HomeMy WebLinkAbout02-5389
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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
: NO. O~- ..s'2Pj'
Q;,-,~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
AV1SO
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 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 importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO
o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE
ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R
AS1STENC1A LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity ofthe 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
caption on a preceding page. If Plaintiff is an assignee
is such by virtue of the following recorded assignments:
Assignor: The CIT Group/Consumer Finance, Inc.
Assignments of Record to: Bank One N.A., as Trustee
Amortizing Residential Collateral Trust, 2002-BCl
Recording Date: LODGED FOR RECORDING.
in the
then it
of the
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: 69 Cherry Grove Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township
COUNTY: Cumberland
DATE EXECUTED: 10/17/01
DATE RECORDED: 11/8/01 BOOK: 1738 PAGE: 2193
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
10/24/02:
Principal of debt due and unpaid
Interest at 9.75%
from 6/22/02
to 10/24/02
(the per diem interest accruing on
this debt is $36.38 and that sum
should be added each day after
10/24/02)
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
Late Charges
(monthly late charge of $50.00
should be added in accordance
with the terms of the note
each month after 10/24/02)
NSF Check Charges
Fees Billed
Pre-Payment Penalty
Attorneys Fees (anticipated
to 5% of principal)
$134,598.06
4,480.27
250.00
280.00
150.00
25.00
126.69
5,383.92
and actual
TOTAL
6.729.90
$152,023.84
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 "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $152,023.84 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreoloeure and eale of 'he Mor,gagjfl;f\miaee.
/ !
Mark J. Udren,'ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL the followl"9 described real estate lying and being situate in Southampton Township, Cumberland County,
Pennsylvania, bounded and described as follows:
,
BEGINNING al a railroad spike sel in the centerline of public road known and designated as Township Route
302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 26 degrees 37 minutes 45
seconds West 150.00 feetlo a railroad aplke set In the center line of Township Route 302 at common comer of
Lol3 and 2; thence along common boundary line ofLots 3 and 2, North 61 degrees 53 minutes 43 seconds
Eas1323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or
formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of
other lands now or formerly of John Thrush; thence along line of lands now or IoRnerly of John Trush. South 08
degrees 12 minutes 52 seconds East 92.95 feet lo an iron pin; thance through lands now or formeriy of John
Thrush, South 61 degrees 53 minutes 43 seconds West 325.63 feet to the point and place of b~innln9'
ContaIning 1.176 aor,es, more or Jess, and being Lot No.3 on a certain subdivision plan entlUed 'SubdIVision for
John Thrush" dated January 22. 1968, drawn by John R. Kissinger, Registered Surveyor. which plan Is
recorded In Cumberland County, PA Plan Book . Page .
Parcel #39-14-0171-164
.f
'OU:UU UUr
1.....................1
OOWEN
September 20, 2002
...
'0001661036'
Amos L. Keefer Jr
69 Cherty Gfove Road
Shippensburg, PA 17257-9459
This is an official notice that the mortgage 00 your home is in default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the allached pages.
ACT 91 NOTICE TAKE ACTION TO :SA VE YOUR
HOME FROM FORECLOSURE
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 '[REMAP can helD vou. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITIflN 30 DAYS OF THE
DATE OF TIllS NOTICE. Take this Notice with ou when ou m t with the unseliD a en .
The name address and hone number of Consumer Credit Counselin encies servin our coun are listed at the end of this Notice. If
ou have an uestions ou ma call the Penns Ivania HousiD Finance A enc loll free at 1-800-342-2397 ersons with 1m aired hearin
can call 717-780-18691.
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 viviendo en su casa. Si no comprende el contenido de
esta notificion obtenga una traduccion immediatamente llamando esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program"
al coal puede salvar su casa de la perdida del derecho a redimir su hipoteca.
HOMEOWNER'S NAME(S) : Amos L. Keefer Jr
PROPERTY ADDRESS: 69 Cherry Grove Road
Shippensburg, PA 17257-0000
LOAN ACCOUNT 30972491
CURRENT SERVICER Ocwen Federal Bank FSB
You ma be eli 'ble for fmancial assistance which can save our home from foreclosure and hel ou make future mort a e
paYments 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 circwnstances 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 of this Notice. During that time you must arrange and attend a "face-to-face" meeting with
one of the designated conswner counseling agencies listed at the end of this Notice. This meetin~ must occur within the next thirtv
30 da . IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. E~"H I BIT A
Page two
30972491
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 {\rrther action against you for thirty (30) days after
the date ofthis meeting. The names. addresses and teleDhone numbers of desi211llted consumer counselin\! a~encies for the
county in which vour DroDertv is located are set forth at the end of this Notice.. It is only necessary to schednIe one face-to-face
meeting. You shonId advise this lender immediatelv of your intentions. . .
APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in defanIt 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 imable to resolve this
problem with the lender, you have the right to apply for fmancial 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 of this Notice. Only consumer
credit counseling agencies have applications for the program and they will assist you in submitting 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 TillS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
' .
AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the
Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to
make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued agains'
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 CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS
NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If yon bave ffied bankruptcy you can still apply for Emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEFAULT(Brin~ it uo to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on yoUr property located at 69
Cherry Grove Road Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because:
YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounl
are now past due :
(a) Monthly payments from 07/22/2002:
(b) Late charge(s) :
(c) Other charge(s): NSF & Advances
(d) Less: Credit Balance
(e) Total amount required as of 09/19/2002:
$2,321.86
$100.00
$25.67
$.00
$2,447.53
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, WHICH IS $2,447.53, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other charges) WHICH 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
Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577.
