1 l a'ge 5 of 5) FEDERAL TRUTH-IN-LENDING DI&WR.E STATEMENT For use with Adjustable Rate Mortgage Loam Dare. nqrsaishgg 92 n2 loarJ nnn1969721 QNEW CENTURY Borrowers: THE MA STernl F MORTGAGE CORPORATION Property 2t nn vat L aUCY11E Location: CAMP HILL PA 17011 ANNUAL FINANCE Amount Total of PERCENTAGE CHARGE Financed Payments ?c1 osstt of your The dollar amount The amount of credit The amount you will credit as a yearly the credit will cost provided to you or on have paid after you rate. you. your behalf. have made all payments as scheduled. 8.239 % $ 306,837.15 $ 180,166.29 S 487,003.44 ? Preliminary ® Final Your payment schedule will be: No. of Payments Amount of Payments •• When Pa meets are Due 24 Monthly, b I nin February 1 2004 336 S 1 M14 211 Monthly, in February 1 2006 ? This obligation has a demand feature. ?,?? ¦? ?I ¦! This is a variable-rate Loan. Disclosures were provided to you earlier. Filing Fees S 100.00 Non-Filing Insurance $ M/A Security: You are giving a security interest in the property located at ® 9Reft Y11E AVEMIIE PAMP HILL PA 17011 Late Charge: If payment is 15 days late, you will be charged 5.00 % of the payment. Prepayment: If you pay off early, you ? may ? will not have to pay a penalty. ? may 10 will not be entitled to a refund of part of the finance charge. Assumption: Someone buying your home 10 cannot assume t?te remainder of the mortgage on the original terms. ? nay, subject to conditions, be allowed to assume the remainder of the mortgage on the original terms. See your contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date, and prepayment refunds and penalties. e tne•ans an eey mate PROPERTY INSURANCE: ® Property hazard insurance to replace the cost of improvements with a loss payable clause to the lender is a required condition of this loan. Borrower may purchase this insarance from any company acceptable to the lender. Hazard insurance ? is ® is not available through the Lender at an estimated cost of for a year term. UWe bomb acknowledge eceipt of this disclosure. NE A STE Date Date Date Date •' NOTE: Payments shown above do not include deposits for taxes, assessments, and property or flood insurance. UNWMM tat/uut / TIL-ARM t 1-0 DE 091503 7 Q C exl.;h', t S? I(Page 1 , of 5) dpl. Lon Loan StWicingl' 7/24/2006 Thelma Steidle 2600 Yale Avenue Camp 1-Ell, PA 17011 ACT 91 NOTICE 4828 Loop Cen ftal Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 vn;vm,.1ittonloan.com TAIL ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the morteaee on voar home is in default and the lender intends to foredose Specific information about the nature of the default is provided in the attached page. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your bome This Notice explains -how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WrIWK 30 DAYS OF-THE DATE OF THIS NOTICE. Take this Notice with you whea you meet with the Counseling Agency.. The name. address, and phone number of Consumer Credit Counseling Agencies seining Your Countv are listed at the end of the Notice If von have any aaestions. you may call the Pennsylvania Housing Finance Agency toll- free at (800) 342-2397. Persons with impaired hearing can call (7171790-1869. 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTMICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUBS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTMCACION OBTENGA UNA TRADUCCION INMEDIATAMENTE L. •AMANDO ESTA AGENCIA PUEDES SER ELEGIIBLE PARA ITN PRESTAMO POR EL PROGAMA IJ""O "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIIt SU HIPOTECA. EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER CURRENT LENDERISERVICER Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 11817699 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S 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 of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the 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 DE A n T " EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - 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 addresses and telephone numbers of desigoated consumer credit co miging_aeenrirs for the cou r y in which the =,pertv is 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 inventions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth latter 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 forfrnanaial 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. U FIQ,E YQUR AJPPXJCATIQN PROMPTLY. IF YOU FAIL TO DO SO ORIF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, PROCEED AGAINST YOUR HOME IIMAMDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. r ?. • (Page of 5) 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 Bring it up to date.) NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at 2600 Yale Avenue, 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: " 2/1/2006 through 711/2006 at $1,586.62 totaling $9,519.72 Other charges Late charges $76.86 Deferred late charges $317.67 NSF charges $0 Deferred NSF charges $0 Suspense balance $0 TOTAL AMOUNT DUE AS OF THIS DATE 59,914.25 B. YOU HAVE FAMED TO TAKE THE FOLLOWING ACTION: Cure the default HOW TO CURE THE DEFAULT --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 $9,914.25 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: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire Liston Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 outstanding balance of this 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 instr= its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off 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 fee 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 .__actuallzT pggK ud by the lender even if they exceed $50.00. Aar attorney's fees will. be added to the amount you owe the lender, which - -- may also include other rea-sonabre cost`s. 7i"you care tfie d?a?wr?t#ritrthe2'i?`(38}-DAB period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due-Lnder the mortgage. V -11 1 (Page 4 of 5) 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 paying 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 Sheriffs Sale as specified in writing by the lender and by performing any other requirements 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 Sheriff's Sale of the mortgaged property could be held would be approximately 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 be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number. (713) 966-8906 Contact Person: Default Administration Department 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 - Under the tenons of your mortgage and rote, it may be possible to 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 INS=MON 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 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 INS= TIED 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland a ! (image 5,, or s? CCCS of Western Pennsvivania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717(541-1757 (888)511-2227 Urban League of Metronoiitan Harrisburg N. 6th' Street Harrisburg, PA 17101 (717)234-5925 FAX(717)234-9459 Adams County Housing Authority 139-143 Carlisle St Gettvsbu m. PA 17325 (717)334-1518 FAX(717)334-8326 Financial Counseling Services of Franklin 31 West 3rd Street Wavnesboro, PA 172,68 (717)762-3285 ;YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(717)731-9589 M Communitv Action Comm of the Capital Region 1514 Derry Street Harrisburg. PA 17104 (717)232-9757 FAX(717)234-2227 rw NOTICE NOTICE TO BORROWERS: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT OWED BY YOU. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. UDREN LAW OFFICES, P.C. /s/ Alan M. Minato, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 ?l r-..? ?' ' - ` ;.:.a ? ,1 . _ 3 _ ? ?2 m? _ T' 3 ...w 7 ' l'? s ? ? ? a KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. I.D. No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkopeAkopelaw.com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NO. 2006-5880 CIVIL TERM ANSWER TO PLAINTIFF'S AMENDED COMPLAINT AND NOW comes the Defendant, Thelma Steidle (hereinafter "Defendant" and /or "Steidle"), by her counsel, Shane B. Kope, Esquire, and assert the following Answer to Plaintiffs' Amended Complaint: 1. Paragraph one (1) refers to a written document that speaks for itself; Defendant avers that any inconsistent characterizations of the document's terms are strictly denied. 2. Admitted. 3. Paragraph three (3) refers to a written document that speaks for itself; Defendant avers that any inconsistent characterizations of the document's terms are strictly denied. 4. Denied. It is specifically denied that Defendant did not make her required mortgage payments. It is also specifically denied that Defendant failed to cure any breach of the Mortgage Agreement. It is further specifically denied that Defendant received notice of breach of the Mortgage Agreement. 5. Denied. It is specifically denied that Defendant is failing or refusing to make her mortgage payments. It is specifically denied that Defendant is refusing to pay installments of the principle interest or other charges associated with said Mortgage Agreement. 6. