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Home My WebLink About02-5388 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff . - COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) : NO. ~ - S JPp C!:O~l~~ 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 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. Race 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 previa 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 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 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, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt ofthis 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 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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 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: 5210 Royal Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 12/14/01 DATE RECORDED: 01/16/02 BOOK: 1746 PAGE: 1678 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 9/12/02: Principal of debt due and unpaid Interest at 9.7%* from 5/01/02 to 9/12/02 (the per diem interest accruing on this debt is $21.74 and that sum should be added each day after 9/12/02) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $41.58 should be added in accordance with the terms of the note each month after 9/12/02) Fees Billed Suspense Credit Attorneys Fees (anticipated to 5% of principal) $80,845.34 2,872.96 250.00 280.00 124.74 17.01 (135.00) and actual 4,042.27 TOTAL $88,297.32 * 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 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 nAn, 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 $88,297.32 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. M MarklJ. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 , ALL THAT CERTAIN lot In Plan No.3, Windsor p~, LoWer Allen Township, Cumberland County, Pennsylvania, said Plan being recorded In Cumberland County Plan Book 12, Page 23, as shown on the survey dated June 13. 1959, by D.P. ' Raffensperger RS, more fully described as follows: Lot No.6. Block "A". BEGINNING at a' point In the southem side of Royal DriVe, 'said point being 392.59 feet in a southwesterly direction along the southern side of Royal Drive, from the southwest comer of the intersectIon of Wesley Drive and Royal Drive, from the southwest comer of the rnte~ection of Wesley DriVe and Royal Drive; thence South 44 degrees 08 minutes East. a distance of 110 feet to a point: thence South 45 degrees 52 minutes West, a distance of 75 feet to a polntj thence North 44 degrees 08 minutes West, a distance of 110 feet to a point; thence North 45 degrees 52 minutes East, a dlsta!'lCe of 75 feet to a point; the place of BEC;;INNING. , HAVING thereon erected a brick dwelling house known as No. 5210 Royal Drive, . Mechanlcsburg, PeMsylvanla. .'..;:- ~ . , - . rOn.'....nn....'T' I ! : ; ~ : i I . :. , . . , l..........-r....,...l OOWEN July 31, 2002 "0001521601" Mary Lee Scott 5210 Royal Dr Mechanicsburg, P A 17055-3512 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR , --n:QME-FROMFORECLUSURE 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, IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (REMAP) may be able to help to save your home, This notice explains how the program works. To see ifHEMAP can helD vou. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY Wl11IlN 30 DAYS OF THE DATE OF TIllS NOTICE, Take this Notice with vou when vou meet with the connseling agencv. The name. address. and ohone number of Consumer Credit Counselin2: Allencies servinll Your county are listed at the end of this Notice. If you have anvauestions vou may call the Pennsylvania Housing Finance Allencv toll free at 1.800-342-2397 (oersons with imnaired hearin2 cancaIl717-780-1869l. 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 Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviend.o en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (pennsylvania Housing Finance Agency) sin cargos a1 nwnero mencionado arriba Puedes ser elegible para un prestamo por el programa Hamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): Mary Lee Scott PROPERTY ADDRESS: 5210 Royal Drive Mechanicsburg, P A 17055-0000 LOAN ACCOUNT 31126469 CURRENT SERVICER Ocwen Federal Bank FSB You mav be elhuble for financial assistance which can save vour home from foreclosure and helD vou make future mortgage oavrnents if you comply with the provision of the Homeowners' 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, 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 the foreclosure on your mortgage for thirty (30) days from the date oflhis Notice, During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end oflhis Notice, This meeting must occur within the next lhirtv (30) davs, IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TillS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Page two 31126469 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting, The names. addresses and teleohone numbers of desillIlllted consumer counseling agencies for the county in which vour properlY is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediatelv of your