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Home My WebLink About00-01510 MARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) : NO. 00 - !5'/{J (11 u\ L '-r E:IJ.h) 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 -'~~~ ,,- "1 . f1r..=~t, 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 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas 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 0 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 0 sus propiedades u otros derechos import antes 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 0 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, P A 17013-3387 717-249-3166 or 800-990-9108 "~~.!1 " . '- ~--, " , -1- L ~ 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. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire '1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 liffl<!, , - -~ -, "', ,~ 1 I' ,_. r 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: Bank united of Texas, FSB Assignments of Record to: Mercantile Bank s/b/m/t Farm and Home Savings Association Recording Date: 8/30/93 Book: 452 Page: 1150 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: 115 Charlotte Way MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 12/21/92 DATE RECORDED: 1/5/93 BOOK: 1111 PAGE: 1027 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 ,,~. , ,r I' . I 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 Note 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 2/3/00: Principal of debt due and unpaid Interest at 8.5% from 6/1/99 to 2/3/00 (the per diem interest accruing on this debt is $9.29 and that sum should be added each day after 2/3/00) $39,875.49 2,303.92 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $75.13 and that sum should be added on the first of each month after 2/3/00) 339.78 Late Charges (monthly late charge of $16.34 should be added on the fifteenth of each month after 2/3/00) 114.38 Other Fees 32.00 Attorneys Fees (anticipated and actual to 5% of principal) 1.993.77 TOTAL $45,189.34 -"'<<11<II'_, 'd:~_1 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 sent to each defendant, via certified and regular mail, accordance with the requirements of those acts, and the date appearing on the 'copy attached hereto as exhibit A, and made part hereof, and defendants have failed to proceed within the time limits, or has 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 $45,189.34, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortg Mark . Udren, ESQUIRE MARK IT. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 '-}'ll1l __ ~ iiiiiiiI..I ALL THAT CZRTAIN tlNI:T IN THE l'llOl'El!.Tr KNOWN, ........... _,D IDENTIFIED ZN TIIB DECLARATZON n.lIN. 1Il!:FERJUlD TO BELOW AS WESTWOoD CONDllMZNZUI4 LOCATED m EAST l"ENNSBD1\O TOPINSHZl', CIlI<IBE!lL1oND COUN'rY, C~H OF 1'BNNSn.VloNZA, WHICH IIlAS HEl\I!:TOFOl\l!: BEEN S1lBM:tTTED TO TIIB 1'lIDV:tSIONS 01' TIlE UNIT 1'llOl'ER'n' ~ OF 11ENNSn.Vl\N:tA. ~ 01' JULY 3, J.963 , 1'. L. 196 BY Till!: 1Il!:CORDING m TIlE OF THE ()PF!CE OF THE RECORDER OF DllBDS OF CUMIII!:RLIWI> COUN'l'l!', l'BNNSn.VloNZA OJ!' A I>ECLARATION C1lEM!mG AND ESTA8L:tllH:tNG WESTWOOD V:tLLAGI!. CONDllMZNZUI4 DATED ,J'ANU1IIl.Y 29, 1975, AND BI!lCORDED JlUlUARY 29, 1975, IN MISC. BOOK 231, AT l'ASE 283, AND AMl!:NDED BY A CZRTAIN J!'ZRS9.' AMI!:NDMI!:Ift' TO DEcr.IUlATION CRI!lATmG AND I!:STABLJ:SHmG WES'1'IIOOI> VILLAGI!: CONDOlaNZUM DATED MAY 28, 1976 AND BI!lCORDED ON JUNE 22, 1976, IN !dISC BOOK 222, PAGE 729 AND A ~ SECOND A'MI!lNDMI!:N'J TO DECLARATION CRI!lATING lIND ES'l!ABLISHmG WESTWOOD V:tLLAGI!. CONDllMZNZUI4 DATED JULY 21, 1976, lIND l\I!:CORDED ON JULY 28, 1976, IN MISC. BOOK 223, A l'AGE 343, lIND A CODE OF RllGI>LATIONS OF WESTWOOD VILLAGE CONDOMINIUM DATED JlUlUARY 29, 1975, Ann RECORDED ON JJ\NUAIlY 29, 1975. m MISC. BOOK 213 A!r PAGE 328, lIND AMl!:NDED !3Y A CERTAIN FZl\ST ~ TO CODE OF l\I!:~TIONS OF WESTWOOD VILLAGE CONDOMINIUM DATED MAY 28, 1976, AND l\I!:CORDED ON JON!!: 22, 1976, ZN MISC. BOOK 2~2 AT PAGE 737. lIND DI!:CLARATION n.lIN OF WES'1'IIOOI> VILLAGE CONDOMINIUM DATED .:JUlUAla' 29, 1975, lIND l\I!:CORDED ON JlUlUARY 29, 1975. m n.lIN BOOK 26 AT PAGE 15. lIND AMl!:NDED BY A ~ FIRST AI:<<I!\NDNZN'l TO DI!lCLI\1\A!J!ZON n.lIN OF WESTWOOD V!LLAGE CONDOMINIUM nA!rI!lD JULY 21, 1976, lIND l\I!:CORDED ON JULY 26, 1976, IN l'LAN BOOK 28 AT PAGE 72, BEING DESIGNATED ON SAUl DI!lCLI\1\A!J!ZoN PLl\N OF WE S '1'IIOOI> VILLAGE CONDOKINZUM AS llNIT NO. 115. SUZTl!i 304, KNOWN AS 115 C){l'~OTTl!i mY, SUZTE 304, blOLA, l'BNNSn.VloNZA. AS MOl\I!: FULLY DBSCRJ:llBD m SUCH DECLl\li\AT:tON l'LAN lIND DECLARATION ClIEATING lIND ES'll2\BLISHING WESTWOOD V1:LLAGE CONDOKJ:NIUM, AS TIII!l sAMe A1'l'1!ll\RS OF l\I!:CORD AS SETH FOaTH ABOVl!:, INCLUOZNG ANr AMENt>MI!lNTS THERETO. TOGETHI!:R WZTH A l'aol'ORTIONATE UND:tV:tDED INTEl\I!:ST m THE COMNON 1I!T.........NTS (AS DEFINED ZN SUCH OI!:CLl\li\AT:tON) OF NINE HUNDRED THIRTr THOUSlIND l'El!. CI!:N'I! (.930%) ~ 'f' - . . .-".. - "~,..,..--: ->:~&-~.::~~r:::~?-.~i0!:~?-.::$?f"(I~~-p;~(;gr:W':;;';:'fi14~,:U;::-,,&,;i_~,~>,'.:"":<:'l: ,'1Hll ,~,' ^ December 24, 1999 ACT 91 NOTICE TAKE ACTION TO S YOUR HOME FR FORECLOSU This is an official notice that the mortgage on your home is in efault, and the lender intends to foreclose. Specific information about the nature ofthe default s provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGR M (HEMAP) may be able to help to save your home. This notice explains how the program wor To see if HEMAP can help, you must MEET WITH A CONS MER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOT CEo Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Cm seling Agencies serving your County are listed at the end of this Notice. If you have any que tions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342~ 397. (Persons with impaired hearing can call 717- 780.] 869). . This Notice contains important legal information. If y u have any questions, representatives at the Consumer Credit Counseling Agency m be able to help explain it. You may also want to contact an attorney in your area. The local b r association may be able to help you find a lawyer. LA MOTIFICACION EN ADJUNTO ES DE SUMA IMPOR ANCIA, PUES AFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI 0 COMPRENDE EL CONTENDO DE STA NOTIFICACION OBTENGE UNA T DUCCION INMEDlT AMENTE LLAMANDO EST A AGENCIA (PENN YL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCI NADO ARRIBA. PUEDESSER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" E CUAL PUEDE SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDIMIR SU IPSTECA. EXHIBIT A - I ~', HOMEOWNER'S NAME (S): Judith H. Dahlquist PROPERTY ADDRESS: liS Charlotte Way Enola, PA 17025 LOAN NUMBER: 014125272 ORIGINAL LENDER: Bank United of Texas FSB CURRENT LENDERlSERVICER: Mercantile Bank HOMEOWNER'S EMERGENCY MORTGAGE A SISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIA ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FO ECLOSURE AND HELP YOU MAKE FUTURE MORTGAG PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF TH HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 ( HE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANC . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCU STANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEIN ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENT ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE. Under the Ac you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from he date of this Notice. During that time you must arrange and attend a "face-to-face" meet in with one of the consumer credit counseling agencies listed at the end of this Notice. THIS M TlNG MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EM RGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE U TO DA TE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTG GE DEFAULT" , EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. 2 '''''Ilr:'l\' -.., , r~~' : CONSUMER CREDIT COUNSELING AGENCIES- If yo meet with one of the consumer credit counseling agencies listed at the end of this notice, the Ie der may NOT take action against you for thirty (30) days after the date of this meeting. The nam , addresses and telephone numbers of designated consumer credit counseling agencies for he county in which the property is located are set "forth at the end of this Notice. It is only neces ry to schedule one face.to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your ortgage is in default for the reasons set forth later in this Notice (see following pages for sp cific infonnation about the nature of your default.) If you have tried and are unable to res ve this problem with thereunder, you have the right to apply for finaricial assistance from Home ner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a ompleted Homeowner's Emergency Assistance Program Application with one of the de ignated consumer credit counseling agencies listed at the end of this Notice. Only cons er credit counseling agencies have application for the program and they will assist you in su itting a complete application to the Pennsylvania Housing Finance Agency. Your application UST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF Y U FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SE FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOM IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE ENIED. AGENCY ACTION- Available funds for emergency mortgag assistance are very limited. They will be disbursed by the Agency under the eligibility criteria e tabJished by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to ake a decision after it receives your application. During that time, no foreclosure proceedings ill be pursued against you if you have met the time requirements set forth above. You will be n ified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY T FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NO ICE [S FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSID ED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Erne ency Mortgage Assistance.) NATURE OF THE DEFAULT -The MORTGAGE debt he by the above lender on your property located at: 115 Charlotte Way Enola, P A 17025 IS SERIOUSL Y IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PA MENTS for the following months and the following amount is now past due: Paym ts of $40 1.92 each for July through December 1999, $98.04 in late charges, and $8.0 in property inspections. TOTAL AMOUNT PAST DUE: $2517.56 3 ,,'~"'" ~, " B. YOU HAVE FAILED TO TAKE THE FOLLOWING AC ON: HOW TO CURE THE DEFAULT-You may cure the defaul within THIRTY (30) DAYS of the date of this notice by paying the total amount past due to th lender which is $_2517.56_. Plus any mortgage payments and late charges which become d during the thirty (30) day period. Payments must be made either by cash, cashier's chec certified check or money order made payable and sent to : Mercantile Mortgage 221 West Cherry Nevada, MO 64772 IF YOU DO NOT CURE THE DEFAULT - If you do not c e the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exe ise its rights to accelerate the mortgage debt. This means that the entire outstanding balance this debt will be considered due immediately and you may lose the chance to pay the mortgage monthly installments. If full payment of the total amount past due is not made within THIR Y (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose pon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mo gaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers y r case to its attorneys, but you cure the delinquency before the lender begins legal proceeding against you, you will still be require to pay the reasonable attorney's fees that were actually ncurred, up to $50.00. However, if legal proceedings are started against you, you will have to p all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. An attorney's fees will be added to the amount that you owe the lender, which may also include ot er reasonable costs. If you cure the default within the thirty (30) day period, you will not be re uired to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue u')Jersonally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF S SALE--- If you have not cured the default within the THIRTY (30) DAY period and foreclos e proceedings have begun, you still have the right to cure the default and prevent the sale at a time up to one hour before the Sheriffs Sale. You may do so by paying the total amount the past due, plus any late or other charges then due, reasonable attorney's fees and costs connect d with the foreclosure sale and any together costs connected with the Sheriff's Sale as specifi in writing by the lender and by performing and other requirements under the mortgage. Curin your default in manner set forth in this will restore your mortgage to the same position as if yo had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is es imated that the earliest date that such a Sheriffs Sale ofthe mortgaged property could be held ould be approximately _eight months from the date of this Notice. A n tice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, th amount needed to cure the default will increase the longer you wait. You may find out at any tim exactly what the required payment or action will be by contacting the lender. 