Page three
30972491
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 ofthis debt will be considered due immediately, and you may lose the chance
to pay the mortgage in monthly installments. If full payment of the amount of default is not made within
THIRTY (30) days ofthe letter date, Ocwen Federal Bank FSB also intends to instruct their attomeys to start
a legal action to foreclose uoon vour mortgaged orooertv. ,
IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged propert)..wilLbe sold by the Sheriff to
pay off th~e mortgage debt. If the lender refers your case to its attorneys, but you cure tli.e 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 curethe
. default within the THIRTY nOmA Y oeriod. vou will not be recuired to oav'attornevs' fees.
OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance,
and all other sums due under the Mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30)
day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time
up to one hour before the Sheriff's Sale. You may do so by 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 perfonning any other requirements under the mortgage. Curing your
default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale 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 three 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
30972491
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: . . ., _
I) Provide to you, upon your .written request, verification-.of the debt or a cOJ>y of any
judgment entered against.you.
2) Provide to you,' upon your written request, the name and address of your original
creditor, if the original ereditor is different from the current creditor _'.
Unless you dispute the debt within that .30 day period, we will ,assume thatit i,s valid.
Sincerely,
Ocwen Federal Bank FSB
",t.
Ocwen Federal Bank FSB, P.O. Box 24737, West Palm Beach. FL 33416 Phone (800) 746-2936
10'UU..u.u.um.r"
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i.....................~
OCWEN
September 20, 2002
*0001661037*
Carol A. Keefer
69 Cherry Grove Rd
Shippensburg, PA 17257
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.
ACT 91 NOTICE TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
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 WITIIIN 30 DAYS OF THE
DATE OF THIS NOTICE. Take this Notice wiLl, vou when vou meet with the counselin. a.encv.
The name address and hone number of Consumer Credit Co selin A eocies servin our COUll . are listed at th . end of this Notice. If
ou have an uestions ou ma call the Penns lvania Housin Finance A ene toll free at 1-800~342-2397 ersons with im aired hearin
can call 717-780-18691.
This Notice contains important legal infonnation. If you have any questions, representatives at the Constuner 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 viviendo en su casa. Si no comprende el contenido de
esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionad.o arriba. Puedes ser elegible para un prestamo por el programa llamad.o "Homeowners' Emergency Mortgage Assistance Program"
al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
HOMEOWNER'S NAME(S): Carol A. Keefer
PROPERTY ADDRESS: 69 Cherry Grove Road
Shippensburg,PA 17257-0000
LOAN ACCOUNT 30972491
CURRENT SERVICER Ocwen Federal Bank FSB
You ma be eli ible for financial assistance which can save our home from foreclosure and hel ou make future mort a e
payments 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 ofthis 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 of this Notice. This meetin" mnst occur within the next thirty
30 da s. 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
30972491
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 yon for thirty (30) days after
the dale of this meetinE. The names. addresses and telenhone numbers of desil!llated consumer counselinl! al!encies for the
county in which vour nrooertv 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 infoimation 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 fmancial 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 !he end of this Notice. Only consumer
credit counseling agencies have applications for.the program and they will assist you in submitting 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 ACTlON- 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. DlLring 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 directIy by the Agency ofils decision on your
application.
~
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TffiS
NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have rued bankruptcy YOIl can sdll apply for Emergency Mortgage Assistance)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 69
Cherry Grove Road Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because:
HOW TO CURE YOUR MORTGAGE DEFAULTffirinl! it un to date).
YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts
are now past due :
(a) Monthly payments from 07/22/2002:
(b) Late charge(s):
(c) Other charge(s): NSF & Advances
(d) Less: Credit Balance
(e) Total amount required as of 09/19/2002:
$2,321.86
$100.00
$25.67
$.00
$2,447.53
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, WHICH IS $2,447.53, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURlNG THE THIRTY (30)
DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable t(
Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577.
Page three
30972491
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 ri2ht to accelerate the mort2a2e 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 unon vour rnort2a2ed nrooertv. .
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 c.ase 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, inegal 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 (30lDAY neriod. vou will not be reouired to nav attornevs' fees.
OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance,
and all other sums due under the Mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30)
day period and foreclosure proceedings have begun, you still have the right to cure the default 'and prevent the sale at any time
up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due phiS any late charges, charge,
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 POSSIBLE 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 BankFSB
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 pay off this debt.
To have this default cured by any third party acting on your behalf.
To have the mortgage restored to the same position as ifno default had occurred. (However, you are not entitled te
this right more than three 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
30972491
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 anyportio~ thereof, is disputed, We will: '. . .
. 1) Provide to you, upon,your written request, veriflcation 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, iftheoriginaI creditor is different from the current creditor
Unless you dispute the d,ebt wi,thiiI thatJO day period, we wUI assume that it is valid.
Sincerely, .
Ocwen F ederaI 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
he is authorized to take this Verification and does so because of
for the Plaintiff, a corporation unless designated otherwise; that
Mark J. Udren, Esquire, hereby states that he is the attorney
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
pleading; and that the statements made in the foregoing pleading
personal knowledge of some of the facts averred in the foregoing
belief and the source of his information is public records and
are true and correct to the best of his knowledge, information 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
MAR
Udren, ESQUIRE
UDREN ASSOCIATES
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-05389 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE NA
VS
KEEFER AMOS L JR ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KEEFER AMOS L JR
the
DEFENDANT
at 1129:00 HOURS, on the 8th day of November, 2002
at 69 CHERRY GROVE ROAD
SHIPPENSBURG, PA 17257
by handing to
AMOS L KEEFER JR
-
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
13 .11
.00
10.00
.00
41.11
r~/Y-,~~
R. Thomas Kline
11/12/2002
MARK UDREN
Sworn and Subscribed to before
By:
<;J~ i.