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. 7. Paragraph seven (7) refers to a written document that speaks for itself; Defendant avers that any inconsistent characterizations of the document's terms are strictly denied. By way of further answer, the allegations in paragraph seven (7) are comprised of legal conclusions to which no answer is required. 8. Paragraph eight (8) refers to a written document that speaks for itself; Defendant avers that any inconsistent characterizations of the document's terms are strictly denied. By way of further answer, the allegations in paragraph seven (7) are comprised of legal conclusions to which no answer is required. Page 2 of 3 WHEREFORE, Defendant respectfully requests this Court to enter judgment in her favor and against Plaintiff, together with costs, interest and any other fees the Court deems appropriate. Respectfully Submitted, KOPE AND ASSOCIATES, LLC SHANE BXOPE, Dated: February 28, 2007 Page 3 of 3 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on March,, 2007, 1 served a true and correct copy of the foregoing Answer to Plaintiff's Amended Complaint via first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (Attorney for Plaintiff) KOPE & ASSOCIATES, LLC Shane 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I.D. No. 92207 Attorney for Defendant ? ?' ? ? -r? - ? ?.,;?z _ ti . , r. , ` ? _ rv _ ` , , `_f? ? ? ?? ? ? ?. ,? ?'1 1 . a UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee under the :CIVIL DIVISION Pooling and Servicing agreement :Cumberland County dated as of April 1, 2004, GSAMP Trust 2004-NC1 ':MORTGAGE FORECLOSURE 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Thelma Steidle =NO. 06-5880 CIVIL TERM 2600 Yale Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Thelma Steidle for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 9/21/06 to 2/27/07 Late charges per Complaint From 9/21/06 to 2/27/07 Escrow payment per Complaint From 9/21/06 to 2/27/07 $204,220.91 7,606.40 384.30 247.10 TOTAL $212,458.71 I hereby certify that (1) the addresses of the Plaintif and Defendant are as shown above, and (2) that notice has been given in ccordance with Rule 237.1, a copy of which is attached hereto. OFFICES, P.C. DAMAGES ARE HEREBY ASSESSED AS DATE : ffi fiG .2, Zm T MSC J. Udren, ESQUIRE Attorney for Plaintiff INDICATED ID PRO ROTH VDREN LAW OFFICES, P.C. BY. Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant(s) TO: Thelma Steidle c/o Shane B,Es & Associates,Lzc 4660 Trindle Road,Suite 201 Camp Hill, PA 17011 DATE of Notice: February 14, 2007 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU-ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR.NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717=249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,. EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR. SENTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 I 717-249-3166 / 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTTQpR AND THI AN ATTEMPT O COLLECT A DEBT. ANY INFORMATION OBTAINED WILL $E\USED FOR HAT IKURPOSE. YV odcrest Corporate Center 11 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P. C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as Trustee under the Pooling and Servicingg agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant(s) TO: Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 DATE of Notice: February 14, 2007 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY. OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUSA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA•TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 / NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES A959, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT T/0/ COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. uacu, aJ a e 'j-c, oodcrest C orporat Center it Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 :MORTGAGE FORECLOSURE Plaintiff V. Thelma Steidle `:NO. 06-5880 CIVIL TERM Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: r Defendant: Thelma Steidle Age: Over 18 Residence: As captioned a Employment: Unknown Sworn to and subscribed before me this 27th day of February, 2007. A o ry 15-ublic LY G1LlLLr . i'lr itlb V • VLaYa, yv]i[ . Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. SHERIFF'S RETURN - REGULAR CASE NO: 2006-05880 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS STEIDLE THELMA VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEIDLE THELMA the DEFENDANT , at 2032:00 HOURS, on the 18th day of October , 2006 at 2600 YALE AVENUE CAMP HILL, PA 17011 by handing to THELMA STEIDLE 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 Sworn and Subscibed to before me this of So Answers: 18.00 13.20 .00 10.00 R. Thomas Kline .00 41.20 10/19/2006 UDREN LAW OFFICE By: /i day 5eputy h iff A. D. ~?. -0 Or (1 s ?yA?? r ,` t t (Y \ f ,, ? t ,ty} l 1V7 ? ? C-? 7 '`d UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM To: Thelma Steidle c/o Shane B. Kope, Esq. & Associates, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Ju+ Judgment Judgment Judgment Judgment Judgment Prothonotary 3gment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Escru.ire At this telephone number: 856-669-5400 f KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. I.D. No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkopea_kopelaw.com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive : Houston TX 77081, Plaintiff, V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. : NO. 2006-5880 CIVIL TERM PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Please attach the enclosed Verification signed by the Defendant to the Answer to Plaintiff's Amended Complaint that was filed in the above captioned matter. Respectfully Submitted, A S, LLC y: o e E ire 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I.D. 92207 (Attorney for Defendant) A. KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. I.D. No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkope kopelaw.com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NO. 2006-5880 CIVIL TERM CERTIFICATE OF SERVICE I, Julie Wehnert, Paralegal, hereby certify that on March 13, 2007, 1 served a copy of the foregoing Praecipe to Attach Verifcation by first class United States mail upon the following: Udren Law Offices, P.C. Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 PE & ASS CIATES, LLC ie Wehnert, Paralegal lJ 4 lie Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 VERIFICATION I, Thelma Steidle, the Defendant in this matter, have read the foregoing Answer to Plaintiff's Amended Complaint. I verify that my averments contained therein are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: 0 ?A.&Y?-S?`J 1-, Thelma Steidle ?5 -.-' --,? ?'.?, ? ? ,., . ,L.. ;, - ? -? ??`a ?? _._._ t UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM V. Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT TO THE PROTHONOTARY: Kindly withdraw the Judgment entered on March 2, 2007 upon Thelma Steidle in the amount of $212,458.71. Defendant(s), Thelma Steidle filed HAS FILED AN ANSWER. UDREN LAW OFFIIC?S, P.C. Mark J Y Udren, quire ATTORNEY FOR PLAINTIFF DATED: March 8, 2007 ?? {? ? ,--- ??`,, SF .;:? t':= ,4`?}?' <- c , + . dh PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle NO. 06-5880 CIVIL TERM Defendant 1. State matter to be argued (i.e. plaintiff s motion for new trial, defendant's demurrer to complaint, etc.): Plaintiff's Motion for Summary Judgment 2. Identify counsel who will argue case: (a) for plaintiff. Mark J. Udren, Esquire Address: Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (b) for defendant: Julie Wehnert, Esquire Address: Kope & Associates 4660 Trindle Road, Suite 201 Camp Hill, NJ 17011 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: August 15, 2007 Dated: June 2K, 2007 ? ?a ? -r? ...? ? ? ' ? ? ? ? s r?rt ? ? ?, N , ' ? - `? - ? 'f' .. .? , .? . 4 i ? A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as COURT OF COMMON PLEAS Trustee under the Pooling and Servicing = CIVIL DIVISION agreement dated as of April 1, 2004, GSAMP Cumberland County Trust 2004-NC I Plaintiff V. Thelma Steidle NO. 06-5880 CIVIL TERM Defendant CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I served true and correct copies of Plaintiff s Motion for Summary Judgment and Brief in Support and Argument Praecipe upon the following person named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: June 2$, 2007 TO: Julie Wehnert, Esquire Kope & Associates 4660 Trindle Road, Suite 201 Camp Hill, NJ 17011 Attorney for Defendant 1 m rs' 0 C cJJ 0 t? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as = COURT OF COMMON PLEAS Trustee under the Pooling and Servicing ' CIVIL DIVISION agreement dated as of April 1, 2004, GSAMP Cumberland County Trust 2004-NC 1 Plaintiff V. Thelma Steidle Defendant NO. 06-5880 CIVIL TERM PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Plaintiff, Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI, by its Attorney, Mark J. Udren, Esquire, respectfully requests your Honorable Court to enter an Order granting Summary Judgment in the above-captioned matter for the following reasons: 1. There are no genuine issues as to any material fact, and therefore, Plaintiff (moving party) is entitled to Judgment as a matter of law. 2. Defendant Thelma Steidle filed an Answer to the Complaint in which Defendant effectively admitted all of the allegations in the Complaint. 