intentions, APPLICATION FOR MORTGAGE ASSIST ANCE- 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 Homeowners' Emergency Mortgage Assistance Fund, In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end ofthis,N.otic~,_OoI2' consumer , cfeilifCoUfisel1ng agencfesnaveappl1cilnonsTor'tlieprogrnm and they wIll assISt you -i1isubniltting a completed application to the Pennsylvania Housing Finance Agency, Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, AGENCY AcrION- 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 you application, During that additional 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 Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLYPROTECfED 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 yon can still apply Cor Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULTffiring it UP to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 5210 Royal Drive Mechanicsburg, P A 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 06/01/2002: (b) Late charge(s) : (c) Other charge(s): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 07/30/2002: $1,385.90 $83,16 $9,26 $135,00 $1,343,32 YOU HA VB FAILED TO TAKE THE FOLLOWING ACTION (if applicable) : HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WIllCH IS $1,343.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WIllCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577, Page tbree 31126469 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire 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 amount of default is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose uoon vour mortgaged orooertv, 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 they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50,00, However, iflegal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50,00, Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs, Ifvou cure the default within the THIRTY (30)DA Y oeriod, vou will not be reauired to oav attornevs' fees. OTlfr.R "LcNlJbK KbMblJiliS- Thelenaer may iTso sue you perSonallyror theunp.ud principal balance, and all other swns due under the Mortgage, RIGHT TO CURE THE DEF AUL T 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 charges, charges then due, reasonable attorneys' 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 POSSffiLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) 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 Ocwen Federal Bank FSB 12650 Ingenuity Drive, Orlando, FL 32826 (800) 746-2936 Name of Lender: Address: Telephone Number: 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' 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 borrower money from another lending institution to payoff 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 ifno default had occurred, (However, you are not entitled to this right more than tbree times in a 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, Page four 31126469 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writinl! at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, ifthe original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Ocwen Federal Bank FSB, P.O. Box 24737, West Palm Beach. FL 33416 Phone (800) 746-2936 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. ~~. /J \ Mark J. Udrerl, ESQUIRE MARK J. UDREN & ASSOCIATES (.:)""9- 1~~ - b::J ()- ~~-sJ ~rr .f-J2 ........7"-- [~ -t}L n'~ J ::> 1: , C-\ _..,J c' C..:: :1 ?~ '; ::;) -< (::; -~.... ""J -,j t) SHERIFF'S RETURN - REGULAR CASE NO: 2002-05388 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NA VS SCOTT MARY LEE CPL, TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCOTT MARY LEE the DEFENDANT , at 2056:00 HOURS, on the 7th day of November, 2002 at 5210 ROYAL DRIVE MECHANICSBURG, PA 17055 by handing to MARY L SCOTT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7,59 .00 10,00 .00 35.59 r-~~~~ R, Thomas Kline 11/08/2002 MARK UDREN me this 01;1.....4. day of Sworn and Subscribed to before By: ~ ~=2J A.D, C), 1,:-'-' (2 fJ" '" C L' , qJ> '1' rothonotary' 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 - . NO. 02-5388 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) for failure to file an Answer to Plaintiff I 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 9/13/02 to 12/13/02 Late charges per Complaint From 9/13/02 to 12/13/02 Escrow payment per Complaint From 9/13/02 to 12/13/02 $88,297.32 2,000.08 124.74 .o.......QO. TOTAL W.422 14 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 attached hereto. IPt dM do.. I , Ma: k J ~~ttorne AS I~CA TED, ~ ~ '1A~ ) . PRO PROTHY UDREN & ASSOCIATES DAMAGES ARE DATE: -.:Dcf: C HEREBY ASSESSED 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 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Mary Lee Scott Defendant(s) NO. 02-5388 DATED: TO: December 2, 2002 Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 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 717-249-3166 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 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 PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 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. NOV, 8.2002 4: 02PM Ma i 1 MARK J UDREN & ASSOC 856 