~
me this ,);) ~ day of
Deputy Sheriff
-n.,nuoUA/L-<-.J dOn.L, A.D.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-05389 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE NA
VS
KEEFER AMOS L JR ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
the
KEEFER CAROL A
DEFENDANT
, at 1129:00 HOURS, on the 8th day of November, 2002
at 69 CHERRY GROVE ROAD
SHIPPENSBURG, PA 17257
by handing to
AMOS L KEEFER JR
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
r~~J~~
R. Thomas Kline .
11/12/2002
MARK UDREN
Sworn and Subscribed to before
By:
\J~ ~. ~
Deputy Sheriff
me this ..2.) .~ day of
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~
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N;--iINGS 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
: MORTGAGE FORECLOSURE
~"......."'....
v.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
.
. NO. 02 - 5389
.........~~.'".'"
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 10/25/02 to 4/22/03
~Late charges per Complaint
From 10/25/02 to 4/22/03
_ _. Escrow payment per Complaint
From 10/25/02 to 4/22/03
$152,023.84
6,548.40
300.00
.D....JLCl
TOTAL
$158,872.24
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 attached hereto.
~..:?.J1REN & ASSOCIATES
~ar~ ~ ~ren, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS
DATE:JlpthL ~ :>003
I
I~CATED ~
4 -)f2_
PR ~Y
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.
Amos L. Keefer, Jr.
Carol A. Keefer
Defendant{s)
NO. 02-5389
April 10, 2003
Amos L. Keefer, Jr.
69 Cherry Grove Road
Shippensburg, PA 17257
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
DATED:
TO:
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED 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.
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.
Amos L. Keefer, Jr.
Carol A. Keefer
Defendant(s)
NO. 02-5389
DATED:
TO:
April 10, 2003
Carol A. Keefer
69 Cherry Grove Road
ShippensDurg, PA 17257
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
NOTIFlCACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR 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.
MARK J. ODREN & ASSOCIATES
BY: Mark J. Odren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SOITE 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
: MORTGAGE FORECLOSURE
v.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
: NO. 02-5389
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF
New Jersey
SS
COUNTY OF
Camden
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
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Carol A. Keefer
Over 18
As captioned above
Unknown
Defendant:
Age:
Residence:
Employment:
Amos L. Keefer, Jr.
Over 18
As captioned
Unknown
ab... ove YJ
/2?;l
\Na'me: Mar J. Udren, Esq.
Title: Attorney for Plaintiff
Company: Mark J. Udren & Assoc.
Sworn to and subscribed
before me this 22 day
o April '20~ck
KIeisTfN ANNer. ..._
NOTARY PUBuc OF . --.....
Commission 1:...._ ~ JEIIrV
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MARK Jo UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY IoDo 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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s}
-
- NO. 02 - 53 8 9
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$158,872.24
Interest From April 23. 2003
to Date of Sale September 3, 2003
Per diem @$36.38
4,874.92
(Costs to be added)
$
MARK J. UDREN & ASSOCIATES
L~
Mark J. dren, ESQUIRE
ATTORNEY FOR PLAINTIFF
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-5389 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, 2002-BCl Plaintiff (s)
From AMOS L. KEEFER, JR. AND CAROL A. KEEFER, 69 CHERRY GROVE ROAD,
SIDPPENSBURG, P A 17257
(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 $158,872.24
L.L. $.50
Interest FROM 4/23/03 TO DATE OF SALE 9/3/03 - PER DIEM @ $36.38 - $4,874.92
Arty's Comm % Due Prothy $1.00
Arty Paid $139.11 Other Costs
Plaintiff Paid
Date: APRIL 24, 2003
(Seal)
CURTIS R. LONG
pr~thono~ n
<-....fu'. ~II ~ ~
Deputy
7r(IUW-V
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: 1040 N. KINGS HIGHWAY, SUITE 500
CHERRY IDLL, NJ 08034
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ID No. 04302
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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
-
- NO. 02-5389
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.
REN & ASSOCIATES
Udren, ESQUIRE
FOR PLAINTIFF
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A'r'rOtueY FOR PLAINtIFF
~ J. UDREN & ASSOC"IA'tES
BY: Mark. J. udren, ESquire
A'tT'Y "I.D. NO. 04302
~040 N. K~NGS g~~Y. SU~TB 500
CHERRY H"ILL, NJ 08034
856_482-6900
Bank one N .A., as Trustee of
the Amortizing Residentia~
collateral Trust, 2002-BC~
~26S0 Ingenuity Drive
orlando, FL 32826
: COURT OF coMMON PLEAS
: CIVIL DIVISION
: cutnber~and County
-: MORTGAGE FORECLOSURE
Plaintiff
v.
.
. NO. 02- 53 89
AmOS L. Keefer, Jr.
Caro~ A. Keefer
69 Cherry Grove Road
Shippensbur9, PA ~72S7
Defendant(S)
Bank one N.A.. as TrUstee of the Amortizing Residential Collateral Trust.
2002-BC~. 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' 69 Cherry Grove Road. Shippensburg. PA ~7257
AFFIDAVIT PURSUANT TO RULE 3~29.~
~. Name and address of ownerls) or reputed ownerls),
Name AddresS
69 Cherry Grove Rd.. s;dPPensburg. PA ~7257
69 Cherry Grove Rd.. Shippensburg. PA ~725'
AmOS L. Keefer, Jr.