4 '~"',",,"> 1- "" ~, ~ HOW TO CONTACT THE LENDER: Name of Lender: Mercantile Mortgage Address: 221 West Cherry ~evada, MO 64772 1.800-446-4042 1.417-448.8281 Vonnie Foster Phone Number: Fax Number: Contact Person: EFFECT OF SHERIFF'S SALE-You should realize that as eriff's Sale will end your ownership ofthe mortgaged property and your right to occupy i If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and y r furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You_may or _X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the ortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs re paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RI . TO SELL THE PROPERTY TO OBTAIN MONEY TO P DEBT OR TO BORROW MONEY FROM ANOTHER LE OFF THIS DEBT. . TO HAVE THIS DEF AUL T CURED BY ANY THIRD P BEHALF OFF THE MORTGAGE DING INSTITUTION TO PAY TY ACTING ON YOUR . TO HAVE THE MORTGAGE RESTORED TO THE SAM POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEF UtT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT ORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN NY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTE UNDER THE MORTGAGE DOCUMENT, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YUMA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BAN UPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVIN YOUR COUNTY See APPENDIX C 5 "')!I'f.iUl, ~~ , ~.".. ^ 1 Z 506 528 862 ~ -!- <J <t US Postal SelVic. Receipt for Certified Mail No Insurance Coverage- Provided. Do not IJse for International Mail See reverse Sentla ("l I"" oJ '" rl " ;}:: :t2 Postage , ';". ::J Cel1ified Fee <>-. ""= Special Delivery Fee ' .8 Restricted Delivery Fee "v "' 0' m Return Receipt Showing to 0"- .... Whom &: Date DeUvered ::t "[ Retum ReceiPl ShowiIg 10 WhOm, N <( Dale. & Addressee's Address ~. Q~ ~ 0 TOTAL Postage & Fees CO (I') Postmark or Dale \'!IE Irlo 1iT"- A~ e"',<? $ -''l;U . '1' ~ -'::!. 'b Z 50 :2"'" us Postal SelVice r!: Receipt for No Insurance Cove 00 nol use for Inte ~ Sont to N l() '" S: ..... 528 861 ..... .vJ ~ .... - ..s:: ~ ,q Postage Certified Fee Special Delivery Fee Restricted Delivery F "' CJ"-. m Retum Receipl.Showin '3"- T"" Whom & Date DelWere :;;'"5,A_AeceipIShowingIo ~ ~ Dale,&Addressee'sAddr NO ....... 0 TOTAL Postage & Fee CO ~ ~ Postmark or Dale .JQo cx-~ AD. ml - V E R I F I CAT ION 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 MARK J. UDREN & ASSOCIATES -7J'j:j" ... ~...,.".,.,,,,..~,~ "",-'1_ J;:) i ~ -&g, (") (;) ~ ~ C 0 It- ~ h9 :s:: ::I: ::;:l 8 ~co ".. m ;;0- i'fj::O 0 ~.,~ " r- ~~ -oJT1 ~ ...... (fJ~ UI ~.~ ~ ..0 ::S ~. ~ ~CJ " 'J ~8 :x o:n ~I<) N z(') Lv Vl om ~ .. ~ V "'" ~~ <Xl --< ~ ~-lP ,,'Jllll!m' Ifn .~~'~~'IW~!"lMlII",i:U~,~n.,.,._~ ~.^~"""~ _~_~ SHERIFF'S RETURN - REGULAR C;\SE NO: 2000-01510 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MERCANTILE BANK ET AL VS D1\.HLQUIST JUDITH H RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DAHLQUIST JUDITH H the DEFENDANT , at 0019:08 HOURS, on the 17th day of March , 2000 at 820 LISBURN ROAD APT 402 CAMP HILL, PA 17011 by handing to J1IDITH DAHLQUIST a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.92 .00 10.00 .00 37.92 r~~~ R. Thomas Kline 03/21/2000 MARK J. UDREN Sworn and Subscribed to before By: me this 10 ~ day of _j)~ ~ A.D. '~ t2. ~,UP;;-' rothonotary -'liI'i,,- "~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire AT,]~Y LD. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 6051-482 -6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1:;72 Second Avenue Sam Diego, CA 92101 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) :NO. 00-1510 Civil Term 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 De:Eendant (s) for failure to file an Answer to Plaintiff I s Complaint wi1:hin 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 02/04/00 to 04/21/00 Late charges per Complaint From 02/15/00 to 04/21/00 Escrow payment per Complaint From 03/01/00 to 04/21/00 $45,189.34 724.62 49.02 150.26 TOTAL $46.113.24 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is ttached hereto. MARK Mark J Udren, ESQUIRE Attorn y for Plaintiff D~~GES ARE HEREBY ASSESSED AS DATE: IA,VI ( .J. /j. J (J-(HJ INDICATED PRO '\W-&"'~__ ~- , \ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N.KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) NO. 00-1510 Civil Term DATED: TO: April 10, 2000 Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APpEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED 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 PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: 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. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,'''''''''ll'''- ~~ . I' .""., , , I'?~"~- ~- \ \ MARK J. UDREN & ASSOCIATES BY: Hark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association ~572 Second Avenue San Diego, CA 92~0~ Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA ~70~~-742 Defendant(s) NO. 00-~5~0 civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF 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 Soldiers and Sailors civil Relief Act of ~940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Judith H. Dahlquist Over ~8 As captioned above Unknown f Nam: Ohn . ie.;,. Tit A5'&\-. Vi v... "'"?"'esl~t Company: MUc:..of\-\11c:.. ~I'\~ tJ. A. JAMES W. LITTELL Notar:r Public - Notary Seal STATE OF MISSOURI Vernon County My Commi8sion Expil"ea: June 12. 21000 -~ ~- - I' .1. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS H~GHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Mercantil~Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 civil Term Defendant(s) TO: JUDITH H. DAHLQUIST 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby not:ified that a Judgment has been entered against you in the above proceeding as indicated below. ~ Judgment by Default Prothonotary Money Judgment , Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark ,To Udren. Esquire At this telephone number: 609-482-6900 '-'l'W. _ _~_ - . .....,~.......,- I!!I! ~(~P~ FD "'-~) ^- ~~ ~ :& ~ ~ ~~ ,.,J ~ \) l.N --0 .,..,.. 21 ~ \ ~ ~ f~::> 10> ~ -~ iCC--~ I<-^ I ~. ~. 2=- ~ j-~ ~ <.JI t. ,~ . " - i. . C") CC> 0 r" U T1 ~ ~~- ::,~:7J1 ",--:-1 -r~1 [ ~ ~ -";.1 " '''' rn >OJ . , ~i >'" ;".'1 .~ l/~ eFi y 1. .-.f", U c::: ~TI "T, ',"\ " , ."~.-~ Ci ," ';0 C) , n S::~: ,. ;;;;; :..:~ =< ~ f ~. . Iv -...... (jo" U'I J r ~ ~ ~ """'___~'-"- ~-~lIIlI! _ . "'!!!~'" ",~~~~,._,_"J-"_ __~i!1Ii)~ffi'il'ilfl!'ijH"Il'1!l"tl1jl'l!\~l'I"f';~,'!~lIl~jiI!Il~" 1'Ir<<I~_ ~"~,,,^~"!Ii!I~~ , ( MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Ise:ue writ of Execution in the above matter: 115 Charlotte Way Enola, PA 17025 Amount due $~6.113.24 Interest From April 22. 