3. At the time of this pleading, Defendant owned the premises being foreclosed without making a mortgage payment for an excessive period of time. 4. Defendant admits outright, and/or in part, paragraph 2 of the Complaint, thereby admitting, inter alia, that Defendant is the real owner and mortgagor of the within mortgaged property. 5. Although Defendant purports to deny and/or fails to deny, in whole or in part, specifically or by necessary implication, the averments contained in paragraphs 1, 3, 4, 5, 6, 7 and 8 of the Complaint, in reality, said denials are improper and should be deemed as admissions for the reasons set forth in the attached Memorandum of Law. a 6. The Pennsylvania pre-foreclosure Act 6 Notice is not required as the Defendant's original principal balance on the Mortgage is greater than $50,000.00. 41 P.S. Section 101, et M. See Exhibit "A" attached hereto (Mortgage). 7. Plaintiff complied with the Pennsylvania pre-foreclosure Notice requirements of Act 91 (35 P.S. Section 1680.401c, et seg.). 8. Plaintiff has an express contractual right pursuant to the terms of the Mortgage to charge the Defendant attorney's fees as a consequence of the initiation of the within action in mortgage foreclosure. In addition to the amounts due and owing as set forth in the Complaint, additional sums have accumulated since the filing of the Complaint, pursuant to the terms of the Mortgage. The total amounts due and owing, which sums can be calculated from the face of the Complaint, are as follows: Principal of debt due and unpaid $181,209.17 Interest at ARM 9.45% from 1/1/06 to 5/31/06 (the per diem interest accruing on this debt is $47.54 and that sum should be added each day after 5/31/07) 27,261.70 Title Report 325.00 Court Costs (anticipated, excluding Sheriffs Sale costs) 280.00 Escrow Overdraft/Balance City tax $3,694.64 County tax $3,968.70 Forced Place Insurance $593.00; Other tax $5.00 8,261.34 Late Charges 250.26 BPO Fee 307.00 Property Inspection 107.00 Attorney's Fees (anticipated and actual to 5% of principal) 9,060.46 TOTAL $226,647.93 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. WHEREFORE, Plaintiff respectfully requests that the Honorable Court grant its Motion for Summary Judgment, and that Judgment be entered, in rem, as prayed for in the Complaint in favor of the Plaintiff and against the Defendant, Thelma Steidle, in the amount of $226,647.93, together with ongoing per diem interest, escrow advances, and any additional recoverable costs to date of Sheriffs Sale; and for foreclosure and sale of the mortgaged property. Respectfully submitted, C. UDREN LAW OF r, By: Mark. J."Udren, lfuire Attorney fpr Plaintiff/Movant n O C_ -11 y rn ? N CD UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust '--COURT OF COMMON PLEAS Company as Trustee under the 'CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 ':NO. 06-5880 CIVIL TERM Plaintiff V. Thelma Steidle Defendant(s) PRAECIPE TO ATTACH AFFIDAVIT AND VERIFICATION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT TO THE PROTHONOTARY: Kindly attach the enclosed Affidavit and Verification to Plaintiff's Motion for Summary Judgment which was filed on July 2, 2007. UDREN LAW OFFICES, P.C. LA\,- BY: Mark J. Udren, Esquire ATTORNEY FOR PLAINTIFF ?A ? UDREN LAW OFFICES, P.C. BY. MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC 1 Plaintiff V. Thelma Steidle Defendant STATE OF {; lcS COUNTY OF E'I S ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM AFFIDAVIT SS I, Denise Bailey , being duly sworn according to law, depose and say: 1. That I am the Assistant;Secretary for Litton Loan Servicing, LP, the servicing agent for the Plaintiff in the within matter. 2. That in said capacity I am fami iar with the account that forms the basis of the instant foreclosure action and that I am authorized to take this Affidavit. 3. That all notices, if required to be sent to the Defendant pursuant to Act 6 of 1974 and Act 91 of 1983, have been sent pursuant to the requirements of those Acts on the dates appearing thereon, copies of said notices being attached to the Complaint as Exhibits, if applicable. 4. The amounts due on the Mortgage were correctly stated as of the date appearing in the Complaint, in paragraph 6 thereof and have accumulated since the filing of the Compl int, as follows: Principal of debt due and unpaid $181,209.17 Interest at ARM 9.45%* from 1/1/06 to 5/31/07 (the per diem interest accruing on this debt is $47.54 and that sum should be added each day after 5/31/07) 27,261.70 Title Report Court Costs (anticipated, e) Escrow Overdraft/Balance City tax County tax Forced Place Insurance Other tax 325.00 :chiding Sheriffs Sale costs) 280.00 8,261.34 $3,694.64 3,968.70 593.00 5.00 Late Charges 250.26 BPO Fees 307.00 Property Inspection Fees 107.00 Attorney's Fees (anticipated and actual to 5% ofprincipal) 9,060.46 TOTAL $226,647.93 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 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Notary Public VERIFICATION The undersigned, the servicing agent for the Plaintiff in the Motion for Suinrnary JudgmeM being authorized to make this Verification on behalf of the Plairta hereby verifies that the facts set forth in the Motion for Summary Judgment are taken from the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is rrrade subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Litton Loan Servicing, LP By: 14 V4 ?', 7 Name: Denise Bailey Title: Assistant Secretary Dated: Litton Loan Servicing LP Attorney in Fact UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO.04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 :NO. 06-5880 CIVIL TERM Plaintiff V. Thelma Steidle Defendant(s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served a true and correct copy of the Praecipe to Attach Affidavit and Verification to Plaintiffs Motion for Summary Judgment upon the following person(s) named herein at their last known address or their attorney of record: xxxxx Regular First Class Mail Certified Mail Other Date Served: July a), 2007 TO: Julie Wehnert, Esquire Kope & Associates 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 Attorney for Defendant UDREN LAW OFFICES, P.C. r n BY : v Mark J. Udre , -Esquire Attorney or Plaintiff ?-? t?.? i"' , t? .? ?.? r. ? ?W, r? 7 t.. i.;'? _t ,fit ,,_? 'r .+.3 '? i_ '"? DEUTSCHE BANK NATIONAL TRUST, COMPANY as TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2004, GSAMP TRUST 2004 NC1 4828 Loop Central Drive Houston, TX 77081, Plaintiff VS. THELMA STEIDLE, 2600 Yale Avenue Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 CIVIL TERM 06-5380 ENTRY OF APPEARANCE AS LOCAL COUNSEL Dear Sir: I hereby enter my appearance as local counsel, in conjunction with the Udren Law offices, for the limited purpose of representing Plaintiff at Argument Court to be held on Wednesday, August 15, 2007 on Plaintiff's Motion for Summary Judgment. Date: August 13, 2007 Q4? 1 Dale F. S ughar J . Supreme Court I. 93 3 10 West High Street Carlisle, PA 17013 (717) 241-4311 CC: Mark J. Udren, Esquire Shane B. Kope, Esquire C) C o V -Tj FT- OD DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2004, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. THELMA STEIDLE, DEFENDANT : 06-5880 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2007, the motion of plaintiff for summary judgment against defendant Thelma Steidle, IS GRANTED. Judgment in rem is entered in favor of plaintiff and against defendant in the amount of $226,647.93 with interest and costs. By th Edgar B. Bayley, J. ,.,Mark J. Udren, Esquire Xale F. Shughart, Esquire For Plaintiff Xhane B. Kope, Esquire For Defendant J :sal _t 5 -- C-3 f-o uC3 c?-? UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM PRANCIPE FOR JUDGMENT BASED ON COURT ORDER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), Thelma Steidle pursuant to the Court's Order dated August 20, 2007 (in accordance with the Complaint) and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Court Order $226,647.93 TOTAL $226,647.93 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that a true and correct copy of the Praecipe has been mailed pursuant to Pa.R.C.P. Rule 237. OFFICES, P.C. arc J. Udren, ESQUIRE t orney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : _ gla?7 R PROTHY I _1 UDREN LAW OFFICES, P.C. BY: NARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff v. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers, Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Thelma Steidle Over 18 As captioned Unknown Sworn to and subscribed before me this 28th day of August, 2007. No ary tNWO NEN1,18M C&Wdon Etas 1116/7008 above Nam K J. UDREN, ESQ. Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. WREN LAN OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 NOODCREST CORPORATE CENTER 111 NOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the =CIVIL DIVISION Pooling and Servicing ::Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 :MORTGAGE FORECLOSURE Plaintiff V. Thelma Steidle NO. 06-5880 CIVIL TERM Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. LAW OFFICES, P,,C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ? Q -st ? ! UDREN LAN OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Deutsche Bank National Trust. Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM To: Thelma Steidle c/o Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary 151 OU4.a icaw '046 81x9/o7 Judgment on Award of Arbitration Judgment on Verdict x Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J Udren, Esquire At this telephone number: 856-669-5400 s .v r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. c Thelma Steidle NO. 06-5880 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $226,647.93 Interest From 07 8,937.52 to Date of Sale 1,2/5/07 Ongoing Per Diem of g4'?54 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. N?rft J. Udren, ESQUIRE A ORNEY FOR PLAINTIFF A ?V H? V6 Q ? ? -? v S 13 S s a Gam s? -. (J T "'A, "'t'1 'TJ co w ? lw I . v UDREN LAW OFFICES, P.C. BY: Nark J. Udren, Enquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004- NC1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 2600 Yale Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed owner(s): Name Address Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Target National Bank 213 East Street, Carnegie, PA 15106 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust 4828 Loop Central Drive Company as Trustee under the Houston, TX 77081 Pooling and Servicing agreement dated as of 4/1/04, GSAMP Trust 2004-NC1 46 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Name Address Tenants/Occupants 2600 Yale Avenue Camp Hill, PA 17011 Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C DATED: August 28, 2007 Mai. Udren, ESQ. Att ev for Plaintiff '?'t -.., ?f ? ? Ci'7 !"' ] ? y i .?- -C7 '? -ii ?? _1 w ? 1 UDREN LAMP OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Thelma Steidle NO. 06-5880 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $226,647.93, obtained,by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment,, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RI48TS MM IF THE SHERIFF'S SALE DOES TARE 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 maybe 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 CANMOT AFFORD ONE, CEO TO OR TELEPHONE TEE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013, 717-249-3166 800-990-9108 UDREN LAPP OFFICES', P.C. BY: Mark J. Udren, Enquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON'PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Thelma Steidle c/o Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 .Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $226,647.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OMOR'S RIGNTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take izzediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two on how to obtain an attorney.) III, YOU MY STILL B8 ABLE TO SAVE YOUR PROPEM AND YOU HAVE OTHRR RIGHTS RVEN IF THE SHERIFF'S SALE DOES TAER PLAM, 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO Fnw OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT, LOT, OR PIECE OF LAND SITUATE IN THE BOROUGH OF CAM "HILL, COUNTY OF CUMBERLAND, AND STATE.OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE'NORTHWEST CORNER OF YALE AVENUE AND SOUTH TWENTY-SIXTH STREET; THENCE IN A NORTHERLY DIRECTION ALONG THE WESTERN LINE OF SOUTH TWENTY-SIXTH STREET ONE HUNDRED FORTY-FIVE (145) FEET TO A POINT; THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE OF A TWENTY (20) FEET ALLEY FIFTY (50) FEET TO A POINT;. THENCE IN A SOUTHERLY DIRECTION ALONG THE LINE OF LOT NO.8 OF THE PLAN OF LOTS HEREINAFTER MENTIONED ONE HUNDRED FORTY-FIVE (145) FEET TO YALE AVENUE; THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF YALE-AVENUE FIFTY (50) FEET TO THE PLACE-OF BEGINNING. TAX PARCEL NUMBER: 01-21-0271-568 BEING KNOWN AS: 2.600 YALE AVENUE, CAMP HILL, PA 17011 PROPERTY ID NO.: 01-21-0271-568 TITLE TO SAID PREMISES IS VESTED IN THELMA STEIDLE, SINGLE WOMAN BY DEED FROM ROBERT L. SHAW, SINGLE MAN, RECORD OWNER AND RICHARD A. MCBRIDE AND DIANE E. MCBRIDE, HIS WIFE, OPTION HOLDERS DATED 9/6/02 RECORDED 10/4/02 IN DEED BOOK 253 PAGE 4564. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5880 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP TRUST 2004- NC1, Plaintiff (s) From THELMA STEIDLE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendatt(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $226,647.93 L.L. Interest from 6/01/07 to Date of Sale 12/05/07 - Ongoing Per Diem of $47.54 to actual date of sale including if sale is held at a later date - $8,937.52 Atty's Comm % Due Prothy $2.00 Atty Paid $ Other Costs Plaintiff Paid Date: 8/29/07 Curtis R. Long, Prothono6ry (Seal) By: .& . Nn ? Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 ?% UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE TO THE PROTHONOTARY: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM PROOF OF SERVICE Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: October 23, 2007 BY: Ma J. Udren, Esquire At rnev for Plaintiff Deutsche Bank National Trust Co. as trustee, et. al., Plaintiff(s) vs. Thelma Steidle, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 APS File #: 085716-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Thelma Stedile Court Case No. 06-5880 State of: ss. - - - - -- --- - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - County of- Name of Server: ?5017Ag',I.V11?0? , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the day of, - , 2002, at 7Q2d o'clock P -M Place of Service: at 2600 Yale Avenue Documents Served: Service of Process on: Person Served, and Method of Service: , to Camp Hill, PA 17011 the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Thelma Stedile By personally delivering them into the hands of the person to be served. C By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Thelma Stedile at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex -f-; Skin Color ; Hair Color -" ; Facial Hair "# Approx. Age ; Approx. Height ; Appkx. Weight To the best of my knowledge and belief, said pe on as not the time of service. Signature of Server: Undersigned declares under penalty of perjury Subsc 'bed and that the foregoing is true an correct. day of ignature of Server otary Public 617 APS International, Ltd. 00MO WEALTH OF PENNSYLVANIA DweMe L Trimble, Notary Pi#lric Carlisle Bono, Cumberland County Rlotaufaf Seal My Commission E)cpires Sept. 11, 2010 in the US Military at before me this ?V .IP , 20 (Commission Expires) Member, Pennsylvania Association of Notaries rv *c _ ?-: tOr rC S I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 :NO. 06-5880 CIVIL TERM Plaintiff V. Thelma Steidle Defendant(s) 5 CERTIFICATE OF SERVICE ns c? 0 W I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of the Notice of Sale upon the following person (s) named herein at their last known address or their attorney of, record. xxxxxx xxxxxx Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: September 12, 2007 TO: Thelma Steidle c/o Julie Wehnert, Esquire 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 UDREN LAW OFFICES, P.C. By: Mark J. At t orne dren, Esquire for Plaintiff y 1 i H O n lPh n H w rn ? ? b O o IFj C4 W pC H itE N M rr C a !U IJ ? r- r •mcu Pi td r ?a 9 M F-1 0 (1) C o p r t i r ? x td r rQ H [J to O N tin t O O T?_vTa X i y MM <O0 Z v Q O zcmn?? an nm +V 1.3aMr z -i r*?i Postal - u7 u7 (Domestic No Insurance Coverage Provided) 1 For deliver information i it b i O --- O y v s our we s te at www.usps.com, 1 C a- cr - L o r rl Page $ w ru ru p p Certified Fee ?- o .? p o p Return Receipt Fee (Endorsement Required) ' I Postmark Here M t7 Restricted Delivery Fee rl r-1 (Endorsement Required) sir rl r9 rt't M Total Postage & Fees $ Ln Ln O O Sent To M --_ C3 Julie Wehnert Esquire - 1 , ------------------ N PO, Ap Box t. No or 1 4660 Trindle Road, Suite 201 or PO . . ------ Cam HiU ---t Sta--------t - -- -- ZlP 4 - PA 17011 ------------------- Cl _ _ _ y, + e, Form 3800, June 2002 See Revetse for Instructions _ k S. F z • Atma6?M8receipt Prorides: (as enea) mi z -r'oose uuoA sa ¦ A unique identifier for your malipiece ¦ A record of delivery kept by the Postal Service for two years Important Reminders: ¦ Certified Mail may ONLY be combined with Rrst-Class Mail® or Priority Mail@ ¦ Certified Mail is not available for any class of international mail. ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. • For an additional fee a Return RBCe?pt may be requested to provide proof of delivery. To obtain R;Wrn Receipt SeMCB, prease complete and attach a Return Receipt (PS Form 3811 to the article and add applicable postage to cover the fee. Endorse mailpiece Return Receipt Requested". To receive a fee waiver for a dupli .sate return receipt, a USPS® postmark on your Certified Mail receipt is requires • For an additional fee, delivery . may be restricted to the addressee or addressee's authorized a?geent?. Advise the clerk or mark the mailpiece with the endorsement 'Restricted delivery". • If a postmark on the Certified Mail receipt is desired, please present the arty cle at the post office for postmarking. 