Caro~ A. Keefer
2. Name and addresS of Defendant l s) in the judgment'
Name AddresS
Same as # ~ above
3. Name and address of every judgment creditor whose judgment is a reco'
lien on the rea~ property to be sold:
Name AddresS
None
4. Name and address of the last recorded holder of every mortgage
record:
Name AddresS
See caption above.
Plaintiff herein.
-
~. 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
69 Cherry Grove Rd., Shippensburg, PA 17257
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 22, 2003
~Udren, ESQ.
Attorney for Plaintiff
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08934
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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
. NO. 02-5389
Defendant(s)
NOTICE OF SHERIFFISSALE OF REAL PROPERTY
TO: Amos L. Keefer, Jr.
69 Cherry Grove Road
Shippensburg,PA 17257
Your house (real estate) at 69 Cherry Grove Road, Shippensburg, PA 17257
is scheduled to be sold at the Sheriff's Sale on September 3, 2003, at
10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $158,872.24, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOT~CE OP OWNER'S R~GHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF' S S~T.F.
To prevent this Sheriff I s Sale, you must take ;..""ediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856) 482-6900.
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.)
~OU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S s>>.r.R DOES TAlC.E 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 856-482-6900.
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 TAKB THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT APPOIm ONE, GO TO OR TBLBPHONE TBB OFFICE LISTED BBLOW TO FIND OUT WBBR.B YOU CAN
GBT LBGAL HELP.
LAWYER RBFBlUiAL 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
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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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
. NO. 02 - 53 8 9
Defendant{s}
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Your house {real estate} at 69 Cherry Grove Road, Shippensburg, PA 17257
is scheduled to be sold at the Sheriff's Sale on September 3, 2003, at
10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $158,872.24, 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 BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856)-482-6900.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
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 TH:IS PAPER TO YOUR. LAWYER AT ONCE. :IP YOU DO NOT HAVE A LAWYER. OR
CANNOT AFPORD ONE, GO TO OR TELEPHONE THE OPP:ICE L:ISTED BELOW TO P:IND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER. REPERRAL SERV:ICE
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
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ALL the fonowing descnbed real estate lying and being situate in Southampton Township, Cumberland County,
Penl)syJvania, bounded and described as follows:
~
BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route
302 (Cherry Greve Road); thence along the centerline of Township Route 302. North 28 degrees 37 minutes 45
seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common comer of
Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds
East 323.47 feet to an iron pin set in line of land now or fonnerly of James Hil~ thence along line of land now or
formerly of James Hill, SOuth 57 degrees 33 minutes 28 seconds East 71.88 feet to an iren pin set in line of
other lands now or fonnerly of John Thrush; thence along line of lands now or formerly of John Trush. South 08
degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John
Thrush. South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and place of ~innlng. .
Containing 1.176 acrBs, more or less, and being Lot No.3 on a certain subdivision plan entitfed I Subdivision.for
John Thrush- dated January 22. 1988, drawn by John R. Kissinger. Registered Surveyor. which plan is
recorded in Cumberland County, PA Plan Book . Page .
Pa~I~14-0171-164
TITLE TO SAID PREMISES IS VESTED IN AMOSL.KEEFER, JR. AND CAROL
A. KEEFER, HUSBAND AND WIFE, BY DEED FROM AMOS L. KEEFER, JR. AND
CAROL A. LESHER NKA CAROL A. KEEFER, AS JOINT TENANTS WITH RIGHT OF
SURVIVORSHIP AND NOT AS TENANTS IN COMMON, DATED 10/17/01, RECORDED
11/8/01, IN DEED BOOK 249, PA~E 704.
PROPERTY ID NO.: 39-14-0171-164
BEING. KNOWN AS 69 CHERRY GROVE ROAD, SHIPPENSBURG, PA 17257
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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
: NO. 02-5389
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 "Bn.
4. If service was by Order of Court, then
Order is attached hereto as Exhibit "B".
This Affidavit is made subject to t
relating to unsworn falsification t
pe al ie of 18 Pa.C.S. Section 4904
ut~ r'ti s. ~
J. ~TES
Mark J. Udren, Esquire
Attorney for Plaintiff
with said
All Notices were
3129.
set forth by Pa Rule C.P.
Dated: July 23, 2003
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
NO. 02-5389
v.
Amos L. Keefer, Jr. I
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
DATE: June 23, 2003
TO: ALL PARTIES IN INTEREST AND CLAIMANTs
NOTICE OF SHERIFF'S SALE
OF RF.lI.t. PROPERTY
OWNER(S): Amos L. Keefer, Jr. and Carol A. Keefer
PROPERTY: 69 Cherry Grove Road
Shippensburg, PA 17257
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumher~ County Sheriff's Sale on September 3. 2003, at 10:00
a. m., in the Commisioners 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
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Bank One N.A., as Trustee of the
Amortizing Residential Collateral
Trust,2002-BCl
VS
Amos 1. Keefer, Jr. and Carol A. Keefer
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-5389 Civil Term
.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on May 15, 2003 at 7:23 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: Amos 1. Keefer, Jr., by making known unto Amos Keefer, personally,
at~69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania, its contents
and at the same tirne handing to him personally the said true and correct copy of the
same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on May 15, 2003 at 7:23 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: Carol A. Keefer, by making known unto Amos Keefer, husband of
defendant, at'69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania,
its contents and at the same time handing to him personally the said true and correct copy
ofthe same.