2000 to Date of Sale September 6 7.000 Per diem @$9.29 1. 282 02 (Costs to be added) $ MARK J. UDREN & ASSOCIATES Mark ATTO . Udren, ESQUIRE EY FOR PLAINTIFF '~1!13 -~ -I"'" "~ ""~ ""''I!''P>ll'''''''''T ,"" A:l;L THAT CERTAIN UNIT IN THE PIlOPERTY KNOWN, _D AND IDENTIFIED IN ~KE D",c;t..ARl\.~ION PLAN, REIl'ElUIED TO BELOW' AS WESTI'IOOD qONDOM:INIUM LOC,'l.TED IN EAST PFNNSBORO TOWNSHIP, CUMBERLl\ND COUNTY, COMMONWEllLTH 011' PENNSYLV.lINIA, WIlICH HAS HERETOFORE BEEN SUBMITTED TO THE PROVISIONS OF THE UNIT PROPERTY ACT OF PENNSYLV.lINIA, ACT OF JULY 3, J.963 , Po L. J.96 BY THE RECOllDING IN THE OF THE Of'f'YCE OF THE 1ll!:COllDER OF DEEDS OJ!' ctJMBERLl\ND COuNTY, I!'ENNSYLVANIA OJ!' A DlECJ:J\RATION CREATING AND ESTABLISHING WESTI'IOOD VILLAGE CONDOMINIUM DATED JAW/AllY 29, J.975, AND RECOllDED JANUAllY 29, J.975 , IN MISC. BOOK 231, AT PAGE 28'3, AND AMENllEl:> BY A CER!I!lUN FIRST AMENIlMENT TO DECLlUlATION CREATING AND EPrABLISHING WESTWOOD VILLAGE CONDOMINIUM DA'rED MAY 28, J.976 AND HECOllDED ON J'M>; 22, J.976, IN MISC BOOK 222, PAGE 729 AND A CERTAIN SECOND .l\.MENDMl!:NT TO DJi'c:J:J\RA'rION CHEATING AND ES!l!ABLISHING WES!l!WOOD VILLAGE CONDUMINIUM DATED JULY 21., J.976, AND RECOllDED ON JULY 28, J.976, IN MISC. BOOK 223, A PAGE 343, AND A CtJl)J!: OF REGULA~XONS OF WESTI'IOOD VILLAGE CONDOMINIUM DA~ED oJ2\NUARY 29, J.975 , ANc HECOllDED ON J:ANUARY 29, J.975 , IN MISC. BOOK 2J.3 A~ PAGE 328, AND AWENDED BY )I. CER~AIN FI:as~ .l\MENDMEN'r ~O CODE OF HEGULA~IONS OF WESTI'IOOD VILLAGE CONDOMINIUM DA~l!:D MAY 28, J.976, AND HECOllDED ON JUNE 22, J.976, IN MISC. BOOK 22.2. AT PAGE 737, AND DECLlUlATION PLAN OF llESTI'IOOD VILLAGE CONPUMINIUM DATED JAfofI.JARY 29, J.975, AND HECOllDED ON oJ2\NUARY 29, J.975, IN PLAN BOOK 26 AT PAGE J.5, AND lIMENDED BY A CER~AIN FIRS~ AMENllWEN~ ~O DI!:CLlI1lA!l!ION PLAN Oli' llESTNOOD VILLAGE CONDOMINIUM DATED JULY 2J., J.976, AND RECOllDED ON JULY 26, J.976, IN l?'..l\t~ BOOK 28 AT PAGE 72, BEING DESIGNA~ED ON SAnl DECLlUlATION PLAN OF Wi'S'l:'i'IOOD VILLlIGl!: CONDOMINIUM AS UNIT NO. J.J.5, SUI'rB 304, mOWN AS J.15 ClIARLOT'rE ro\Y, SUI~E 304, ENOLA, PENNSYLVANIA, AS MOllI!l F!lLLY DBSCRIBED IN SUell DECLlI1\A'J!IOlil PLAN' AND DECLlI1\A'J!ION CREA'rING AND ES'rABLISHING WES=OOD Vn...LAGE CONDOMIlilIUM, AS ~HB SAWE Al'PWs Oli' RECORD AS SE~ 1i'0ll!l1H ABOVE, INC:WDING ANY Al<ll!lNDMENTS 'rIIEHE~O. To.r;i!:THER WITH A PIlOPOR~IONATE UNDIVIDED IN'rBRES~ IN 'rKE COMMON ELEMENTS (AS DU'J:NED IN SUCH DI!lCLlUlATION) OF NINE HUNDB.EIl 'rHIRfi 'rHOUSAND E'ER CEN'r (.930%) BEING KNOWN AS 115 CHARLOTTE WAY PROPERTY ID NO. 09-12-2992-011-A-12304 TITLE TO SAID PREMISES IS VESTED IN JUDITH H. DAHLQUIST, SINGLE PERSON BY DEED FROM LISA ANN FINK, NOW BY MARRIAGE, LISA ANN HACKENBERG, AND KURT A. HACKENBERG, HER HUSBAND, DATED 4/28/1989 AND RECORDED 5/3/1989 IN DEED BOOK 33 X PAGE 919 . I 11'0 ~- ',' '~l!\9I!!l'Il;mll-,_. Cf{ ,- -il\W!li.'_ F:J~ "" I ,,- --.. C> -0 ',f; FD 0J ~ ~ -{::---~, . :-->G~ I' - ~ ~ ~ ^ ~ ,~ ' ^" f~ s2l2~ ~~ ~~ ~-"," ~ _-;,_1- :;;~ ::::.1 ,"-", :0;-1 ~ r",) C!; , ---:]'1'1 ~] (-? ,.- t:~, ~i< - ----p ::0 _" c) ;,-_,.m ~~;~ 3~ );7" >~r"'lID1r ]":m:__~"~HII'l' . ,_" ,,"~""~>MfflUn-~1!? . """,'_''!!!'!I1Ii~~ ~~r:Jl\W, ".'. . ~b -i"~ J.... J i MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-48'2-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ATTORNEY FOR PLAINTIFF , . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) : NO. 00-1510 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Mercantile Bank s/b/m/t Farm and Home Savings Association, 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: 115 Charlotte Way Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s) : Name Address JUDITH H. DAHLQIST 820 LISBURG RD., APT 402, CAMP HILL, PA 17011-742 2. Name and addres&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 NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ""-ll-'~). ,.. . 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 DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Corrmonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 115 Charlotte Way, Enola, PA 17025 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. MARK J. UDREN & ASSOCIATES DATED: April 21, 2000 Mark . Udren, ESQ. Atto ney for Plaintiff -~"$;l~~ ~='.I-' - , I,. -~ "_=_~~i!l\j1t:ll~1 "~ ~,!!I!I;,-"" '-' o ~ ~l.=..' i':;~'- n'l':~', ?'--,;. .?'~ F'-- ~":'7:'- r.= fOO- ~~~~ '~ ::':i ", " " o (::J ,1.'":::1 .---.., -, " 'j :-n ,- ::-:;:; !'.) 0, ",'j;" ;-,;Cr} ~:::(::) .':-:-',:'1 (i:~ ::;~ i;! ~ ~':'~? ~:.) r:.- .r.:- ~,!Il'"W'~;f:oliI;1;~l'f11'iIll<III'J!I~~_~~, ,f1-~ "" ~ i MARX J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATT'Y I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHE'RRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 . ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE. FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JUDITH H. DAHLQUIST 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Your house (real estate) at 115 Charlotte Way, Enola, PA 17025 is scheduled to be sold at the Sheriff I s Sale on September 6, 2000, at 10: 00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $46,113.24, 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 RF: ART.F: '1'0 PREVENT THIS SHF:RTFF'S SALE To prevent this Sheriff's Baler you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and-reasonable attorney's fees. you may call: (609) 482-6900 mortgagee the back payment, late To find out how much you must pay, 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.) <mil_ < ~ < , I ,. " , y~r MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EYll:N IF THE SHERIFF I 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 609-482-6900. 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 609-482-6900. 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 mon~~y. 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 CANlqOT 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 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 -'''''''''''i!>~ , 1'1' _~!!l!lll'~. n_,.._ l'~._ """". ',- r " , C) (-, ("-I ..' C 0 ':"'7:1 ::::~ - ~ '0 f;, ,o' IT] " 'J , Z 'T " .'--;P' L.,,, f',.) ~-I (7~ crt ~=-) ~ C) s:: -;:.~ -~ .--- -,---. "7- C :l: C) Co .~ - . ;> f',) C_-) fIl C --, ?: ~[;>: ---J ,. '-,,-. --~ ~ :< .}HlI _ "..,", ~'_"";<,fflWffl'l~I~~,*fiI:J\m:m,". ~~~Jl!llIfIl~~m!~~Ji1!i1L~_~ .."" MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 Civil Term Defendant(s) C E R T I F I CAT 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. MARK J. UDREN & AS OCIATES Mark J. dren, ESQUIRE ATTORNEY FOR PLAINTIFF -"'''''lJl'~",r._ ~ - ~~~ f Ii1IlI\ll.