4825384 NO.4153 P. 3/10 MARK J. ODREN &: ASSOCIATES BY: Mark J. tTcb:en, Esquire ATTY X.D. NO. 04302 1040 N. kXNGS HXGHWAY, SUXTE 500 CHERRY HXLL, NJ 08034 956-482-6900 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAXNTIPF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGB FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Meohanicsburg, PA 17055 Defendant(s) NO. 02-5388 Civil TERM STATE OF AFFIOAVIT OF NON-MILITARY SERVICE Florida COUNTY OF Orange THE UNDE:RSIGNED being duly BWorn, deposes and says that the averments herein are Dased upon invest1gations 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 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Mary Lee Scott Age: OVer 18 Residence: As captioned above Employment: Unknown SS ame. Title: Director of Loan Reso ution Company: Ocwen Federal Bank, FSB ~'(/llJ. t ."O~\ ekaira Butler '!t..: . Me. 9-} 0' .df~ Y _ ommlsS1on DO 14658 Ff\. E)(P1res S 0 emember 03. 2006 f1{)){Jn t=F- 3( I ~bCfbf C:\windows\TEMP\FAX.TIF F92 201 page 3 1 ~~ t ~ F'W ~ 0 j ~ ~ ~ k~ l -ft n ". ~-~.~ -' --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 856-482-6900 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 Plaintiff - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Mary Lee Scott - - NO. 02-5388 Defendant(s) 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. DATED: December 13, 2002 MARK J. UDREN & ASSOCIATES Mar J Udren, Esquire Attorney for Plaintiff NOV. 8,2002 4:02PM Mai I MARK J UDREN & ASSOC 856 4825384 NO.4153 P. 2/10 V E R I F I CAT I 0 ~ 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, heroby 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: IfliAJ{O!J- { N...,/4i#;.tdff Title: Director of Loan Resolution Company: Oewen Federal Bank, FSB Mary Lee Scott Loan #31126469 MJU #0235256 C:\windows\TEMP\FAX.TIF F92 201 page 2 1 C) ".- l ~ " :~ rj -'J .;;') :",) (=, -...... 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 - - NO. 02-5388 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $90.422.14 Interest From Dec~mber 14. 2002 to Date of Sale June 11. 2003 Per diem @$2l.74 3.913 20 (Costs to be added) $ MARK J. UDREN & ASSOCIATES ~\ a k J ren, ESQUIRE ATTORN~OR PLAINTIFF f + phJ - ~tv~ {Q.~ ......... ~ it'l -;..... ~ N :-0 C(i .~ ~ '0 () ~ CrtOV}~O - - C 0 -0 ()()().{)D' -~, w l) I I I , J , P llJ ....() 'f~ ~-U ~ "-C ~~~~F ~ t ... ~ l '~~~:e ~ ~ ~ ~ E' ~~ - .. t .. ~ ~ r-.... 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BCl 12650 Ingenuity Drive Orlando, FL 32826 - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 - - NO. 02-5388 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. ASSOCIATES l..~:. 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 856-482-6900 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 - - COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 - - NO. 02-5388 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1, 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: 5210 Royal Drive, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Mary Lee Scott 5210 Royal Drive, Mechanicsburg, PA 17055 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 None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. '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 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 Tenants/Occupants 5210 Royal Drive, Mechanicsburg, PA 17055 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: December 13, 2002 Udren, ESQ. for Plaintiff C" ,..........., 1 ) C"> ~ ..."' 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 - - NO. 02-5388 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Your house (real estate) at 5210 Royal Drive, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 11, 2003, at 10:00 a.m. in the commissisioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $90,422.14, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE o~E~5-RIGHTS Y.OILMA'L-BE-ABLE-TD PREVENT THIS SHERIFF 1 S~LE To prevent this Sheriff's Sale, you must take ~mme~te-act~Q~ 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: jB56) 482-69~ 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.) "t:O_~Y-S'llLL~BLE-.TCL~AYlLXillIlL.2RO.1'~TY AND'--yQILHA-'lE_O'l'HE.LlUGH'l'S ~EN IF THE SHERIFF'S SALE D~ES-TAKE PLAC~ 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 856-482-6900. 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 856-482-6900. 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 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 DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 717-249-3166 800-990-9108 .. h"') t:. WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5388 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK ONE, N.A. AS TRUSTEE OF THE AMORTIZING RESIDENTIAL COLLATERAL TRUST, Plaintiff (s) From MARY LEE SCOTT, 5210 ROYAL DRIVE, MECHANICSBURG, PA 17055 (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $90,422.14 L.L. $.50 Interest FROM 12/14/02 TO DATE OF SALE 6/11/03 - PER DIEM @ $21.74 - $3,913.20 Atty's Corom % Due Prothy $1.00 Atty Paid $117.59 Plaintiff Paid Date: DECEMBER 18, 2002 Other Costs CURTIS R. LONG (Seal) protho~ 21f ~ 1')....... -' ~ [} . 