0 a postmark on the Certified Mail, receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an Inquiry. Internet access to delivery information is not available on mail addressed to APOs and FPOs. Ln irk in a 171-- Er r1 rU O O O C3I r-9 r9 m C I O O It EE dot N rr E rr U m E is r W anmFQ W S E c m 7 FD yWB?a E m N (?' N p C ? m m U = d ' n tnLL ES? Ea + R?mcma m m-.. L ` gm?m Eo ? a?`pd o> VjLL ?2 caWS cm=s vl oo,? p ? W c ma 0 2 = C H ? • ?LL a q???UOa ? A WE E'S m m a p.OV r E-EZ o`> p ty a c=cm?m if L2 -E 0 ? :yU mmE ?? x Via E Wt m mffi? ?W ? ma ' E c ,. ? Al c S4 W ° o a ?mo W w d ? c ? ai ' a m p- C A 52 ; ,2 E w C? W- +3 . N 'C W p? ? W . (L cp $Nv O p? ID t ?.V1 'C m W e a a"' > dv . m 40 'cE o C mm$ H d o ' ? > e- c ? ? _ Y ?. _ 1 ID CM3: 41.W ?Om 7N c? 0 U d) .0 L m C - w oa 0 _ ? I m m O LL 1sod ??.W ?0 CI ID ti j10?2Zl?0 ?-UU o H Q o 2 W m z v ° a r W? 0 VF W c lu W IL 0 V?L = m U _ LL©E'LU LL 40 Z 75 E _ a O ?J m oU C o ? CC C%j Zu w UJ C £ .. WN ' m Z m ?gTw Z Ea o? N :E E 4) 4) r. N N Q Z » w o CO O co E T3 7 C C d b N d ' Cl) L) 2 cf) 4) ZQZ-) J N M ?t In CC f? Ca c'q r r r dl Fp- J C m IL C O IL m L O Y C i L e. m d a 0 V 3 L 1 t0 m LL ti r m m O LL a ra c? FT, iTT 7ij T ,C) g L? cm UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust `COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing €:Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Thelma Steidle 2600 Yale Avenue :NO. 06-5880 CIVIL TERM Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the p n lt'es Aof 18 P C.S. Section 4904 relating to unsworn falsification to au h ri ie Dated: November 8, 2007 k#REN\?AW ON/ICES, P.C. BY: Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI Plaintiff V. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5880 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004- NC1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 2600 Yale Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS 41 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Target National Bank 213 East Street, Carnegie, PA 15106 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust 4828 Loop Central Drive Company as Trustee under the Houston, TX 77081 Pooling and Servicing agreement dated as of 4/1/04, GSAMP Trust 2004-NC1 5. Name and address of on the property: Name Camp Hill Borough Address 2145 Walnut Street, Camp Hill, PA 17011 Camp Hill School District 100 South 24th Street, Camp Hill, PA 17011-4609 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Name Address Tenants/Occupants 2600 Yale Avenue Camp Hill, PA 17011 Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. .S. sec. 4904 relatin o unsworn falsification to authoritiV r\ FICEA, P.C. DATED: November 8, 2007 every other person who has any record lien Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI Plaintiff v. Thelma Steidle Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5880 CIVIL TERM TO: ALL PARTIES IN INTEREST AND'CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Thelma Steidle PROPERTY: 2600 Yale Avenue Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 5. 2007, at 10:00 am, in the Commissioners Hearing Room 2"d Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 10EXHIBIT A d I o i? ?LL Q m D ? S m ((? LL ? CC .tl1 ? py O ? m N ? iEc G g„ o p c ? ? oG to 0 0 a ° o. C °t ?dya r-0) Ate' i h 'Q ? y 1 iJ J7 '.? l o ?. ?Lbc ? ??? Nal j La..z a?} - r > ?r7 ? 0 r _ ^y s cb v ? as O ???IXl? N O .a a- d ? y d ? m p CD a a ° °- ? N N .? c N O ? Q? r ? ON N ? } r O W o f ( 4U 07 cr) N tt3 > ca cU ct3 ". 6 ?O Ce) L?o t!y ao Tc as (? p..'O d. e- C O , t6 W a' O ? :r 7 O r'te` Q v 4 m r t D m •- '? r- r- m T ca 4 c -ry ..: M-0 y OpG?? r N ...?CL' 4e- U NQ G 4 C6U? d 7? ?_?- m CZ 4?cry4 U n 3 J W ! - ..N O p p N?; y N C..r m W?lNa 0Z ?^ - >. d ??'?= = 1 Z N ca 2 ,,, ca o N N- a ;to p c p? K? Zy ??? c ?cccap ?U ca °rU WSW Z 0Z o ?Wm? Zo to ~NU v Q OW 0-= rNU ? U T T d Lr) N N m? d m N M ? t?4 Q ? J T Z o?dw? 5m: a G 0 a m 0 71r a r .a .a O r.+ m Q w ? o 0 4'i m r ? r y O 3 Z d O ao QQ G)s O? ^ h- m a. ? a? .0 to r V1 C14 ! Y a r co ?XH?g1T O N v, U -R:r ce) O -c;r a : o CD O LPL M ? O U. N a s 4 Cd ?12; 4 Ir LL E k Q? E g- m C C sic) 1 T ? s, SAP 24107 4-ILJ 7 4 Q L ? a W M ? g o ? W a a G) ? C U ti W ao g N go I o uiQ w vj OVW? U W Grp zi CS U L a UQ ?? A la m ` 'u er 2 a oa$'c Z Q c ?g cv co co Cb r- ?.. " An ti --1 v ? o ?? D f CO) .w LL? ? w ? a o z I o il z L' 2 a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 4828 Loop Central Drive NO. 06-5880 CIVIL TERM Houston, TX 77081 Plaintiff V. Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: October 23, 2007 BY: Ma J. Udren, Esquire At rney for Plaintiff EXHIBIT 13 Deutsch 13,ank riational Trust Co. as trustee, et. al., Plaintiff(s) VS. Thelma Steidle, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 -Thelma Stedile Court Case No. 06-5880 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - State of: ss. County of. Name of Server: undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; y of C?? , 20Q2, at 7--,2 LO o'clock P M Date/Time of Service: that on the Zlf'da- Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: at 2600 Yale Avenue , 111 Camp Hill, PA 17011 the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Thelma Stedile By personally delivering them into the hands of the person to be served. ? By delivering them into, the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Thelma Stedile at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex 4; Skin Color /el Hair Color Facial Hair lz Approx. Age Approx. Height App x. Weight 171 To the best of my knowledge and belief, said pe on as not eng ed in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury Subsc Lbed and that the foregoing is true an correct. day of Signature of Server _ otary Public APS International, Ltd. eQOM 1QNWEAL.T! 1 OF PENNSYLVANIA Notarfed Seal Dwuft L. Trimble, Notary Public P,,at WW Boro, Curnberland County My Commission Expires Sept. 11, 2010 Msmber, Pennsylvania Association of Notaries before me this I?V kt;l , 20 (Commission Expires) EXHIBIT B APS File #: 085716-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: Deutsche Bank National Trust Co. as Trustee In the Court of Common Pleas of Under the Pooling and Servicing Agreement Cumberland County, Pennsylvania Dated as of April 1, 2004, GSAMP Trust Writ No. 2006-5880 Civil Term 2004-NCI VS Thelma Steidle Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2007 at 1354 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Thelma Steidle, by making known unto Thelma Steidle personally, at 2600 Yale Ave., Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1308 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thelma Steidle located at 2600 Yale Ave., Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Thelma Steidle by regular mail to her last known address of 2600 Yale Ave., Camp Hill, PA 17011. This letter was mailed under the date of October 23, 2007 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BY Real Estate ergeant EXHIBIT B v UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust =COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing -:Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 NO. 06-5880 CIVIL TERM Plaintiff V. Thelma Steidle De f endant (s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of the Notice of Sale upon the following person(s) named herein at their last known address or their attorney of, record. xxxxxx xxxxxx Certified Mail Regular First Class Mail other (certificate of mailing) Date Served: September 12, 2007 TO: Thelma Steidle c/o Julie Wehnert, Esquire 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 UDREN LAW OFFICES, P.C. By: 1-, 11 Mark J. Udren, Esquire Attorne° for Plaintiff EXHIBIT B H O C] ? t2 H Pi a) O N U o I x H G Pi N. K N N F'- N- to !2 N0 M rt c a M N 'E: P- F- ? :v ? PU 0 M I-l O m c ?A) n N o p, rt N- M F-J M Ti) M t2i lu M x N-'Q H rt N M N U] O Fj M O O c v o i?n? rn ? o 1-0, =0Q? F Q M 0 r- :30 -M n Z Cch M C) -n oM?m C> cz CA) M m to Lrl CERTIFIED MAIL, RECEIPT Ln Ln to (Domestic Only: No Insurance Coverage Provided) deliver For 171- y 9 ?