-.- ~_ ~l9l!1lfiWIT'J1 " ~ ~. -~ ~-~ C) (~':) 0 C c.::o "1 ~;,;- :;:::~ '- r-,' '""':J ,,, IT: '''I: Z --V 2_: ?~- ,....,) 0:;; (J, -< roo C-~-' ~ u ,Po, Z ;-:._~ j;; (" j",,) ~<:::.. r:- ~--< , (Ii """'~~~",,,,"~~"II1\P1fWl'-~~M~~"r 'l-_~ >t '\ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Mercantile Bank s/b/m/t Farm and Home Savings Association Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Judith H. Dahlquist Defendant(s) . NO. 00-151.0 Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. MARK J. UDREN & ASSOCIATES DATED: April 21, 2000 BY: Ma' J. Udren, Esquire At orney for Plaintiff ,"'W'JI..~, ~.....,."'" "'1 - { ,~ . , .. V E R I F I CAT I 0 N The undersigned, an officer of the Corporation which is the plaintiff in the foregoing Complaint or an officer of the Corporation which is 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 foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain 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. Date: ~~/ /00 . - Ohh c.; \I ie.., . TOle: Acs'Sh Vi c.,e.. <1>(eB\ cluJ- Company: MefC-Ot",tk.- '&f'\t. I0.A. (fu..,._ 1-' . ~M__ "'he " ,~, ,,-,-,.,.-- --,,""---<>,,- '\I " ..,.. ~~~=,~o....41, ^III~,,,,,,,,",,,,~. ~ H~""",,, ~t;Il"'m~;i#W.!!iIl~~~____,~~~~~l!IlI_ .w, r- ...~ r-' -~ ,) ,-- ,,~1 c: C::J ">"1 '.0;' ~ "Cj 9~t:~; :;J 7' ;'0 CJ.;' , u -. t:~i ~ ," ., -' :::::~ c-.::': r;? :.-:) )> ( S;~ , .,~,- r:- --j :D -< r'" -< , MARK J. UDREN & ASSOCIATES BY, Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. . , Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) :NO. 00-1510 Civil Term 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 penalties of 18 Pa.C.S. Section 4904 relat,ing to unsworn falsification to authorities. Dated: August 3, 2000 MARK J. UDREN & ASSOCIATES BY: ~. Mark J. Udren, Esquire Attorney for Plaintiff -'"",J, "' ,- 1'- "",,"~ I MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) : NO. 00-1510 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Mercantile Bank s/b/m/t Farm and Home Savings Association, 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: 115 Charlotte Way Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s) : Name Address JUDITH H. DAHLQIST 820 LISBURG RD., APT 402, CAMP HILL, PA 17011-742 2. Name and address of Defendant(s) in the judgment: Name Address SAllIE 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 NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 1 "'WIJ'?II , <~ '- "<, ~ -I " , , " 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 REllL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address WESTWOOD VILLAGE CONDOMINIUM 650 WESTWOOD DR., ENOLA, PA 17025 Tenants/Occupants 115 Charlotte Way, Enola, PA 17025 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. MARK J. UDREN & ASSOCIATES DATED: AUGUST 3, 2000 l-fY\. Mark J. Udren, ESQ. Attorney for Plaintiff ''''''''''-'ru~_,"~~" , -,..... laRK J. UDREN & ASSoOCIATES BY: Mark J. Udren, Esquire ATTY LD. NoO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 1356-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 Plaintiff ATToORNEY FoOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 00-1510 civil Term v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, FA 17011-742 Defendant(s) DATE: April 28, 2000 'ToO: ALL PAR'l'IES IN INTEREST AND CLAIMANTS NoOTICE oOF SHERIFF'S SALE oOF-REAL_ERQEER~Y OWNER(S): JUDITH H DAHLQUIST PRoOPERTY: 11S Charlotte Way Eno1a, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~~e~and County Sheriff's Sale on ~ep_~e~e~6~QO~, at 10:00 AM, at the CUMBERLAND COUNTY COURTHOUSE,l COURTHOUSE SQUARE 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 ot 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. ~IBITA ,\'-''l!"'''_~ " -., --I "",. ...1 - r.... ~ ~ ~ ~ ~ ~ co ex> '" '" '" "" '" '" ~ r iii'~ '" "" '" '" ~ 0 5' .!!!. ro ;~ )> )>()O :>., r zc)> Z)> fi'[ () O;;::I: 3a ~ m ()lDr g-~ -<mO ",!2. 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"''''' ~tIl c.. z" ~~. 0'''- ~o DODOi'[ O()3"IlFr CD Ow CIlll:> a"o~~"(ii 15' ~m~ a. rom ~O' DO O~ -0 ~~Q'~= ![ -. ~~~ g m~R~ CD S:-~~CD It> "-:I ~ '~9:"5' o~- ~ " o o oar 00$19 5a~~~.~ ~.:I" 5' s: $- ~ IC 0 "'lJ -. "C So 0 CD"C ):> "'0 ~ c...... ~n. g e. s::.g JJ< OJ 5"~.::!. mill = ~ :-7' a ~. :J... ro J:.ffi ~ ~ 0- ~ l6 g- o '" o _ ~~ Q ffi~ 2~ -Ql 2t gg' ~ 015. ~ ~ " ~ "- ,,;D <:> m JJ tu iD ,,00 g, m ~ JJ ~ ,,(f)~" re~ -. 00 " ~a.sr B-d!e ""0 lDro3 00''' 0'-", ~.~; Ul= oS":=; ~~. iir.:.ffi O'O'~ =--'lll ID ;D " $I~ 3 " ~ ~ ~ ' ID " " o ~" , :::-, ~t~ili~R-~1t~!~,;iffii~;(f EXHIBl'T A ~~ . 1-\ Tt~~;~"f'f',:,i ""'. ~1~!!IIIII~_~""",,..4\l.~............IJ "<" ~'. .. () g 0 C "l1 ~ ~ .., ;:g~ c:: f':~~fJ Z::tJ G') ~~ I -_"':dT~ -~4t1 -.J -<',,,-- ,_.~, , ~l"") ~D -0 ,< "( ig :x i*: ::D ~C) r,,,? Om Z 'b! :< :!G -< _''',n~ " ~_=" 1~~Il\f<\'f'~W~!~~'jj)'.IW~~_lj!\Iil!ifffiJlilffi;;""K!ll~'" 'rRl;llQl~ \--.~. , STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, __h___n_nnh_n_nnhnn__________ n_____________ n________nn__h_____ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ____U_n_n____ Federal Natl Mtg Assoc . ___________________________.________________________________________________________ ~ the grantee 6th the same having been sold to said grantee on the ___________________________u__________n____n day of ___~~l'_t:.~lIll>_~~n__nnnn_________nn_ A. D.,~()9.9-n-' under and by virtue of a wriL___u________ Execution . d th 25th ___ _____ ________ ___ __ __ _ __ __ __ ___ ___ __ _____ _____ Issue OIl e ______ __ ___ __ ___ __ _ ___ __ ________ __ ___ Apnl 19 xx2000 C . dllY of u___________~hn_____n_ A. D., n____' /lut of the Court of omman Pleas of smd County as of Civil ~~2000 _..._ _______________ ---__ _____ __",______ - ______ __ _ _ __ ______________ __ ____ __ __ ______ _ Term, I ~_ ______ Number __~~.!-_C!.____n_' at the suit of ___l>!~!'~_~~!.!__J,,~_~~_~~_~!'!.~t:._!'_~~lIl_~__l!()!'!.~_~~.Y_~_~~_s_~~hn____ . Judith H Dahlquist :. _._________________________________agamst____________________________________________________ ~ dldy recorded in Sheriff's Deed Book No. n_:~_~___h' Page ____~~~_____. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _Cz_~~_n_ day of ___ - -:AW#;~ Iletorder oIlleeds, Cumberland Coo"" Carlisle PA Mw CammilsiGa (apires Ule fll$\ _ of an: 2Illl2 t, ,~""'"" ,", -' . "' "~ y ,,"' - ',' ,~ -',:c"f--- - " ,:;<;""l~. _ .' r Mercantile Bank slb/m/t Farm and Home Savings Association -vs- Judith H. Dahlquist In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-1510 Civil Richard E. smith Deputy Sheriff, who being duly sworn according to law says on May 1, 2000 at 12:45 o'clock P.M. EDST, he served a copy of Real Estate Writ Notice and Description in the above entitled action upon the within named defendant to wit: Judith Dahlquist by making known unto Judith Dahlquist at 820 Lisburn Road Apt 402, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on July 13,2000 at 3:50 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Judith Dahlquist located at 115 Charlotte Way, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly swom according to law, says 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 defendant Judith Dahlquist at 820 Lisburn Road Apt 402, Camp Hill, Pennsylvania. This letter was mailed under the date of July14, 2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on September 6, 2000 at 10:00 o'clock A.M, EDST and sold the same for the sum of$ 1.00 to Attorney James Flower Jr for Federal National Mortgage Association. It being the highest bed and best price quoted for the same Federal National Mortgage Association of 1900 Market Street, Suite 800, Philadelphia, being the buyer in this execution paid to SheriffR. Thomas Kline the sum of $ $ 1071.57 it being costs. Sheriff's Costs: Docketing PGundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills 30.00 21.01 15.00 15.00 30.00 10.00 .50 1.00 9.30 .74 15.00 20.00 442.10 386.89 23.53 '-'-' ",...." ~/ ",,;,~"=..~ ,. Distribution of Proceeds Sheriff's Deed 25.00 26.50 $1,071.57 Pd By Arty 10/3/00 Sworn and Subscribed To Before Me This ft.€:: Dayofa~ . - ~ . Soan~/ __.i ~.4 2000, A.D. 1_ (l ~~ r ~-r~- ro onotary R. Thomas Kline, Sheriff By_{J;t~.#.~ Real Estate Deputy -,< " I ~~~ ~' ~ 3D ,triJ l. t)O Ck J. qq9:L- ~ .IC.:6 'I'f&, --"""""", ,. . " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ATTORNEY FOR PLAINTIFF, . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Defendant(s) . : NO. 00-1510 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Mercantile Bank s/b/m/t Farm and Home Savings Association, 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: 115 Charlotte Way Enola, PA 17025 1. Name and address of Owner(s) or, reputed Owner(s) : Nam,e Address JUDITH H. DAHLQIST 820 LISBURG RD., APT 402, CAMP HILL, PA 17011-742 2. Name and addres&of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. I~ame and address of every judgment creditor whose judgment is a record lien On the real property to be sold: Name Address NONJ~ 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ~- I ,,~ "".. ~,." " '" 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 DEPT. 1 COURTHOUSE.SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Corrmonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 115 Charlotte Way, Enola, PA 17025 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 18Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: April 21, 2000 /hJ , Mark p. Udren, ESQ. Atto~ney for Plaintiff o;~, , -~ r- ," ~_lii""" ~ "~Jiiji~mM~..~IltiIl4",.,"-'~m!Wii,'_':>,fu!~,...,~, '" WiBMl_i'l"-';'" \):f~;'c. ' (',;:. . c " ',~.~,~:~'~.~~,: l\fR IE \,;:~ ,- 1, ... ",'_J ~ ~~ ;" , ' . ~I~.io:... 1i:1~ ~~, miI~P .'~~' ~"'.......~ "'J -ojl , , . ; MAF~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire AT'rY LD. NO. 04302 104,0 N. KINGS HIGHWAY, SUITE 500 CHE~RRY HILL, NJ 08034 6051-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ,ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JUDITH H. DAHLQUIST 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Your house (real estate) at 115 Charlotte Way, Enola, PA 17025 is scheduled to be sold at the Sheriff I s Sale on September 6, 2000, at 10: 00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $46,113.24, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be re1isted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS Yilll MAY BE ABT,E TO PREVENT THIS SHERIFF'S' SALE To prevent this Sheriffrs Sale, you must take immedia.te action: 1. The sale will be cancelled if you p'ay to the charges, costs and reasonable attorney's fees. you may call: (609) 482-6900 mortgagee the back payment, late To find out how much you must pay, 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.) ~~ '" I! ~ , """""" '"' ~ , YOll MAY STILL B1L.ABLE TO ,SAVE YOUR PRQ.P,ERTY AND_,yrm HAVE OTHER-RIGH'l'S EYE:N IF THE FlHERIl"F-'-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 609-482-6900. 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 609-482-6900. 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 mane=y. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrqng) are filed with the Sheriff within ten (10;0 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 CANlIIOT 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 17013-3387 717-2,49-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA CUmberland County Bar ASSbciation 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ',= - - <, I ~_...!-. ,,;.,.-~, L;g~I~~.iSlIllIi~Mlj~i!'iI!,I~~illiii!8"~l!l1~fj;~,,""A 1[- ".~'~......., '""'<-t.~~~'i~"~-~. -'~"""" ""''''IiiM~ r;'L!_ Co',' ; '\:<',}~(,:~~~ L;:~ "1 .:.....\ ." , --~ - ~ -It: ~. ~ , MARX J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire AT'!'Y LD. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHE:RRY HILL, NJ 08034 609-482-6900 Mercantile Bank s/b/m/t Farm and Home Savings Association 1572 Second Avenue San Diego, CA 92101 ,ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE. FORECLOSURE Plaintiff v. Judith H. Dahlquist 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 : NO. 00-1510 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JUDITH H. DAHLQUIST 820 Lisburn Road, Apt. 402 Camp Hill, PA 17011-742 Your house (real estate) at 115 Charlotte Way, Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on September 6, 2000, at 10: 00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $46,113.24, 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 YillL MAY BE ABLE TO PREVENT THIS SHERTFF' S' SAT,E To prevent this Sheriff's Sale, you must take immediate action: ],. The sale will be cancelled if you p'ay to the charges, costs and-reasonable attorney's fees. you may call: (60ql 482-6QOQ mortgagee the back payment, late To find out how much you must pay, 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.) ~_~IJl,.~ , . " " - I~ - .. /. , YOU MAY STILL BE ABLE T~AVE YOU~EROPERTY~AND YOU HAVE OTHER RI~TS EYE:NJF THE SHER,lFF' S-.-SAL.E DOES TAKE.I'.LAClL. 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 609-482-6900. 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 609-482-6900. 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 mone,y. The money will be paid out in accordance with this schedule unless exceptions (rea.sons why the proposed distribution is wrqng) are filed with the Sheriff within ten (10) d~ys after Schedule of Distribution is filed. 