'CflA'" "l . r-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No, 04302 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 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) : NO. 02 - 53 8 8 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 roof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the t' ts set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the Pa.C.S. Section 4904 relating to unsworn falsification to a Dated: April 25, 2003 BY: Mark J. Udren, Esquire Attorney for Plaintiff 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 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-5388 v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) DATE: January 22, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): MARY LEE SCOTT PROPERTY: 5210 Royal Drive, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberl~d County Sheriff's Sale on ~,~~~, at 10:00 a.m., at the COMMISSIONERS HEARING ROOM, 2ND 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. exH'sr,. 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Ocl' _ c: .. __CD i Oen.. 011* oa... II :: ... Il. ~ 'T1::C ~ ~~~ ~ "Tl en 'is. IIC_ CD. II>n> ~~~ g:~!!. ::l III II> ~iD3 (')0'1:1 O....:r '2.3 CI> ~.~ Ci o 5. ::; _,------- -.cc if . ~ 2:Sll!! III "",II ~Sl~ , III "Tlen II' m;:t H ~ ~ IT A 1r;r II III- 11 Bank One, N.A., as Trustee of the Amortizing Residential Collateral Trust,2002-BCl VS " Mary Lee Scott In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5388 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on February 05,2003 at 4:06 o'clock PM, 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: Mary Lee Scott, by making known unto Mary L. Scott, personally, at 5210 Royal Drive, Mechanicsburg, Cmrtberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 08, 2003 at 2:54 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mary Lee Scott located at 5210 Royal Drive, Mechanicsburg, Pennsylvania, according to law. R. ThomaS Kline, Sheriff, who being duly sworn 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 one of the within named , defendants to wit: Mary Lee Scott, by regular plair to her last known address of 521 0 Royal Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of April 4,2003 and never returned to the Sheriffs Office. Sworn and~ubry~~,~cBe"6~ts~j;~f~~~t.;~/;!~.'.".,:S'/'i';; This' Day of . .-r....~...........?"~ .' R. Thomas'Kline, Sheriff . . - " -';j.c,;;': :j':;~;:"''';'f:::.:,,:,;-..i~~.,.'.]:.r::' \"ft't\;;';:;1i<.1f,~J~: .'"....,.... ',' . . 2003, A.D. . '. .,' l. _.. . ~ _ , ,~rothonotary . ~. '. S It . .'. B' MC~ :.. ~; .,""' _.....~,.." . '.v;.RealEst . Deputy . .~ .' .! ~ ; .,.. .._.... 4'':'" _....., .. .'._, :.J>..' e"u....," ...... '~Ioil~;;~j' /Q L!J Iii ., G, (") c s: -0 eo nlrr Z:I ZC ~;:;. ~c:; ~c 5>C c:: ~ o w :x :,;::110 --< N -.1 o -n .-4 :1: '~1 ;1} -r)tn -..;"'.9 ,..~ ("..:; .~~~ ~5 iSm =-t J:>:: ?2 ;po ~ 9 N r-..:> 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 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-5388 SUGGESTION OF BANKRUP!~ To the Prothonotary: Kindly note on the record that the above Defendant, Mary Lee Scott, has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on May 28, 2003, Bankru tcy Case No. 03-03184. A Mark J. dren, Esquire MARK J. UDREN & ASSOCIATES Atto ney for Plaintiff (") c:. ? rRl'C ~~. (II ~r,:: r:; . < :E:: ("~: ~(-; ;t>,.. S"~ "3 -, Cl W "" r"I'1 ." I OJ ",. 3: '2 ;:- Ul o -n ","; (~j -r, -Ii c':i ?)rfl :.~-1 -".. ~.o -< Bank One, N,A, as Trustee ofthe Amortizing Residential Collateral Trust 2002-BCl VS Mary Lee Scott In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5388 Civil Term c. R, Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J, Ddren, Sheriffs Costs: Docketing Poundage Posting Bills Advertising Mileage Levy Surcharge Postpone Sale Law Library Prothonotary Certified Mail Law Journal Patriot News Share of Bills 30.00 13,31 15,00 15.00 15,18 15,00 20,00 20,00 ,50 1.00 265.40 263,20 25,24 $ 698,83 paid by attorney 9/2/03 Sworn and subscribed to before me ThisLdayof ~ 2003,A.D, C}r....... 0 ~~ Prothonotary SOAnS~ r ~"".-~t:~-'. R. Thomas Kline, Sheriff BY,,-,' (V';' . 2~ Real i~~Deputy ,.so LIt. 'I' '\ $'1 6(u.. . 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 Ass!. 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 Sundav 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 22nd and 29th day(s) of April and the 6th day(s) of May 2003. 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 S ALE #13 ,../J..~......,........ Sworn to and s s ribed before ~.e this 14thzay ~May. 3 A,D. NOlana aI t ..., ~ Teny L. Russell, Notary Public /~l. (;(" Lk2/../ " City Of Hamsburg, Dauphin County . ~ MyCommissionExpiresJune6.2006 ~ARY PUBLIC Member. Pennsylvania Association Of Notanes My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 / Statement of Advertising 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 $ 261.45 1.75 263,20 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, By,..,..,.,....,.,....,.".,.,..,.,.,......,.....,.".....,...,.,.,.., ~ r 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 : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 25, MAY 2, 9, 2003 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, REAL ESTATE SALE NO, 13 ;;ha~, Writ No. 2002,5388 CIvil Bank One. N.A. as Trustee of The Amortizing Residential Collateral Trust. 