'- ~ Steve Whistler, Deputy Sheriff, who being duly sworn according to law, states
that on July 10,2003 at 5:56 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Amos 1. Keefer, Jr. and Carol A. Keefer located at 69 Cherry Grove Road,
Shippensburg, 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 one of the within
named defendants, to wit: Amos 1. Keefer, Jr., by regular mail to his last known address
of69 Cherry Grove Road, Shippensburg, PA 17257. This letter was mailed under the
date of July 3,2003 and never returned to the Sheriff's Office.
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 one of the within
named defendants, to wit: Carol A. Keefer, by regular mail to her last known address of
69 Cherry Grove Road, Shippensburg, P A 17257. This letter was mailed under the date
of July 3, 2003 and never returned to the Sheriff's Office.
Sworn and subscribed to before me
~~~
This _ day of
R. Thomas Kline, Sheriff
2003, A.D.
Prothonotary
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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
1 CIVIL DIVISION
; Cumberland County
NO. 02-5389
v.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
SUGGESTION OF BANKRUl"!CY
To the Prothonotary:
Kindly note on the record that the above Defendants, AmOS L Keefer,
Jr. a/k/a Lee Keefer & Carol A. Keefer, have filed Chapter 13
Bankruptcy in the Middle District of pennsylvania on September 2,
2003, Bankruptcy Case No. 03-05135.
k J.
K J. UDREN & ASSOCIATES
torney for plaintiff
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Bank One N.a., as Trustee of the
Amortizing Residential Collateral
Trust,2002-BCl
VS
Amos L. Keefer, Jr. and Carol A. Keefer
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-5389 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Mark J. Udren.
Sheriffs Costs:
Docketing
Poundage
Posting Handbills
Advertising
Mileage
Levy
Surcharge
Law Library
Prothonotary
Law Journal
Patriot News
Share of Bills
Postpone Sale
30.00
15.84
15.00
15.00
28.98
15.00
30.00
.50
1.00
344.45
263.20
28.90
20.00
$ 807.87 paid by attorney
12/02/03
Sworn and subscribed to before me
This at!::- day of J.Jeu~
2003, A.D. Ch4."-. a /hdJ/,-,: ~
Prothonotary
So~~~' /~
~~".'I!'.,,<:, ?~..---,-
R. Thomas Kline, Sheriff
BY JMiw~
Real Es~t~ Deputy
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,
Real Estate Sale # 02
On April 29, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
Southampton Township, Cumberland County, PA
known and numbered as 69 Cherry Grove Road,
Shippensburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: April 29, 2003
By: -Jolil{ ~h
Real Estate Deputy
~
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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~
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,
t 854, 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 July and the 5th
day(s) of August 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 pursua,nt 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
SALE #2
. ....~I.k.~-:t~ :::>..............
Sworn to ~:ribed befo~e 's t3th day ~~03 A.D.
TenyLRUOI8II,NotaIyPuDIiC f--:;a '/C!-t'~JJ/./
OlyOfHan1ObUIll, oaup-;nCounlYe """" N TARY PUBLI~ --<-c:f
My CommiS8I<>Il ElcpIreo JlIlll ,ovuu
""""""'. Penno-,1Vanla AlI(lCioIinr1 Of __ My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. t7013
!
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....................................................................
~
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor ofthe 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,
VlZ:
JULY 18, 25, 2003 AUGUST 1,2003
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. 2
2~/1
SWORN TO AND SUBSCRIBED before me this
1 day of AUGUST, 2003
Writ No. 2002-5389 Civil
Bank One. N.A.. as Trustee of the
Amortizing Residential Collateral
Trust. 2002-BC 1
vs.
Amos L. Keefer, Jr. and
Carol A. Keefer
Atty.: Mark J. Udren
ALL the following described real
estate lying and being situate in
Southampton Township, Cumberland
County. Pennsylvania, bounded and
described as follows:
BEGINNING at a railroad spike
set in the centerline of public road
known and designated as Township
Route 302 (Cherry Grove Road);
thence along the centerline of Town-
ship Route 302. North 28 degrees
37 minutes 45 seconds West 150.00
feet to a railroad spike set in the
center line of Township Route 302
at common corner of Lot 3 and 2:
thence along common boundary line
of Lots 3 and 2. North 61 degrees
53 minutes 43 seconds East 323.47
feet to an iron pin set in line of land
now or fonnerly of James Hill; thence
along line of land now or formerly
of James Hill, South 57 degrees 33
minutes 28 seconds East 71.88 feet
to an iron pin set in line of other
lands now or formerly of John
~~,L.xhUtfrftv
~SEAl. ;)
LOIS E. SNYDER, Notary NlIc
Carfitle Sool, ClllTiOOlIand County
My CorIll.li8lIMl ~ March 5, 2005
Thrush: thence along line of lands
now or formerly of John Trush.
South 08 degrees 12 minutes 52
seconds East 92.95 feet to an iron
pin: thence through lands now or
formerly of John Thrush. South 61
degrees 53 minutes 43 seconds
West 325.83 feet to the point and
place of beginning. Containing 1.176
acres. more or less. and being Lot
No.3 on a certHin ..l1hrlivicd....... ~1~_
,...