&w Er Iff- . . r'9 r-q Postage $ M 0 C3 0 Certified Fee C3 Q Retum Receipt Fee (Endorsement Required) Postmark Here M 0 Restricted Delivery Fee r9 rl (Endorsement Required) a r-1 M m Total Postage R Fees Ln Lr) O O Sent To Q Julie Wehnert, Esquire -------------------- - in3et, Apt No.; 1 4660 Trindle Road, Suite 201 orPOeoxNo . -- - -- - Camp Hill PA 17011 - --- - , P+4 PS Form City, State. Zl 3800. June 2002 See Revuse for Instructions i x EXHIBIT B w • o GJ O s 3 y. t0 C O 0 1 -J o O M Si to w iD t-' k-' M M CD m O C3 O ru ..0 0 Ln w Lr' N h D s 0 l 0 `s •s0d:l PUB SM 01 PesseJppe llew uo elgelleAe jou sl U01 ewJ9jUI IJBAllep 01 SS9538 IBUie}Ul •lilabul ue Buipw uegm;l auessid pus ldlem slgl eAeS UNtliHOMI •ilew pus 96eisod Lwm legal xWB pue 4wiep 'pepeau iou sl idiom 4i-at Jisod Jo; eolgo isod a ll i8 elo i1syN pal;liaeO a4i uo VSwisod 8;i -Bur -life e43 iuesaJd eseald 'peJ)sap sl idiom IIeW Pe peO a4i uo )pewisod a 11 a • dungeea?pePtgsad. iuawaSJOpue e4i 4i1M 8091dll8w a4i VOW Jo MJ013 044 asinpd •iueU8 pezlJ04in8 s,eassaJPPS Jo aasseJppa e4i of paio.4wj aq Aew AJan)lep 'ea; leucgppB ue Jod a sl idlee118W pa4 •peJinbaJ pso JnoA uo >I=od ®SdS(1 a 'idweA wnlw aieo?ldnp e J0; Jenlem 0%B ameaeJ 41 ?peisenbed d wniadp aOeldllew'MOpu3 'ae; et4 JaAW of a6eis6d elge0lldd8 PPB pue "M'S e4i 01 (t WE wJOd Sd) idleoed wr4ay 8 408;ie PUB aisldwoO eseeld ' idleoeH wn}akl ul8igo of •AJan)lep ;O lod'd eplnaui of p%sanbw eg CawperJey wryaa a ee} l8uoluPPe u8 Jod a '118W PeJeisiGed w pEunsul Japlsuoo esseld'selg8npA Jod TBW Pa9li1e'J 4Vm a3UlAOdd SI 3OV143AOO 3ONbdliSNl ON a •eew IOU04BUJMul10 SSOP AM Jo; e1g811sns leu sl IIsW peygJeO a ®IIBW Aiuoud 10 Ollie n SM10-isAd 4Pm POW oo eq AINO A8w IIBW pa!iliaeO a :siepulured i avadwl sJesA onni JO; eOIAMS IBisod ew Aq ida)l AJenllap ;OPJOOM y ¦ waldilew JnoA Jo; Jaguep onblun V ¦ PS Form 3800, June 2002 (Reverse) idiom 5u1jIBw y a :saplAad 118N P610183 IF EXHIBIT B ?I ?m ? w ? I ? ` = s 'O y N y O 5 y td ? m Qv cw v xi O D U.- spy WO Q G O .+ N O- O ??an s all o w o ra 'fl v ?? w ?vc:W o .o a ?r m d? 4 w LiJ D a W o p: ? ;11y m m N C O N a W OV.Z aU to d N Q 'o o V;pflG. Cl) mW W Z ?, ca S b C? r h);E Swam i ML d^ H N M? to V ? y ?3 Y N .? y ? d Tip, (a 0 GG Q T m"fl'r?C) G Yp1f???s? C.m N? ? G m ? O1 o s E o to C??$ N-gym c L m m 3 10 U 9 = 6..5 U N O. N ?v O P A ?'EuNmE to m W$?? m co°'arn m om' ?tfl c m o ? va c?i m o°om?N u ?A c° ms m vm`r'Y? E 0 ?E? a 0 0. m O C r y n. m V E 0 d LL `m =y 0 LL N o? tD I LO 0 te) Q `22(^? ` ? 1 t t . . i .y s yn - ? KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. Court ID No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkopeO-kopelaw.com ------------------------------------------------------ Attorney for Defendant Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, : NO. 2006-5880 CIVIL TERM 2600 Yale Avenue Camp Hill, PA 17011, EMERGENCY PETITION FOR STAY OF EXECUTION NOW COMES the Defendant, Thelma Steidie, by her attorney, Shane B. Kope, Esq., and petitions this Honorable Court for a stay of execution, and in support thereof alleges as follows: 1. Plaintiff confessed judgment against the Defendant on August 20, 2007. 2. Pursuant to Writ of Execution, Plaintiff caused the Sheriff of Cumberland County to list for Sheriff's Sale Defendant's residence located at 2600 Yale Avenue, Camp Hill, PA 17011; the date for sale is December 5, 2007 at 10:00 a.m. A copy of the notice of Sheriffs Sale is attached hereto as Exhibit "A." 3. The Defendant has since found a buyer for her home and has, therefore, been working directly with the Plaintiff to secure Short Sale approval, which will satisfy Defendant's obligation to the Plaintiff and defeat the need for the Sheriff's Sale in this matter. 4. The Loan Company approved Defendant for a Short Sale on November 20, 2007. 5. Because of the late approval of the Short Sale, it is necessary to stay the Sheriffs Sale until settlement on the Short Sale can be completed. 6. Consequently, Defendant's counsel has been repeatedly trying to reach a representative and/or legal counsel for Plaintiff so as to request that the pending Sheriffs Sale be stayed in light of Plaintiffs approval for the Short Sale; unfortunately, said attempts were to no avail. 7. Unless the Sheriffs Sale is stayed, it will continue as planned on December 5, 2007. 8. Because of Plaintiffs approval for the Short Sale, Plaintiff has the right to stay the Sheriffs Sale for a reasonable amount of time in order to complete settlement on the Short Sale. 9. Unless the Sheriffs Sale is stayed, the Plaintiff will incur substantial and long- term damages that are wholly unnecessary in light of her approval for Short Sale by Plaintiff 10. Under the circumstances, therefore, it would be inequitable to permit the Plaintiff to proceed with the scheduled Sheriffs Sale at this time. Page 2 of 3 WHEREFORE, Defendant requests a stay of execution for a period of sixty (60) days of this petition. Respectfully Submitted, KOPE AND ASSOCIATES, LLC PE SQ. Dated: November 28, 2007 S Page 3 of 3 11/28/2007 14:30 717-761-7572 KOPE & AS50CATES PA(ah bb/bf VERIFICATION i, Th6lma Steidle, the Defendant in this matter, have read the foregoing Petition to stay Execution. I verify that my evennents In this document are true and correct and based upon my personal knowledge. i understand that any Was statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falslfioations to authorltles, Dated: l ? ?'2(z ? `~ J h Thelma Steidle [00A0012 NOIIVZIN830ON A3VJ31 ME Z0E ZLL XV3 VE:SL ZOOZ/8Z/LL UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the 'CIVIL DIVISION Pooling and Servicing -'Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 'MORTGAGE FORECLOSURE Plaintiff v. Thelma Steidle .NO. 06-5880 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Thelma Steidle c/o Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is,scheduled to be sold at the Sheriff's Sale on December 5, 20071 at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $226,647.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back p late charges, costs and reasonable attorney's fees. To find outhowemuch you must pay, you may call: _(856)-669-5400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two 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 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, co TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association .2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 8Q,0-?90-9108 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on November 28, 2007, 1 served a true and correct copy of the foregoing Petition to Stay Execution via facsimile and first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire or Alan M. Minato, Esq. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Fax: 856-428-9680 (Attorneys for Plaintiff) IATES, LLC SKope, Esq. 4660 Trindlee 65, uite 201 Camp Hill, PA 17011 (717) 761-7573 Court ID 92207 (Attorney for Defendant) j -? ' ' ?? + , 3 ? _ , ..., ... :._ja rte s " ?. ? ? ,. t:r',? } t`i1 ? : ; (*J . r %:?. .?x? -.c NOV 292007 Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NO. 2006-'(CIVIL TERM ORDER AND NOW, this day of 6X-Q4 , 2007, upon consideration of Defendant's Petition to Stay Execution, it is hereby ORDERED AND DECREED that Defendant's Petition is granted and the Sherrifs Sale that is too cur in a above captioned matter on December 5, 2007, Sa& Cwt A CAJVhI) ? q-1 . co CD C KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. Court ID No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkope(&-kopelaw. com Attorney for Defendant ------------------------------------------------------ Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004 NCI 4828 Loop Central Drive Houston TX 77081, Plaintiff, : The Honorable Judge Edgar B. Bayley V. Thelma Steidle, : NO. 2006-5880 CIVIL TERM 2600 Yale Avenue Camp Hill, PA 17011, SECOND EMERGENCY PETITION FOR STAY OF EXECUTION NOW COMES the Defendant, Thelma Steidle, by her attorney, Shane B. Kope, Esq., and petitions this Honorable Court for a stay of execution, and in support thereof alleges as follows: 1. Plaintiff confessed judgment against the Defendant on August 20, 2007. 2. Pursuant to Writ of Execution, Plaintiff caused the Sheriff of Cumberland County to list for Sheriffs Sale Defendant's residence located at 2600 Yale Avenue, Camp Hill, PA 17011; the original date of sale was December 5, 2007 at 10:00 a.m. A copy of the notice of Sheriffs Sale is attached hereto as Exhibit "A." 3. The Defendant, however, had found a buyer for her home and, therefore, worked directly with the Plaintiff to secure Short Sale approval, which would satisfy Defendant's obligation to the Plaintiff and defeat the need for the Sheriffs Sale in this matter. 4. The Loan Company approved Defendant for a Short Sale on November 20, 2007. 5. Because of the late approval of the Short Sale, it was necessary to stay the Sheriffs Sale until settlement on the Short Sale could be completed. 6. Therefore, Defendant's counsel filed a Petition to Stay Execution November 28, 2007. 7. This Petition was unopposed by the Plaintiff. 8. Said Petition was granted on November 29, 2007 by President Judge Bayley thereby continuing the Sherriffs Sale until January 9, 2008. A copy of the notice of Sheriffs Sale is attached hereto as Exhibit "B." 9. Although Defendant's counsel has been working diligently to complete settlement of the Short Sale before the Sheriffs Sale on January 9, 2008, there remains one outstanding issue: the Buyer is waiting to have the sale certified by his loan company's underwriters. Although Defendant's counsel received verbal communication that the sale would be certified, written confirmation of such could take until January 11, 2008, which is two (2) days after the Sheriffs Sale is scheduled to occur. 10. By way of caution, therefore, it si necessary to file another Petition to Stay Execution. Page 2 of 3 11. Defendant's counsel contacted Plaintiffs counsel who granted their concurrence with this Petition. 12. Unless the Sheriff's Sale is stayed, it will continue as planned on January 9, 2008, depriving the Defendant of her opportunity to sale the home as agreed upon by Plaintiff and Defendant. 