1. 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 CAm<IOT 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 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar ASSbciation 2 Liberty Avenue Carlisle, pA 17013-3387 717-249-3166 or 800-990-9108 - -F-' I' _iiillI.i*tifl~ii!~iWi!I!,,-,~'li~~.Ilij~j;lj3H!I"i<l!i...tM;Htilil6l:ll><i!ilIiwil->lli::~~i~~~' ~"'''''''''"4~ , ~)Fr:' :- I ~ , liP] p"... ;:, LJ -" \, , ::,HEHlfF 1i'fY ~ i ',' I,' \ I ,,: " ii" ~-"""'-~~ilMiIiIlIlJ::,Ljjdj ~ 0' "-Jiiil- ~H ji Ii ~ I I i A:l~L. THAT CERTAl:N UNIT IN !CHE PROPERfi KNOWN, NAMED AND IDENTIFIED IN THE DlCC:I:.ARATION PLlIN, REFERRED TO lIELOl'l AS WESTWOOD c;ONDOMJ:NXUM LOCATED Ilo! EAST PFNNSBORO TOWNSHIP, CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, V~AICH HAS HERETOFORE BEEN SUBMITTED TO THE PR011ISIONS OF THE UNIT, PROPERTY ACT OF PENNSYLVANIA, ACT OF JlJLY 3, 1963, P. L. 196 BY THE RECORDING IN THE OF THE Of'f":rCE OF THE RECORDER OF DEEDS OF CUMBERLAND COtl!llTY, PENNSYLVANIA OF A DECLARATION CREATING AND ESTABLISHING WESTWOOD VILLAGE CONDOMINIUM DATED JANIJARY 29, 1975, AND RECORDED .:JANUARY 29, 1975, IN MISC. BOOK 231, AT PAGE 283, AND AMENDED BYA CERTAl:N FIRST AliIEI:IDMEN'.r TO DECLA!lATION CREATING AND E1>'i'ABLISHING WESTWOOD VILLAGE CONDOMINIUM DATED MAY 28, 1976 AND RECORDED ON JuNE 22, 1976, IN MISC BOOK 222, PAGE 729 AND A CERTAIN SECOND AMENDMENT TO DJ<aAllATION CREATING AND ESTABLISHING WESTWOOD VILLAGE CONDOMINIUl-J DATED JlJLY 21., 1976, AND RECORDED ON JULY 28, 1976, IN MISC. BOOK 223, A,PAGE 343, AND A COl>l!l OF REGULATIONS OF WESTWOOD VILLAGE CONDOMINXUM DATED JlINUARY 29, 1975, AN'" RECOtlDED ON JlINUARY 29, 1915, :tN MISC. BOOK 213 AT PAGE 328, AND AMENDED BY A CERTAIN FIRST AMENDMENT TO CODE OF REGULl\!I!IONS OF WESTWOOD VJ:LLl\GE C~Nj)OMINIUM DATED MAY 28, 1916, AND RECORDED ON JUNE 22, 1916, IN MISC. BOOK 22.2. AT PAGE 131, AND DECLARATION PLAN OF WESTWOOD VILLAGE CONPOMINIUM DATED JAfl1.1ARY 29, 1975, AND RECORDED ON .DINUARY 29, 1915, IN PLlIN BOOK 26 AT PAGE 15, AND AMENDED BY A CERTAIN FIRST AMENDMENT TO DECLARATION PLllN OF WESTWOOD V1:~!:AGE CONDOM:INIUM DATED JULY 21, 1916, AND RECORDED ON JULY 26, 1916, IN P..i\L~ BOOK 28 AT PAGE 12, BEING DESIGNATED ON SAJD DECLARATION PLAN OF Wl<5'1'W00D VILLl\GE CONDOMINIUM AS UNIT NO. 115, SUITE 304, KNOWN AS 115 ClIi<;u.OTTE WAY, SUITE 304, ENOLA, PENNSYLVANIA, AS MORE li'llLLY DESCRIBED IN su<,f{ DECLAlIl\.TION PLAN AND DECLAlIl\.TIO~ CIlEAT:mG AND ESTABLISHING WESTWOOD V!:lA(JUOE COI:lDOM:INIUM, AS 'rIlE SAbIIE APPEARS OF RECORD AS SETH FORTH ABOVlil, INC.:LUDING ANY AMENDMENTS THERETO. To,G8THER WJ:TH A PROPORTIONATE UNDIVIDED IN'rERESTIN THE COMMON ELEMl!:NTS (AS DEf'tNED IN SUCH DECLARATION) OF NINE HUNDRED THIRfi THOUSAND PER CENT (. 930ls) BEING KNOWN AS 115 CHARLOTTE WAY PROPERTY ID NO. 09-12-2992-011-A-12304 TITLE TO SAID PREMISES IS VESTED IN JUDITH H. DAHLQUIST, SINGLE PElRSON BY DEED FROM LISA ANN FINK, NOW BY MARRIAGE, LISA ANN HACKENBERG, AND KURT A. HACKENBERG, HER HUSBAND, DATED 4/28/1989 AND RECORDED 5/3/1989 IN DEED BOOK 33 X PAGE 919 ~:I."W , r' -~ liilwliliJiiltitf I ,~'" ~ '~iiilJil'~'llo111~~~~~lf>'l~ili.~"'JlI'<I,~~iiIIi' ~'-~"""'"'-~'''.Iill C,FFi" (I ',if' i!,i'H LU :-i[_' b' L, " -"tlilil"'""" , i '~ "";"f('il1olf:' ':";::,;l-:!,t;'y{ l~ '] ; '[j , ~-! , " -\ ':1,1\ L_-'4ti." I I!ll~[~ , ,~ -"~-- "I 'I " i! . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNW OF CUMBERLAND) NO. 00-1510 CIVIL ~ Term CIVIL ACTION . LAW TO THE SHERIFF OF Cumberland COUNW: To satisfy the debt, interest and costs due Mercantile Bank s/b/m/t Farm and HOme Savinqs Association PLAINTIFF(S) from Judith H. Dahlq\list. 820 T.; ",hllrn Ror1iJ. Apt- 40~ (''''11'1[> Hill, PI\, 17011-747 DEFENDANT(S) (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 not~y the garnishee(s) that: (a) an attachment has belln issued: (b) the garnishee(s) is/are 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 tt\ereof; (3) If property 6ffhedefendant(s) not levied upon an subject to attachment is found in thepo!;session of anyone other than a named garnishee, you are directed to notify.himlhert/lat he/she has been added as agarnishee and is enjoined as above stated. Amount Due 4 '2~186113'~16 '()() trum / "LO / Interest per diem @ 9.29 - $1.282.02 Atty's Comm Atty Paid Plaintiff Paid % L.L. Due Prothy Other Costs $.50 $1. 00 $109.92 Date: April 25, 2000 Curtis R. Lonq Prothonotary, Civil Division ~y: .t/;O/Y1.P_ 2.7107//.&,...1'- Deputy REQUESTING PARTY: Name Mark J. Ddren, Esq. Address: 1040 N. Kings Hiqhway, Cherry Hill, NJ 08034 Attorne~f for: Plaintiff Telephone: 609-482-6900 Supreme Court 10 No. 04302 Suite 500 ~f,j1ii!l'i! I " i . REAL ESTATE SALE No. Iv vII ~(U, Hn the sheriff levied upon the defendam~ interest in the real property situated in /SA/ ~A L ~fA"'~ Cumberland County, Pa., known and numbered as: lIS 1)- A L ff'(/e<f ~.y___ and more flJi;i\ined on Exhibit "A" filed with this writ ancl by this reference incorporated herein. "t.~~J."., ~~ , -, j r-"; '.1 -i .J \' \ i: -l ':/ /\ \ -'~ -~:,:;, ;' -, :., ',,1 _, ' , ~ f't l<;; V' ell 1 ~\l gdU ,\11:1'. , ;}3it~:{-::, , , ",,-.; :-!L JO ::;;:;::!:W ">=,.~~ @) c:viJ a;;;J c:= (fi) INi1. -, _ ~[iI!!ltII1 " _ ~ _J. [!!!:11lr~il!II'N..""'I'Ji!>'li'~IW~,ij,~~mj~ftI'!~~\'I~!!!!~""" ,''''-"",,'1 .,.~ f~ "", ~~,.I ~~ ~""" " ~, ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587. Aooroned MaD 16. 1929 Commonwealth of Pennsylvania, County of Dauphin} ss .Tames L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager 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 mgular daily and/or Sunday and Metro editions/issues which appeared on the 1 st, 8th and 15th day(s) of August 2000. 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 adopte,d 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 Misceieous Book "M", vo;:': ~~'::~I:~ ------------------?2---~----------------------- COpy Sworn to and subscribed bef . 30th day of gus 00 A.D. S ALE #12 Notarial Seal Terry L. Russell, Notary PLlblic Harrisburg, Dauphin County My Commission Expires June 6. 2002 NOT Y PUBLIC Member, PennsylVania Associalion 01 N lIe~ommission expires June 6, 2002 4 .. CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertisin9 Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 385.39 1.50 386.89 Publisher's Receipt for Advertising Cost THE PATRIOT.NEWS CO., publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. THE PATRIOT.NEWS CO. By.................................................................... i , 'JJ"il ,~" ~ , . Rf.,AL ESTATE SAt.E N~. l2 Wri:l N.j.. :"fXilJ-HW Ci','HTerm ~{\'K.:1f1Hi'd' BilnN s,,1;.im,'t fetfm and >>~me-$.il\fl;\>;$, A:tr~r.:-. w. ~'J,* "1' H. Da:hl'{!ui,!)