37 minutes 45 seconds West 150,00
feet to a railroad spike set in the
center hne of Township Route .'302
at common corner of Lot 3 and 2:
thence along common boundary line
of Lots 3 and 2. North 61 degrees
53 minutes 43 seconds East 323.47
feet to an iron pin set in line of land
now or fonnerly of James Hill: thence
along line of land now or formerly
of James Hill, South 57 degrees 33
minutes 28 seconds East 71.88 feet
to an iron pin set in line of other
lands now or formerly of John
Thrush; thence along line of lands
now or formerly of John Trush,
South 08 degrees 12 minutes 52
seconds East 92.95 feet to an iron
pin; thence through lands now or
formerly of John Thrush. South 61
degrees 53 minutes 43 seconds
West 325.83 feet to the point and
place of beginning. Containing 1.176
acres. more or less. and being Lot
No. 3 on a certain subdivision plan
entitled "Subdivision for John
Thrush" dated January 22. 1988.
drawn by John R. Kissinger. Regis-
tered Surveyor. which plan is re-
corded in Cumberland County. PA
Plan Book __ Page __'
Parcel #39-14-0171-164.
TITLE TO SAID PREMISES IS
VESTED IN AMOS L. KEEFER. JR.
AND CAROL A. KEEFER. HUSBAND
AND WIFE. BY DEED FROM AMOS
L. KEEFER. JR. AND CAROL A.
LESHER. NKA CAROL A. KEEFER.
AS JOINT TENANTS WITH RIGHT
OF SURVIVORSHlP AND NOT AS
TENANTS IN COMMON. DATED
10/17/01. RECORDED] 1/8/01.
IN DEED BOOK 249. PAGE 704.
PROPERTY lD NO.: 39-14-0171-
164.
BEING KNOWN AS 69 CHERRY
GROVE ROAD. SHIPPENSBURG.
PA 17257.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST 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
v.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 02-5389
TO THE SHERIFF:
PRAECIPE TO ISSUE WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Amount due
Interest From 04/23/03
to Date of Sale December 8. 2004
Per diem @$36.38
$158,872.24
21. 682.48
(Costs to be added)
$
UDREN LAW OFFICES, P.C.
COURT OF COMMON PLEAS
NO. 02-5389
-------------------------------------
-------------------------------------
Bank One N.A., as Trustee of the Amortizing
Residential Collateral Trust, 2002-BC1
vs.
Amos L. Keefer, Jr.
Carol A. Keefer
-------------------------------------
-------------------------------------
WRIT OF EXECUTION
-------------------------------------
-------------------------------------
REAL DEBT
$
158,872.24
INTEREST $ 21,682.48
from 04/23/03 to
Date of Sale December 8, 2004
Per diem @$36.38
COSTS PAID:
PROTHY $
SHERIFF $
STATUTORY $
COSTS DUE PROTHY. $
PREMISES TO BE SOLD:
69 Cherry Grove Road
Shippensburg, PA 17257
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Mark J. Udren, ESQUIRE
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 669-5400
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 02-5389 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, 2002-BC1, Plaintiff (s)
From AMOS L. KEEFER, JR AND CAROL A. KEEFER
(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
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 ofthe defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $158,872.24 L.L.
Interest FROM 4/23/03 TO DATE OF SALE 12/8/04 - PER DIEM @$36.38 - $21,682.48
Atty's Comm % Due Prothy $1.00
Ally Paid $959.48 Other Costs
Plaintiff Paid
Date: JULY 20, 2004
CURTIS R. LONG
(Seal)
ProthonotarY n
'- By: ~n-,.,..1 r' ~ou, ~
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATION CENTER
111 WOODCREST ROAD, SillTE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 04302
IN THE UNTIED STATES BANKRUPTCY
COURT FOR THE Middle DISTRICT OF PENNSYLVANIA
IN RE: Amos L. Keefer, Jr. alkJa Lee Keefer CHAPTER 13
Carol A. Keefer
CASE NO. 03-05135 MDF
Bank One, N.A., as Trustee of the Amortizing 11 D.S.C. SEC. 362
Residential Collateral Trust, 2002-BCl
Movant
RESPONDENTS
FILED HARRISBURG
PA
~UL - 7 2004
Clerk U S B
' . . ankruPtcy Court
vs.
Amos L. Keefer, Jr. alkJa Lee Keefer
Carol A. Keefer
Debtor(s)
and
CharlesJ.DeHart,llI,EsquUe
Trustee
ORDER MODIFYING SECTION 362 AUTOMATIC STAY
ANDNOW,this~dayof CLl ,20~,itisORDERED
AND DECREED that: \J - - ~
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.C. 362. is modified with respect to premises:
69 Cherry Grove Road
Shippensburg. PA 17257
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~=<
E,\WPS1\BKY\2003\03090128cod.wpd
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST 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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
NO. 02-5389
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.
UDREN LAW OFFICES, P.C.
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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
Bank One N.A., as Trustee of
the Amortizing Residential
Collateral Trust, 2002-BC1
12650 Ingenuity Drive
Orlando, FL 32826
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
i COURT OF COMMON PLEAS
i CIVIL DIVISION
! Cumberland County
I MORTGAGE FORECLOSURE
:
I NO. 02-""
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
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: 69 Cherry Grove Road, Shippensburg,
PA 17257
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
69 Cherry Grove Road
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and
record lien
Name
address of every judgment creditor
on the real property to be sold:
Address
whose judgment is a
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
interest
sale:
Name
and address of every other person who has any record
in the property and whose interest may be affected by the
Address
Real Estate Tax Department
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 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
69 Cherry Grove Road
Shippensburg, PA 17257
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn
falsification to authorities.
UDREN LAW OFFICES, P.C.
DATED: July 14, 2004
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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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
NO. 02-5389
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Amos L. Keefer, Jr.