2002-BC 1 vs. Mary Lee Scott Atty., Mark J. Udren ALL TIiAT CERTAIN lot In Plan No.3. Windsor Park. Lower Allen Township. Cumberland County. Pennsylvania. said Plan being re- corded in Cumberland County Plan Book 12. Page 23, as shown on the survey dated June 13. 1959. by D.P. Raffensperger RS. more fully described as follows: Lot No.6. Biock "A". BEGlNNING at a point in the southem side of Royal Drive. said point being 392.59 feet in a southwesterly direction along the southern side of Royal Drive. from the southwest corner of the intersection of Wesley Drive and Royal Drive. from the south- west corner of the intersection of Wesley Drive and Royal Drive; thence South 44 degrees 08 min- utes East. a distance of 110 feet to a point; thence South 45 degrees 52 minutes West, a distance of 75 feet to a point; thence North 44 de- grees 08 minutes West, a distance of 110 feet to a point; thence North 45 degrees 52 minutes East. a dis- tance of 75 feet to a point: the place of BEGlNNING. HAVING thereon erected a brick dwelling house known as No. 5210 Royal Drive. Mechanicsburg. Penn- sylvania. TITLE TO SAID PREMISES IS VESTED IN Mary Lee Scott. Indl- SWORN TO AND SUBSCRIBED before me this 9 day of MAY. 2003 F~A ~~'Hl4~~lr/P/J , H"", "'t_,,,- "\.0-", m.,,~IT>_~ r::",,-'/,!;.~::;'; ~"". ("'-,,~. L~.s E. \m;r,~j~.,,,.,>!., ,....~ ' "" ~ 11"0, (;;,rOOi>",:,.'<j C~SI LIy Ccx...lIlI:Ml !:lqllnii tJiiIit:h 5, 2005 r Lot No.6. Block "A". BEGINNING at a point in the southern side of Royal Drive. said point being 392.59 feet in a southwesterly direction along the southern side of Royal Drive. from the southwest corner of the intersection of Wesley Drive and Royal Drive, from the south- west corner of the intersection of Wesley Drive and Royal Drive; thence South 44 degrees 08 min- utes East. a distance of 110 feet to a poiIlt: thence South 45 degrees 52 minutes West, a distance of 75 feet to a point; thence North 44 de- grees 08 minutes West. a distance of 110 feet to a point: thence North 45 degrees 52 minutes East, a dis- tance of 75 feet to a point: the place of BEGINNING. HAVING thereon erected a brick dwelling house known as No. 5210 Royal Drive. Mechanicsburg. Penn- sylvania. TITLE TO SAID PREMISES IS VESTED IN Mary Lee Scott. indj, vidual. by Deed from Mary Lee Scott, ExecutriX of the Last Will and Testament of Fla1nder 1. Scott. dated 2/22/01. recorded 2/23/01. in Deed Book 239. Page 967. PROPER1Y lD NO.: 13-24,0793-r141. BEING KNOWN AS 5210 ROYAL DRIVE. MECHANICSBURG, PA 17055. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO. 02 - 5388 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $90,422.14 17,552.70 Interest From 12/14/02 to Date of Sale March 2, 2005 Per diem @$21,67 (Costs to be added) $ UTIREN ,LAW !CV Mark j~en. ESQU'" ATTORNEY FOR PLAINTIFF ?J P- ~ ~~ ~ '-::C C ~ ~ 'E' \:J + ~ ~ "69. -=- C> (). ~ ~0 J3... CIl ~ CJ.J ~ "I>"'~li'f"Q<1!~ :.0 D () ~ ~irtO 0 1JCDC ..0 " I I I I I (:::)~ ::::~:: ::l,# ..... ':. - ........) - ........~ ' -. LIV!-fF ~? II ?-6l/6 Y D23S256 +i'levV<: IN THE UNITED STATES BANKRUPTCY COURT FOR THE Middle DISTRICT OF PENNSYLVANIA IN RE: Mary L. Scott CHAPTER 13 CASE NO. 03-03184 MDP Bank One, N.A., as Trustee of the Amortizing 11 U ,S.e. SEe. 362 Residential Collateral Trust, 2002- BC 1 Movant vs, Mary L. Scott Debtor(s) and Charles J, DeHart, III, Esquire Trustee RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this., AND DECREED that: day of ,20.' , it is ORDERED The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.e. 362, is modified with respect to premises: 5210 Royal Drive Mechanicsburg, P A 17055 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises.. The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code, 1~~-. !'" ,- '-'i, :-'--'-'--"~'-~l E,\WPS2\BKY\04020S46cod,wpd r . Ii ! ! ," L ,',' ~ JUL - 1 ~"~n." -,... '-t ;/yrl/L- . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO. 02-5388 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. UD"'rv~~ MarklJ. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ~REN LAW OFFICES, P.C. ,BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust:, 2002 -BCl 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO. 02-5388 AFFIDAVIT PURSUANT TO RULE 3129.1 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1, 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: 5210 Royal Drive, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 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 None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ,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 Square 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 Tenants/Occupants 5210 Royal Drive Mechanicsburg, PA 17055 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 t~ authorities. UDREN LAW OFFICES, P.c.. (\ !