! Aii'ii: ;!aT~ J. UOfiof! l1F..$1;:;R!PTl(:lff -iLL fH,xr Cr:1UAj,;~ l,rI;[ j'1 [1-,: F.nO'w::!. "Hm."':~ .md K!:I.'!,lt!rH:d i,t~~~~::,;~;l ':'!I~{I~'J~ '!i"!~;~l~,';~,~ d' !n,;"~:, ,}'f i~;'\' r,l ',( l),.tlt\~t::;jW fiW,7\S!1Ip. C1Jil'tlt"li,]cd C(':;-'li'l: CNi1il1i:':l'1\','i";ihh ,Ji H,'n;l.:'\'\'.,J.r'~';J WI1::,:h h.l', tlf:ri-:.!-,)hl" t"l1' ',ul:,miU:6:r"t,} d,t:- pr,:,)';";':)'!" {'f th~. Lr,;!. P-wt'f:ri'\: A~t (;( Fii--l"Im',d...in"j, ,.\':( l:;f _bh 3, )'-16,\ 'n..' Yi6 h :h, r,.~.:ird!,jc; It! tl:'i',: Oi-rk'i' ",f Hr.';, f~,,~(t.~d;;r I,t !.'~'{'d:, ." ij~~;;'::~'i~~~1 E~:~~~;~ r:~(!~~t; !Z~~:~l;;~;~~;nl \~'~);:h;.'tKx!. 1,.:i.lltge t.,.:md.';I1-'llnitlID d...lf\;d bmllllv 19, 1975, ,lnd r~fnrUc,:::: 1,~J1(WV i,'f..', "1,'775; -1ft ~h-.,,;',_ lkl;lt, 2'.11, ;d r'~g~, :un,,' ..roll. aID.fl'8:k,d h~, a cl;"\"l':i-lln rh,J; A:n\'ndm\'l1~ t, l'i;..'(lar-,ttllJl~' ,(:'!~,1l111l~1 ,!I~,j \:Aabli::,hi!lA Vvbh",,,J.I)d 1"W..:~p C'-'r1d{~1.mhli!t d8t-ed' ,I\,[,.it'!' za,,!:lJ7~; Mid f('(nrdl!,j on jW1/:' 22, t.976, Iii lv!),:,,( fJ.r:l(lf.. - nz, H1f:_t,- ;'1::1 .1nd. ,,1. (Hta:itl &1-'1.'01'1.1 Ajf!i~l'ldlTIi:nf ie! fJNLn:liJt.1t', (r~atin)Z, Il,nd ~:,lj:ti!bli:,!'\i rl!.iY~:~,~".\ l'uli Y iGilf.;t:! "emit:!, 'ft1;l\;~i,~1 -~lttb:-,J 1.J~, ';,:, )'".-t:;, -,HJG_ [t:\(,;<w..\j un ill!:' ltr't ~;~:fl:,iit!~t;~;~;;;l,~~~,:~~~'~il:;~~~ ~;~~};~~~?~;titt;~:J::~l<~~;i ~J~;i~t~;t:;~:,/~t;~ X~~;_~1~.'~><,,:t \"i!i.1,:tl,~_ (l.lm:.1umi:r\lUm _ <!,lii'1:i' ~,{,l} 7.i},_ Hib, .;tni.1 "Vrrn-!ll.m1 Jl:!'1(\ 1l, t';"7i~, ill MlM;_,,,&~J~, _122_ at _ pagt:! T,'I,7,- ,.Hld (~f.i"wa.t-i.'}-a f.f:lu:t 01 ~'V~S~';ll:Id.Vm,a~? C:.~"\JS~){'l1initirn -d;!t"!:;l biiHJ':'!H' ,29, 191\ !In,:l !f:'-((lfUi'd UTI JelTm,,-rr ~\', W::':~fl~_J.'J:~l~-~-2a'-,;K"P~K~:_t.f:~,_,.~_l'j"~_#L"l1~:U~~~ :{~l:;t::'ij,~Jtn:::p{5t_,(\_m..~~j{lnJen:t t4_IJtditt:;f~fY_ 1~1~-i':if:i~~t\'i'~:iPd\,lir~e'_(~{il1iJ9.rn1:n,l\Jrrl_j~i!~j li.:lP..-:'~,j,,,,1..!f76, MJ 1'€((J1ii<1d_:(-}~: jufr:Ut'_ .fi~:'6, h1 j._~.J.a.:_,:,,,,., ..l'~,-',.'(',.~,. '.'.:':...."....f.,'.., '.'.'...~.'.'.~..,-:~....'i:.z ,.g.' i#~.i.~".t!l,.'"...;'1:.~_~....(,'n.. 5t7id- r~:':,d~r.llkm l"i<l:t'l u& _\\ef.hWfo.-j \-til;t,St t:,i~i_~~:iri~ii:h:1t1_-_~:_:t)lil,__, !\;-n~ \l~_ $\llbl" -<44, j;i~~:~~~.~~ 111\f:~oi_t~,_~Vij.; ~Ui~it:~f::~t+I.~~ '~\',~t~l~~:t~~,;qi,~..,:.a~}~,*M,tiJlh:'::i1/(1~ri~ iJ:1- ~~l;t:i;:l~ J~~(~i:~tiriri:,:_:rt~il__::,atl#:: :Dl'(t:'tr~tipn -_Crt:;'tt\~g .fn-iL :ti,:~h'!-t:m~~'~n:g: : _-l:Vlf:s~W~!t)J --_ _\;iJtag~ t.:.:r~:lmlli-"llllm. J,!;. fb!."_ _~:~,-)'f*'l1 :;(;1:p~',Jr~: Dt l~~(:~~~'f ;~::1;,t:h_ j!h}:~{,,::tn~i-~,~in~:~n::::~memrK"J;~;t_ :T{~"I(~~r wj~l ,!_ pl~j).{li1j~m~ltl:'- utlrlh"~ir,A 'ifrf'i~:ti~l;it 111 tl1t'.. ';:L'in'p..m:.~t \:h:'_~'U~_r:lf~ \~5_ \'kH{1~~~\ i-ry _::-otH:h_ d,-'(k~_r:lliiJr_l_"Jf :_niEi,," P-Q'rl;:ll'fll.! thnh -l:l'lYlJ:'~'J:;:tJ:pH (i'TIf.L_Y?:'-f!,,:',f: _ : _ " ' fj_EI~'f; K:'<<~'Vf',; A'7.!; i:-gi(h-id:.: ,::,::..::,;".f~~KiJ.1J{rY: -lD_- -~(l" it~-I:~ :&2lil<;: ,....' ,,' 11'~1!rf~:!:~~,~c:;: ti-i~h.~:~dlml~,t_ '~d~"i,.f-~~:'~t':J~~:d~'J;l_-':A~l:' lW!l',1 it~.n~,d -j:l',id: ,,:r,l\' rc(g'~i'9-.lr,.: - - - - - --" .. . """"'=-""""'='- . ' '. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, 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 Joumal on the following dates, V1Z: JULY 28, AUGUST 4, 11,2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Joumal, 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. I Roger M. Morgentha1, Editor SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 NOTARIAL At LOlli E. SNYDER. ,NOtoryPublic, COrlitl. Dora, evmb<itla,nilqiunty, PA My Commistion Expi~ ~"""5.2001 ;"q,~o," __"",4!>-_" .',1 - ^ . . ,- __ u" _""_"'~__'_ ~~ _ _,,__ ,t _,,,,, ,,~ -- -" < :';"1 ::-C:'; :!<; >:. (-,; 1.;0::, \.j "",',. REAL ESTATE SALE NO. 12 Wrtt No. 2000-1510 Civil Mercantile Bank. s/b/m/t Farm and Home Savings Association vs. Judith H. Dahlquist Atty.: Mark J. Udren ALL TIolAT CERTAIN unit 1I1 the property known. nariled and identi- fied in the Declaration Plan. referred to below as Westwood Condominium located 1I1 East Pennsboro TownsbJp. Cumberland County, Commonwealth of Pennsylvania, which has hereto- fore been submitted to the provtsions of the Unit Property Act of Pennsyl. vania, Act of July 3, 1963, P. L. 196 by the recording in the Office of the Recorder of Deeds of Cumberland I County. Pennsylvania of a Dec1ani- : lion creating and estiblishing West- wood Village Condqrniniumd..t.\l January 29, 1975, and recoF<led January 29, 1975.1I11\fisc.Book231, at Page 283. and amended by a cer. tain First Am~ndment to Declaration creating and establ1shlng Westwood Village CondOmlI1iuni dated May 28. 1976 and recorded on June 22. 1976. 1I1 MIsc. Book 222. Page 729 and a certain SecondAmencftrnent to Decla- ration creating and esfublishingWest- wood Village Condotninium dated July 21, 1976, and recorded on July 28. 1976. 1I1 MIsc. Book 223. at Page 343. and a Code of Regulations of Westwood Village ~ondominlum dated January 29. 1975. and record- edonJanuary29. 1975.1I1M1sc. Book 213 at Page 328. and amended by a certain First Amendnient to Code of Regulations ofWestwo6d Village Con- domlI1ium dated May2S. 1976. and recorded on June 22, 1976. in Misc. Book 222 at Page 737. and Declara- tion Plan of Westwood Village Condo- mlI1ium dated January 29. 1975, and recorded on January 29. 1975. in Plan Book 26 at Page 1,5. and amend- ed by a certain First Amendment to Declaration Plan of Westwood Village CondomlI1ium dated July 21. 1976. and recorded on July 26. 1976. in Plan Book 28 at Page 72. being des- Ignated on said Declaration Plan of Westwood Village Condominium as Unit No. 115, Suite 304. known as 115 Charlotte Way. Sulte 304. Enola. Pennsylvania. as more fully de- scribed in such Declaration Plan and Declaration creating and establish- ing Westwood Village Condominium, as the same appears of record as set forth above. including any amend- ments thereto. " . , TOGElHER with a proportionate undivided interest in the common elements (as defined in such Decla- ration) of nine hundred thirty thou- sand per cent (.930%). BEING KNOWN AS 115 Charlotte Way. PROPERlY 1D NO, 09-12.2992- 01l.A.12304. TITLE TO SAID PREMISES IS VESTED IN Judith H. Dahlquist. slI1- gIe person by deed ITomLlsaAnn Fink now by maniage, Lisa Ann Hacken~ berg, and Kurt A. Hackenberg her husband, dated 4/28/1989 and re- corded 5/3/1989 1I1 Deed Book 33X Page 919. w=~~~_< ~' _,,"~, \,_".-,_,Q""", 0,_', c", ,~"~ ~W~!I'\'l:!;';jF"JI'1'1"M'I/l"'~l!\'llll!lM'8;~ ~",...,.c .r"!l!IIIIl!I