69 Cherry Grove Road
Shippensburg, PA 17257
Your house (real estate) at 69 Cherry Grove Road, Shippensburg, PA
17257 is scheduled to be sold at the Sheriff's Sale on December 8,
2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor,
Courthouse, Carlisle, PA, to enforce the court judgment of
$158,872.24, 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 BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how much
you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You
may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to
the highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3.
amount due
5400.
The sale will go through only if the buyer pays the Sheriff the full
in the sale. To find out if this has happened, you may call 856-669-
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 OOT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
NO. 02-5389
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Your house (real estate) at 69 Cherry Grove Road, Shippensburg, PA
17257 is scheduled to be sold at the Sheriff's Sale on December 8,
2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor,
Courthouse, Carlisle, PA, to enforce the court judgment of
$158,872.24, 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 BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffls Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how much
you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You
may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to
the highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3.
amount due
5400.
The sale will go through only if the buyer pays the Sheriff the full
in the sale. To find out if this has happened, you may call 856-669-
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your
house. A schedule of distribution of the money bid for your house will be filed
by the Sheriff within 30 days after the sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this
schedule unless exceptions (reasons why the proposed distribution is wrong) are
filed with the Sheriff within ten (10) days after Schedule of Distribution is
filed.
7. You may also have other rights and defenses, or ways of getting your
home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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
NO. 02-5389
v.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Amos L. Keefer
Jr. & Carol A. Keefer has filed Chapter 13 Bankruptcy in the Middle
District of Pennsylvania on October 8, 2004, Bankruptcy Case No.
\
04-bk-06096.
Mark J. Udr n, E quire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
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In The Court of Common Pleas of
Cwnberland County, Pennsylvania
Writ No. 2002-5389 Civil Term
Bank One, N.A., as Trustee of the
Amortizing Residential Collateral
Trust,2002-BCI
VS
Amos L. Keefer, Jr. and Carol A Keefer
David McKinney, Deputy Sheriff, who being duly sworn according to law, s tes
that on September 01,2004 at 8:29 o'clock PM, he served a true copy of the within eal
Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, up n
the within named defendants, to wit: Amos L. Keefer, Jr. and Carol A Keefer, by ma ing
known unto Amos Keefer, Jr., personally and adult in charge for Carol A. Keefer, at 9
Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania, its contents d
at the same time handing to him personally the said true and correct copy of the same
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this it
is returned STAYED per instructions from Attorney Mark Udren.
Sheriff s Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Levy
Mileage
Surcharge
Law Journal
Patriot News
Share of Bills
30.00
7.23
15.00
1.00
15.00
14.80
30.00
225.10
30.42
$368.55
Sworn and subscribed to before me
?~.f'~
This' t::: day of ~~
i~ ,.... _ R. Tho mas Kline, Sheriff
2004, AD.l.4- Lt., ))U~ ry yrJ~r/~
r honotary B .
Real Esta eputy
ily-'D "11 QOc(
j~' I :;'fb23
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire'
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLA NTIFF
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.
Amos L. Keefer, Jr. NO. 02-5389
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Bank One N.A., as Trustee of the Amortizing Residential Coll teral
Trust, 2002-BC1, Plaintiff in the above action, by its att rney,
Mark J. Udren, ESQ., sets forth as of the date the Praecipe f r the
Writ of Execution was filed the following information conc rning
the real property located at: 69 Cherry Grove Road, Shippen burg,
PA 17257
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Amos L. Keefer, Jr.
69 Cherry Grove Road
Shippensburg, PA 17257
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
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 judgmen 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 mo tgage
of record:
Name Address
Plaintiff herein.
See Caption above.
5. Name and address of every other person who has any recor lien
on the property:
Name Address
None
6. Name
interest
sale:
Name
and address of every other person who has any
in the property and whose interest may be affected
ecord
y the
Address
Real Estate Tax Department
1 Courthouse Sq.
Carlisle, FA 17013
Domestic Relations Section
13 N. Hanover St.
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 2 0946
Harrisburg, PA 17128-0946
7. Name and address of every other person of whom the plainti f has
knowledge who has any interest in the property which m y be
affected by the sale:
Name Address
Tenants/Occupants
69 Cherry Grove Road
Shippensburg, PA 17257
I verify that the statements made in this affidavit are tr
correct to the best of my personal knowledge or informati
belief. I understand that false statements herein are made s
to the penalties of 18 Pa.C.S. sec. 4904 relating to u
falsification to authorities.
e and
and
ject
sworn
UDREN LAW OFFICES, P.C.
DATED: July 14, 2004
.
ATTORNEY FOR P INTIFF
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire'
ATTY I.D. NO. 04302
WOOD CREST 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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
NO. 02-5389
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Your house (real estate) at 69 Cherry Grove Road, Shippensb
17257 is scheduled to be sold at the Sheriff's Sale on Dece
2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd
Courthouse, Carlisle, PA, to enforce the court judgm
$158,872.24, obtained by Plaintiff above (the mortgagee)
you. If the sale is postponed, the property will be relis
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff1s Sale, you must take immediate action:
rg, PA
er 8,
Floor,
nt of
gainst
ed for
l. The sale will be canceled if you pay to the mortgagee the back ayment,
late charges, costs and reasonable attorneyls fees. To find out ow much
you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the curt to
strike or open the judgment, if the judgment was improperly enter d. 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 procee ings.
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 n tice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be old to
the highest bidder. You may find out the price bid by calling 856-669- 400.
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.
amount due
5400.
The sale will go through only if the buyer pays the Sheriff t e full
in the sale. To find out if this has happened, you may call 8 6-669-
4. If the amount due from the Buyer is not paid to the Sheriff, y u will
remain the owner of the property as if the sale never happened.