\j~) Mark 1. ~ren, ESQ. Attorney for Plaintiff DATED: September 20, 2004 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 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO, 02-5388 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Your house (real estate) at 5210 Royal Drive, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2005, at 10:00 a.m, in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $90,422.14, 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 Sheriffls Sale, 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: (856) 669-5400, 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 2m attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the {See notice on page two on how 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 distributi.on 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 717-249-3l66 800-990-9108 ASSOCIATION DE LICENCIDADOS cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK ONE, N.A. AS TRUSTEE OF THE AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002-BCl, Plaintiff (s) From MARY LEE SCOTT NO 02-5388 Civil CrvIL ACTION - LAW (I ) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also diwcted to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe 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 $90,422.14 L.L. Interest FROM 12/14/02 TO DATE OF SALE 3/2/05 - PER DIEM @$21.67 - $17,552.70 Arty's Comm % Due Prothy $1.00 Arty Paid $828.92 Other Costs Plaintiff Paid Date: OCTOBER 13, 2004 (Seal) CURTIS R. LONG Prothono~ -By' ~O~,_ P. ~('fIh"~.r Deputy REQUESTING PARTY: Name MARK J. UDREN. ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST CORPORATE CENTER CHERRY illLL, NJ 08003.3620 Attorney for: PLAINTIFF' Telephone: 856.669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) . : NO. 02 -5388 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 Exhibi1: "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'l. 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. Mark . Udren, Esquire Attorney for Plaintiff This Affidavit is made subject t Section 4904 relating to unsworn Dated: February 7, 2005 P.C. BY: UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~~~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BCl 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-5388 v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) DATE: January 11, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Mary Lee Scott PROPERTY: 5210 Royal Drive, Mechanicsburg, PA ~7055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 2, 2005, at 10:00 a.m" at the Commissioners Hearing Room, 2nd 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. EXHIBIT A \I) _ d m ttl ...;:: .~ u:i l.L. 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Bank One, N,A, as Trustee of the Amortizing Residential Collateral Trust,2002-BCl VS Mary Lee Scott In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2002-5388 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 07, 2004 at 8:51 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Mary Lee Scott, by making known unto Ernest Scott, adult in charge for Mary Lee Scott, at 5210 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2005 at 10:14 o'clock A,M" she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mary Lee Scott located at 5210 Royal Drive, Mechanicsburg, 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: Mary Lee Scott, by regular mail to her last known address of 521 0 Royal Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of December 29, 2004 and never returned to the Sheriff's Offic<~, Sworn and subscribed to before me So Answers: This _ day of ~~;,( /~- , R. 'ft0"~Klme, :g{'~ ByJO~~ Real Estate eputy 2005, A.D, Prothonotary EDrH'SQT B' --- "~. , (' i: c,. r,) ,:> - Bank One, N.A, as Trustee of the Amortizing Residential Collateral Trust, 2002-BC I VS Mary Lee Scott In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2002-5388 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 07,2004 at 8:51 o'clock PM, he served a true copy ofthe with' Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Mary Lee Scott, by making known unto Erne t Scott, adult in charge for Mary Lee Scott, at 5210 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy ofthe same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2005 at 10:14 o'clock A.M., she posted a true copy of the within R al Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mary Lee Scott located at 5210 Royal Drive, Mechanicsburg, Pennsylvani , 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 name defendant, to wit: Mary Lee Scott, by regular mail to her last known address of 521 0 Royal Drive, Mechanicsburg, P A 17055. This letter was mailed under the date of December 29, 2004 and never returned to the Sheriffs Office, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this rit is returned STAYED per instructions from Attorney Mark Udren, Sheriffs Costs: Docketing 30.00 Poundage 15,07 Posting Bills 15,00 Advertising 15,00 Auctioneer 10,00 Prothonotary 1.00 Mileage 17,76 Certified Mail 6,63 Levy 15.00 Surcharge 20,00 , \' ~f13 ~ I \ P-, lli1~O Law Journal Patriot News Share of Bills 265.40 326,98 30,73 $768,57 Sworn and subscribed to before me This day of 2005, AD. Prothonotary S~~:~..t:p~ R. Thomas Kline, Sheriff ByJ~J~ Real Es Deputy ... .. " 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 PL INTIFF Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF.COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO, 02 -5388 AFFIDAVIT PURSUANT TO