13. Because of Plaintiffs approval for the Short Sale, the Defendant has the right to stay the Sheriffs Sale for a reasonable amount of time in order to complete settlement on the Short Sale. 14. Unless the Sheriffs Sale is stayed, the Defendant will incur substantial and long- term damages that are wholly unnecessary in light of her approval for Short Sale by Plaintiff. 15. Under the circumstances, therefore, it would be inequitable to permit the scheduled Sheriffs Sale at this time. 16. This will be the final Petition to Stay filed by the Defendant. WHEREFORE, Defendant requests a stay of execution for a period of fourteen (14) to thirty days (30) from the date of this petition. Respectfully Submitted, KOPE AND ASSOCIATES, LLC SHANE . Dated: January 4, 2008 Page 3 of 3 7 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing =Cumberland County agreement dated as of April 11 2004, GSAMP Trust 2004-NC1 ':MORTGAGE FORECLOSURE Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY:, Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 080 03-3620 856-669-5400 Thelma Steidle V. Defendant(s) NO. 06-5880 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY . To: Thelma Steidle c/o Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill,.PA 17011 Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is,-scheduled to be sold -at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners'Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to-enforce the court judgment of $226,647.93, obtained by Plaintiff above (the mortgagee) against you. If.-the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWMM'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing.a petition.asking the Court to strike or open the 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 on page two 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 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30.days after the 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 Schedule of Distribution is filed. 7: You may also have other rights and defenses, or ways of getting your home 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 TIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association .2 Liberty Avenue Carlisle, PA 17.013. 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 8.a0-.1"0-9108 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on November 28, 2007, 1 served a true and correct copy of the foregoing Petition to Stay Execution via facsimile and first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire or Alan M. Minato, Esq. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Fax: 856-428-9680 (Attorneys for Plaintiff) TES, LLC Sh'afl . Kope, Esq. 4660 Trindle oa , bite 201 Camp Hill, PA 17011 (717) 761-7573 Court ID 92207 (Attorney for Defendant) NO V 2 9 2007 Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004 NC1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NO. 2006-5141 CIVIL TERM ORDER AND NOW, this --Zlt day of , 2007, upon consideration of Defendant's Petition to Stay Execution, it is hereby ORDERED AND DECREED that Defendant's Petition is granted and the Sherrif s, that?`occur in a above captioned matter on December 5, 2007, '? c?A CM. A cKo ( ? j 'Z?1DU • KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. Court ID No. 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkopeCa)_kopelaw.com Attorney for Defendant Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004 NC 1 4828 Loop Central Drive Houston TX 77081, Plaintiff, V. Thelma Steidle, : NO. 2006-5880 CIVIL TERM 2600 Yale Avenue Camp Hill, PA 17011, EMERGENCY PETITION FOR STAY OF EXECUTION NOW COMES the Defendant, Thelma Steidie, by her attorney, Shane B. Kope, Esq., and petitions this Honorable Court for a stay of execution, and in support thereof alleges as follows: 1. Plaintiff confessed judgment against the Defendant on August 20, 2007. 2. Pursuant to Writ of Execution, Plaintiff caused the Sheriff of Cumberland County to list for Sheriffs Sale Defendant's residence located at 2600 Yale Avenue, Camp Hill, PA 17011; the date for sale is December 5, 2007 at 10:00 a.m. A copy of the notice of Sheriffs Sale is attached hereto as Exhibit "A." 3. The Defendant has since found a buyer for her home and has, therefore, been working directly with the Plaintiff to secure Short Sale approval, which will satisfy Defendant's obligation to the Plaintiff and defeat the need for the Sheriffs Sale in this matter. 4. The Loan Company approved Defendant for a Short Sale on November 20, 2007. 5. Because of the late approval of the Short Sale, it is necessary to stay the Sheriffs Sale until settlement on the Short Sale can be completed. 6. Consequently, Defendant's counsel has been repeatedly trying to reach a representative and/or legal counsel for Plaintiff so as to request that the pending Sheriff's Sale be stayed in light of Plaintiffs approval for the Short Sale; unfortunately, said attempts were to no avail. 7. Unless the Sheriffs Sale is stayed, it will continue as planned on December 5, 2007. 8. Because of Plaintiff's approval for the Short Sale, Plaintiff has the right to stay the Sheriffs Sale for a reasonable amount of time in order to complete settlement on the Short Sale. 9. Unless the Sheriffs Sale is stayed, the Plaintiff will incur substantial and long- term damages that are wholly unnecessary in light of her approval for Short Sale by Plaintiff 10. Under the circumstances, therefore, it would be inequitable to permit the Plaintiff to proceed with the scheduled Sheriffs Sale at this time. Page 2 of 3 WHEREFORE, Defendant requests a stay of execution for a period of sixty (60) days of this petition. Respectfully Submitted, KOPE AND ASSOCIATES, LLC S PE SQ. Dated: November 28, 2007 Page 3 of 3 11/26/2007 14:39 717-761-7572 KOP? & A590CAM PAWL, idb/W VERIFICATION 1, Thelma Steidle, the Defendant In this matter, have road the foregoing Petition to Stay Execution. I verify that my averments In this document are true and correct and based upon my personal knowledge. I understand that any false statements herein are made "Ject to the Penalties of 18 Pa. C.S. 4904 relating to unsworn falefFcations to authorities, Dated: U 7 100/1000 Thelma Steidle NDIIVZIN830ON ADV031 0£lE ZOE L1L XV3 bE:91 LOOZ/SZ/11 /7 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY:j Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 080 03-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the '-CIVIL DIVISION Pooling and Servicing €:Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI :MORTGAGE FORECLOSURE Plaintiff V. Thelma Steidle =. NO. 06-5880 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Thelma Steidle .c/o Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 ,Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is,scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce.the court judgment of $226,;647.93, obtained by Plaintiff above (the mortgagee) against you. If.-the sale is postponed, the property will be relisted for the Next Available Sale. 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: i. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing_.a petition.asking the Court to strike or open the 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 on page two on how to obtain an attorney,) ?? r i YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule.of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association ..2 Liberty Avenue Carlisle, PA 17013. 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 8.0.0-?90-9108 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on November 28, 2007, 1 served a true and correct copy of the foregoing Petition to Stay Execution via facsimile and first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire or Alan M. Minato, Esq. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Fax: 856-428-9680 (Attorneys for Plaintiff TES, LLC Shy? Kope, Esq. 4660 Trindle Roa , uite 201 Camp Hill, PA 17011 (717) 761-7573 Court ID 92207 (Attorney for Defendant) '11-''29/2007 11:03 717-761-7572 KOPE & ASSOCATES LITTON LOAN LOSS MITI Fax: Wog Loan rw*dng* Nov 20, 2007 Tbekna Steidle 2600 Yale Ave Camp Hill, PA 17011-5343 Re: Litton Loan #: Borrower. Property Address: Dear Borrower(s): 11817699' Thelma Steidle, 2600 Yale Averme Camp Hill, PA 17011 PAGE 02/03 Nov 26 2007 07:17am P002/003 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 793-4363 www.littonloan.com Litton Loan Servicing LP hereby agrees to participate in the assisted abort We of the above referenced property. This dwatud letter should be used by the closing agent as our. formal demand statement. No additional statement will be issued. This approval is exclusive to the offer by the buyer referenced in this letter. The conditions of approval era as foilows: 1.'Me closing and fitnding nrnst take place no later tban Dec 19, 2007, or this approval is void. 2.The approved buyer(s) Was (Robert Sau:m Jr and the sales price shall be $216,000.00_ Another buyer cannot be substituted without LiaWs prior written approval_ 3,Procbeds to Litton Loan Servicing LP shall be no less than $216,000.00. Litton reserves its right to adjust its approved net proceeds or cancel tktia approval if any of the terms on the preliminary Hud I provided are altered without our prior approval. The property is being sold in "Ag-WIcondition. No repairswill be paid out ofthe proceeds, unless specifically stated. 