S. 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. t 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 f
house. A schedule of distribution of the money bid for your house will b
by the Sheriff within 30 days after the sale. This schedule will state w
be receiving that money. The money will be paid out in accordance wi
schedule unless exceptions (reasons why the proposed distribution is wro
filed with the Sheriff within ten (10) days after Schedule of Distribu
filed.
7. You may also have other rights and defenses, or ways of getti
home back, if you act immediately after the sale.
r your
filed
o will
this
g) are
ion is
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
4
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR P 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.
Amos L. Keefer, Jr.
Carol A. Keefer
69 Cherry Grove Road
Shippensburg, PA 17257
Defendant(s)
NO. 02-5389
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Amos L. Keefer, Jr.
69 Cherry Grove Road
Shippensburg, PA 17257
Your house (real estate) at 69 Cherry Grove Road, Shippensb
17257 is scheduled to be sold at the Sheriff's Sale on Dece
2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd
Courthouse, Carlisle, PA, to enforce the court judgm
$158,872.24, obtained by Plaintiff above (the mortgagee)
you. If the sale is postponed, the property will be relis
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO prevent this Sheriff1s Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back ayment,
late charges, costs and reasonable attorneyls fees. To find out ow much
you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the ourt to
strike or open the judgment, if the judgment was improperly enter d. 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 procee ings.
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 n tice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be old to
the highest bidder. You may find out the price bid by calling 856-669- 400.
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.
amount due
5400.
The sale will go through only if the buyer pays the Sheriff t e full
in the sale. To find out if this has happened, you may call 8 6-669-
4. If the amount due from the Buyer is not paid to the Sheriff, y u 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. t 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
house. A schedule of distribution of the money bid for your house will
by the Sheriff within 30 days after the sale. This schedule will state wh
be receiving that money. The money will be paid out in accordance wit
schedule unless exceptions (reasons why the proposed distribution is wren
filed with the Sheriff within ten (10) days after Schedule of Distribut
filed.
7. You may also have other rights and defenses, or ways of gettin
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
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FI
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
your
filed
will
this
) are
on is
your
WYER
OUT
--Al.k-tlle--foIIGWlng--descr:ibed-~.eal-astat&JyJng..andbeing..siw~tej[l.s9uthamRtcm TO\Nllshi Cumb
Pennsylv~nia, bounded ~nd described as follows:
,
BEGINNING at a railroad spike set in the centerline of public road known and designated as To hip Route
302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 7 minutes 45
seconds West 150.00 feet to a raflroad spike set in the cehter line ofTownship Route 302 at com on comer of
Lot 3 and 2; thence along common boundary .Iine of Lots 3 and 2. North 61 degrees 53 minutes 4 seconds
East 323.47 teet to an Iron pin set In line of land now or formerly of James HII~ thence along line 0 land now or
formerly of James Hill, South 57 degrees 33 minutes. 26 seconds East 71.86 feet to an Iron pin sa in line of
other lands now or fonner1y of John Thrush; thence aiong line of lands now or fomlerly of John Tr sh, South 08
degrees 12 minutes 52 seconds East 92.95 fsetto an iron pin; thence through lands now or form y of John
Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and piace of begi nlng.
Containing 1.176 acres. more or less, and being Lot No.3 on a certain subdivision plan entitled" bdivision for
John Thrush" dated January 22, 1988, .drawn by John R. Kissinger, Registered Surveyor, which p an is
recorded In Cumberland County, PA Plan Book , Page . '
Parcel #39-14-0171-164
BEING KNOWN AS:
69 CHERRY GROVE ROAD, SHIPPENSBURG, PA 1 257
39-14-0171-164
PROPERTY ID NO. :
TITLE TO SAID PREMISES IS VESTED IN AMOS L KEEFER JR
~ARKEOLEFAER, HUSBAND AND WIFE BY DEED FROM AMOS L KEEFER ANgR OL
. LESHER N/K/A CAROL A KEEFER A J . ,. AND
OF SURVIVORSHIP AND NOT A . ,OINT TENANTS WITH R GHT
RECORDED 11/8/01 IN DEED BOO~ i::~:gE ;~4.COMMON DATED 10/1 /01
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-5389 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 AMOS L. KEEFER, JR Al"D CAROL A. KEEFER
(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
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: Ca) an attachment has been issued; (b) the garnishee(s) is enjoined fr m
paying any debt to or for the account of the defendant (s) and from delivering any property of the defen nt
(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 a a
garnishee and is enjoined as above stated.
Amount Due $158,872.24
L.L.
Interest FROM 4/23/03 TO DATE OF SALE 12/8/04 - PER DIEM @$36.38-$21,682.48
Atty's Comm % Due Prothy $1.00
Atty Paid $959.48
Plaintiff Paid
Date: JULY 20, 2004
Other Costs
CURTIS R. LONG
(Seal)
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATION CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 04302
Real Estate Sale #23
On August 27,2004 the Sherifflevied upon the
defendant's interest in the real property situated in
Southampton Township, Cumberland County, P A
Known and numbered as 69 Cherry Grove Road,
Shippensburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: August 27, 2004
By: J'a otvIJ~~
Real Estate Deputy
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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-BCl
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
({;;;(Q)/f2J'W
v.
Amos L. Keefer, Jr.
Carol A. Keefer
Defendant
NO. 02-5389
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT
WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment
of your costs only.
\ !1M---
Mark J.~dren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
DATED: September 26, 2006
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