RULE 3129,1 Bank One, N.A. as Trustee of the Amortizing Residential Collater 2002-BC1, Plaintiff in the above action, by its attorney, Mark ESQ., sets forth as of the date the Praecipe for the Writ of was filed the following information concerning the real propert at: 5210 Royal Drive, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name lien on Name and address of every judgment creditor whose judgment i the real property to be sold: Address None 1 Trust, . Udren, ecution located a record 4. Name and address of the last recorded holder of every m rtgage of record: Name Address Plaintiff herein. See Caption above. ,4 5, Name and address of every other person who has any record lien n the property: Name Address None 6. Name and address of every other person who has any record inte est in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N, Hanover St, Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 28094 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 aff cted by Address TenantslOccupants 5210 Royal Drive Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true an to the best of my personal knowledge or information and be understand that false statements herein are made subject to the of 18 Pa.C.S, sec. 4904 relating to unsworn falsification t~ aut UDREN LAW OFFICES, P,C. DATED: September 20, 2004 Mark . U ren, ESQ, Attorney for Plaintiff correct ief. I enalties orities, . ATTORNEY FOR LAINTIFF ,UDREN LAW OFFICES, P.C. y/ 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 Bank One, N.A. as Trustee of the Amortizing Residential Collateral Trust, 2002-BC1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Defendant(s) NO, 02 -5388 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mary Lee Scott 5210 Royal Drive Mechanicsburg, PA 17055 Your house (real estate) at 5210 Royal Drive, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2005, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, arlisle, PA , to enforce the court judgment of $90,422.14, obtained by laintiff above (the mortgagee) against you. If the sale is postpo ed, 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 charges, costs and reasonable attorney's fees. you may call: (856) 669-5400, mortgagee the back pa To find out how much yo 2. You may be able to stop the sale by filing a petition asking the Cour or open the judgment, if the judgment was improperly entered. You m 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you conta (See notice on page ent, late must pay, to strike also ask one, the wo on how , , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTH R RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1, If the Sheriff's Sale is not stopped, your property will be s ld 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 th 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 f 11 amount due in the sale. To find out if this has happened, you may call 856-669-54 0, 4. If the amount due from the Buyer is not paid to the Sheriff, you w'll 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 aIDO nt 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 y ur house. A schedule of distribution of the money bid for your house will be filed by t e Sheriff within 30 days after the sale. This schedule will state who will be recei ing that money. The money will be paid out in accordance with this schedule unless e ceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff 'thin ten (10) days after Schedule of Distribution is filed, 7. You may also have other rights and defenses, or ways of getting our home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IP YOU DO NOT HAVE A AWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHER YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l7013 717-249-3166 800-990-9l08 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9l08 - ' ALL THAT CERTAIN lot In Plan No.3, Windsor Park, Lower Alle Township, Cumberland County, Pennsylvania, said Plan being recorded' in Cumbe County Plan Book 12, Page 23, as shown on the survey dated June 13. 19 9, by D.P, . Raffensperger RS, more fully described as follows: Lot No.6, Block "A", BEGINNING at a point in the southem side of yal DriVe, 'said point being 392.59 feet in a southwesterly direction along the south m side of Royal Drive, from the southwest comer of the intersectlonof Wesley Dtiv and Royal Drive, from the southwest comer of the intersection of Wesley Drive and al Drive; thence South 44 degrees 08 minutes East, a distance of 110 feet to a t: thence South 45 degrees 52 minutes West, a distance of 15 feet to a point; the North 44 degrees 08 minutes West, a distance of 110 feet to a point; thence North 45 egress 52 minutes East, a dlstaJ;lCe of 75 feet to a point; the place of BE~INNING, . HAVING thereon erected a bricl< dwelllng house known as No. 5210 Mechanicsburg, PeMsylvanla. , .:' ;" BEING KNOWN AS: PROPERTY ID NO, : 5210 ROYAL DRIVE, MECHANICSBURG, PA 17055 13-24-0793-141 TITLE TO SAID PREMISES IS VESTED IN MARY LEE SCOTT, INDIVIDUAL BY DEED FROM MARY LEE SCOTT, EXECUTRIX OF THE LAST WILL AND TESTAMENT OF FLA NDER L. SCOTT DATED 2/22/01 RECORDED 2/23/01 IN DEED BOOK 239 PAGE 967, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5388 