4.1he sealer will not receive any proceeds firnn this short sak transaction. If there are reimWhing escrow fwtds or refbmds of any kind, they will be sent to Litton Loan Servicing LP to offset the loss. 53hould the closing be delayed and tfte investor agrees to an exbension of the original closing data, the seller shall be responsible for per diem charges, wdension fm and foreclosure sale postponemew fees. The seller shall also be responsible for any additional costs and foes over the aforementioned approved amounts. 6.Litton Loan Servicing LP will provide a satisfaction of debt within the statutory time Intuit gowned by the Property State. 7.7he closing agent must provide a copy of the final HUD-1 closing statement at least 24 hmzrs prior to closing for final approval by Litton. Cloabag agea.klV tut Federal Express elosiag proceeds check hnmediately following closing along with a copy of the ftal fully executed E11111-1 settlement SlAtemettt t0: Litton Loan Servicing LP A.TT_ Loss Mitigation Department - Veronica Scott 4828 Loop Central Drive Houston, TX 77081 Lit= Loan Servicing LF may be required to report this transaction to the W. We recommend that you discuss this matter with your accouxttant or financial advisor. Your loan will be reported to the credit bureau as "Account Settled". Thelma Steidle Nov 20, 2007 Page 2 Litton Loan Servicing LP is a debt collector. This is an attempt to collect a debt and any information provided to •11/29/2007 11:03 717-761-7572 KOPE & ASSOCATES PAGE 03/03 9 1 TTON LOAN LOSS M I T I Fax: Nov 26 2007 07:17am P003/003 u.$ as part tf this transaction wilt be used for at purpose. Should you have any f 1her questions, feel $ee to contact tie undersigned at (800) 548-8665 ext. 4575 s adY? c 1 Ica Loss Mk ip*m Department CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on January 4, 2008, 1 served a true and correct copy of the foregoing Petition to Stay Execution via facsimile and first class mail, postage prepaid, addressed as follows: Udren Law Offices, P.C. Mark J. Udren, Esquire or Alan M. Minato, Esq. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Fax: 856-428-9680 (Attorneys for Plaintiff) KOPE & ASSOCIATES, LLC 6 w Sh'bne B. Kope, sq. 4660 Trin a oad, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Court ID 92207 (Attorney for Defendant) n N JAN 0 4 2008 p°r Deutsche Bank National Trust Company: CUMBERLAND COUNTY, PENNSYLVANIA as Trustee under the pooling and : CIVIL DIVISION Servicing agreement dated as of April 1,: 2004, GSAMP Trust 2004 NC 1 4828 Loop Central Drive Houston TX 77081, Plaintiff, : V. Thelma Steidle, 2600 Yale Avenue Camp Hill, PA 17011, Defendant. NO. 2006-.9441-,CIVIL TERM ORDER AND NOW, this day of , 2008, upon consideration of Defendant's Second Petition to Stay Execution, it is here y ORDERED AND DECREED that Defendant's Petition is granted and thriFsnSal- _ e to t is to ocd r captioned in the above C-,4Aq- 117 as ter on January 9, 204 is .{.1 V' --?y?- ???--s S der. AAa- ov? /. <1 a?/ ° t ?f ?. yfi r _ U N Deutsche Bank National Trust Co. as Trustee In the Court of Common Pleas of Under the Pooling and Servicing Agreement Cumberland County, Pennsylvania Dated as of April 1, 2004, GSAMP Trust Writ No. 2006-5880 Civil Term 2004-NCI VS Thelma Steidle Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2007 at 1354 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Thelma Steidle, by making known unto Thelma Steidle personally, at 2600 Yale Ave., Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1308 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thelma Steidle located at 2600 Yale Ave., Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Thelma Steidle by regular mail to her last known address of 2600 Yale Ave., Camp Hill, PA 17011. This letter was mailed under the date of October 23, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriff's Costs: Docketing 30.00 Poundage 16.83 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 28.80 Levy 15.00 Surcharge 20.00 Postpone Sale 20.00 Law Journal 355.00 Patriot News 325.22 Share of bills 14.92 $ 841.11 ,/ a'/'-/" So Answers: R. Thomas Kline, Sheriff BY Real Estate Sergeant ?, ,?oyga.zr s l t' I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing ::Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NCI MORTGAGE FORECLOSURE Plaintiff V. Thelma Steidle NO. 06-5880 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004- NC1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 2600 Yale Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Target National Bank 213 East Street, Carnegie, PA 15106 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust 4828 Loop Central Drive Company as Trustee under the Houston, TX 77081 Pooling and Servicing agreement dated as of 4/1/04, GSAMP Trust 2004-NC1 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Name Address Tenants/Occupants 2600 Yale Avenue Camp Hill, PA 17011 Julie Wehnert, Esq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C DATED: August 28, 2007 Ma3f?k J. Udren, ESQ. Att6riey for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Thelma Steidle NO. 06-5880 CIVIL TERM Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Thelma Steidle 2600 Yale Avenue Camp Hill, PA 17011 Your house (real estate) at 2600 Yale Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $226,647.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two 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 TARE 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5880 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP TRUST 2004- NC1, Plaintiff (s) From THELMA STEIDLE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property 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 $226,647.93 L.L. Interest from 6/01/07 to Date of Sale 12/05/07 - Ongoing Per Diem of $47.54 to actual date of sale including if sale is held at a later date -- $8,937.52 Atty's Comm % Atty Paid $ 1(c1. Aa Plaintiff Paid Due Prothy $2.00 Other Costs Date: 8/29/07 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, PC 's R. Long, Prothonotry By: f3k Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 65 On September 5, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA Known and numbered as 2600 Yale Avenue, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2007 By: `J? CJVi?t.l; Real Estat Sergeant u ?, Thee Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE ?e atriotwiXew s Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10124/07 10/31/07 11/07/07 e Sworn to an su cribed before me i// 30 day of November, 2007 A.D. Notary P lic COMMONWEAcrh OF PENNSYLVANIA Notanal Sea! James L. 0", Notary Public CRY Of Hanisbirg. naupft County My Commission E)Vres June 2, 2008 Member, Pennsylvania Association of Notaries --i- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. 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: October 26, November 2 and November 9, 2007 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. Li a Marie Coyne, E 'tor SWORN TO AND SUBSCRIBED before me this 9 day of November, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission ExpireS Apr 2g 20 t p REAL I WA'!Z BALE NO. 65 Writ No. 2006-5880 Civil Deutsche Bank National Trust Co. as Trustee under the Pooling and Servicing agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 vs. Thelma Steidle Atty.: Mark Udren DESCRIPTION ALL THAT CERTAIN tract, lot, or piece of land situate in the Borough of Camp Hill, County of Cumberland, and State of Pennsylvania, bounded and described as follows: BEGINNING at a point at the northwest corner of Yale Avenue and South Twenty-Sixth Street; thence in a northerly direction along the western line of South Twenty-Sixth Street one hundred forty-five (145) feet to a point; thence in a westerly direction along the southern line of a twenty (20) feet alley fifty (50) feet to a point; thence in a southerly direc- tion along the line of Lot No. 8 of the plan of lots hereinafter mentioned one hundred forty-five (145) feet to Yale Avenue; thence in an easterly direction along the northern line of Yak Avenue fifty (50) feet to the place of BEGINNING. TAX PARCEL NUMBER: 01-21- 0271-568. BEING KNOWN AS: 2600 YALE AVENUE, CAMP HILL, PA 17011. PROPERTY ID NO.: 01-21-0271- 568. TITLE TO SAID PREMISES IS VESTED IN Thelma Steidle, single woman by deed from Robert L. Shaw, single man, record owner and Richard A. McBride and Diane E. McBride, his wife, option holders dated 9/6/02 recorded 10/4/02 in Deed Book 253 Page 4564. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co. as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County agreement dated as of April 1, 2004, GSAMP Trust 2004-NC1 Plaintiff V. Thelma Steidle :NO. 06-5880 CIVIL TERM Defendant PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: March 11, 2008 UDREN W C. BY Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE +?a ;`. a ? Q r t` t -? ,r..?. .? r?.. "? ?? ? -- ? ? r ` ? -?' -' ?--' ,? £ ?V ? _ ? ? f ti ? "'. ? ' ?