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK ONE, N.A. AS TRUSTEE OF THE AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002-BC1, Plaintiff (s) From MARY LEE SCOTT (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNlSHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined om paying any debt to or for the account of the defendant (s) and from delivering any property of the defe ant (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 himlher that he/she has beeu added a garnishee and is enjoined as above stated. Amount Due $90,422.14 L.L. Interest FROM 12/14/02 TO DATE OF SALE 3/2/05 - PER DIEM @$21.67 - $17,552,70 Atty's Corum % Due Prothy $1.00 Atty Paid $828.92 Other Costs Plaintiff Paid Date: OCTOBER 13, 2004 CURTIS R. LONG (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST CORPORATE CENTER CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court lD No. 04302 Real Estate Sale #07 On November 19, 2004 the Sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 5210 Royal Drive, filed with this writ and by this reference incorporated herein. ~ ~ ~ ~.;1 Mechanicsburg, more fully described on Exhibit "A" Date: November 19,2004 ByJddcf Jmd:h Real Estate Deputy SO :f: d 111 130 ~OOl \td ')"HHIO::' Ulfiiid::i8t.-lfl:J .:l.:lllJ3HS 3Hl .:10 3:JI.:l.:lO . " .' REAL ESTATE SALE NO. 7 Writ No. 2002-5388 Civil Bank One, N.A as Trustee of the Amortt17ing Residential Collateral Trust. 2002-BC 1 VS. Mary Lee Scott Atty.: Mark Udren ALL THAT CERTAIN lot 1n Plan No.3, Windsor Park, Lower Allen Township, Cumberland County, Pennsylvania, said Plan being re- corded in Cumberland County, Plan Book 12, Page 23. as shown on the survey dated June 13, 1959, by D,P. Raffensperger RS, more fully described as follows: Lot No.6. Block ~A". BEGINNING at a point in the southern side of Royal Drive said pOint being 392.59 feet in a southwesterly direction along the southern Side afRayal Drive, from the southwest corner of the Intersection of Wesley Drive and Royal Drtve, from the southwest cor- ner of the intersection of Wesley Drive and Royal Drive; thence South 44 degrees OB minutes East, a dis- tance of 110 feet to a pOint thence South 45 degrees 52 minutes West, a distance of 75 feet to a point; thence North 44 degrees 08 min- utes West, a distance of 110 feet to a point: thence North 45 degrees 52 minutes East. a distance of 75 feet to a po1nt: the place of BEGIN- NING. HAVING thereon erected a brtck dwelling house known as No. 5210 Royal Drive. Mechan1csburg. Penn- sylvania. BEING KNOWN AS: 5210 Royal Drive, Mechanicsburg. PA 17055. PROPERTY to NO.: 13-24-0793- 141. TITLE TO SAID PREMISES IS VESTED IN Mary Lee Scott. Indi- vidual by Deed from Mary Lee Scott. Executrix of the Last Will and Tes- tament of Flainder L. Scott dated 2/22/01 recorded 2/23/01 in Deed Book 239 page 967. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), p, L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland aw Journal, a legal periodical published in the Borough of Carlisle in the County and State afo esaid, 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 reg arly issued weekly in the said County, and that the printed notice or publication attached heret 1S exactly the same as was printed in the regular editions and issues of the said Cumberland aw Journal on the following dates, V1Z: January 14, 21, 28, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumb rland Law Journal, a legal periodical of general circulation, and that he is not interested in the uhject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true, ( SWORN TO AND SUBSCRIBED before this 28 day of Januarv, 2005 r- ~u~~ I. ~1d(A./ Notary ~ REAL ESTATE SALE NO, 7 Writ No. 2002,5388 Civil Bank One, N.A as Trustee of the Amoritizing Residential Collateral Trust. 2002-BC I vs. Mary Lee Scott Atty.: Mark Udren ALL THAT CERTAlN lot in Plan No.3. Windsor Park. Lower Allen Township, Cumberland County, Pennsylvania, said Plan beIng re- corded in Cumberland County, Plan Book 12, Page 23, as shown on the survey dated June 13. 1959, by D.P. Raffensperger RS, more fully described as follows: Lot No.6. Block "fo.:'. BEGINNING at a point in the southern side of Royal Drive said point being 392.59 feet in a southwesterly direction along the southern side afRayal Drive, from the southwest corner of the intersection of Wesley Drive and Royal Drive, from the southwest cor~ ner of the intersection of Wesley Drive and Royal Drive; thence South 44 degrees 08 minutes East. a dis- tance of 110 feet to a point; thence South 45 degrees 52 minutes West, a distance of 75 feet to a pojnt: thence North 44 degrees 08 min~ utes West, a distance of 110 feet to a point; thence North 45 degrees 52 minutes East, a distance of 75 feet to a point: the place of BEGIN~ NING. HAVING thereon erected a brick dwelling house known as No. 5210 Royal DriVe, Mechanicsburg, Penn- sylvania. BEING KNOWN AS: 5210 Royal Drive. Mechanicsburg, PA 17055. PROPERTI ID NO.: 13,24,0793, 141. TITLE TO SAID PREMISES IS VESTED IN Mary Lee Scott. IndI- vidual by Deed from Mary Lee Scott, Executrix of the Last Will and Tes- tament of Flainder L. Scott dated 2/22/01 recorded 2/23/01 in Deed Book 239 page 967.