The URL can be used to link to this page

Home My WebLink About00-02281 J ~ '" -~ ,- ,"-', ,'01'"' MARK J. unREN &: 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . . COURT OF COMMON PLEAS . ' : CIVIL DIVISION : Cumberland County v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) : NO. 00 J .J.;U> 1 Clo~L '-r~ 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 furtber notice, for any money claimed ,in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 :f\c-q:) \ q c..{G3 .c ~-j " ~ -" i: ," ,--.,~ AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de lademanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa 'aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus,propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, ,SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 .1 '-'" .'A"""" " '" ." "C, '" '. ~ ' ; NOTICE The amount of your debt is as stated in the attached document.' The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the mformation 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 MARIO. UDREN Isl Mark J. Udren, Esquire, 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 ,~ ''%< .~< '-~~~' '-"" 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Assignee: Recording Option One Mortgage Corporation Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 Date: LODGED FOR RECORDING Book: Page: 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: 1620 W. Lisburn Road MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township COUNTY: Cumberland DATE EXECUTED: 4/9/99 DATE RECORDED: 4/21/99 BOOK: 1535 PAGE: 964 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 " ' " ~ . ~ ' -'''" c_'",-." "-'0'" .';';;' ;'''''"''''~i~ secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. S. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note ,as follows: (a) by failing or refusing to pay the installments of below; principal and interest when due in the amounts indicated (b) by failing or refusing to pay other charges, if any, indicated below. 4/6/00: 6. The following amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 9.65%* from 11/1/99 to 4/6/00 (the per diem interest accruing on this debt is $28.21 and that sum should be added each day after 4/6/00) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $175.16 and that sum should be added on the first of each month after 4/6/00) Late Charges (monthly late charge of $54.69 should be added on the fifteenth of each month after 4/6/00) Other Fees Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $106,687.83 4,457.18 250.00 280.00 0.00 250.20 68.25 5"334.39 , $117,327.85 * The Interest Rate and Per Diem are subject to adjustment as more fully set forth in the Note and Mortgage. , ~ . ~'< ':;' ~ -~ hk 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 or Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, accordance with the requirements of those acts, and the date appearing on the copy attached hereto as exhibit A, and made part hereof, and defendants have failed to proceed within the time limits, or has been determined ineligible, or Plaintiff has not been notified in . a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $117,327.85, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged Mark . Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ~-'" ~ jl","'.~ --- -~ '" ~ ",' ~!?! ALL THAT CERTAIN LAND AND REAL ESTATE, AND EVERY TRACT, PARCEL, LOT AND PJ:ECE THEREOF SJ:TUATE J:N MONROE TOWNSHJ:P, CUMBEIlLAND COUNTY, PENNSYLVANJ:A, BOUNDI!:D AND DESCRJ:BED AS FOLLOWS: BEGJ:NNJ:NG AT A POJ:NT ON THE NORTHEBN SJ:DE Oli' LJ:SBURN ROAD (L.R. 21013) ON THE DJ:VJ:DJ:NG LJ:NE BETWEEN LOTS NOS. 67 AND 68 ON THE HEREJ:NAIi'TER MENTJ:ONI!:D PLAN Oli' LOTS; THENCE BY SAID DJ:VJ:DJ:NG LJ:EN AND THE DJ:VJ:DJ:NG LJ:NE BETWEEN LOTS NOS. 67 AND 69 ON SAID PLAN Oli' LOTS, NORTH 21 DEGREES 59 MJ:NUTES 20 SECONDS EAST 249.05 Ii'EET TO A POJ:NT; THENCE SOUTH 73 DEGREES 29 MJ:NUTES EAST 100.45 Ii'EET TO A POJ:NT; THENCE BY THE DJ:VJ:DJ:NG LJ:NE BETWEEN LOTS NOS. 66 AND 67 ON SAID PLAN OF LOTS, SOUTH 21 DEGREES 59 MJ:NUTES 20 SECONDS WEST 258.64 TO A POJ:NT ON THE NORTHEBN SmE Oli' LJ:SBURN ROAD AFORESAID; THENCE BY THE NORTHERN SJ:DE Oli' SAID ROAD, NORTH 68 DEGREES 00 MJ:NUTES 40 SECONDS WEST 100 FEET TO THE PLACE Oli' BEGJ:NNJ:NG. BEJ:NG LOT NO. 67 OF SECTJ:ON Ii' ON THE PLAN'"OF LOTS KNOWN AS MONROE ESTATES AS RECOIlDED J:N THE OFIi'J:CE OF THE RECOIlDER OF DEEDS FOR CUMBEIlLAND COUNTY J:N PLAN BOOK 23, PAGE 177. -" ,. c _,<_I" .-, U' - ,~ ~ ". ~- ,'~ -" ,'" ~ Mt . , e. February 02, 2000 OPTION . ONE MORTGAGE;; CORPORATION Joseph J Poeschl Nancy L Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Homeowners Name: Joseph J Poeschl Nancy L Poeschl property Address: 1620 W Lisburn ~oad, Mechanicsburg PA 17055 Loan Account No.: 158438-2 original Lender: OPTION ONE Current LenderjServicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: ., * IF YQUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN" THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP.TO DATE. THE PART OF THIS NOTICE CALLJ;;D "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. on 71 EXHIBIT A CORPORATE OFFices u:3 ADA - IRVINE.. CALIFORNIA 92618_2304" P.O. sox 57041. IRVINE. CALIFORNIA 92619~7041 PHONE 949."790.8100/ BOO.326.'500. FAXLINE 949.790.6"182 G) ........ -", ~ " ".-~ " 'e , ~ - ~, ~ . ,-" ~~ .' . e. OPTION ~ ONE Re: Loan No. 158438-2 MORT~AGE CORPORATION CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FOREeLOSURE MAY PROCEED AGAINST YOUR HOME IMMJ;;DIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. OPl71 COFlPORATE OFFICES -:3 ADA _ IRVINE _ CALIFORNIA 92610-2304 - P.C>. BOX 57041 - IRVINE - CALIFORNIA 92619-7041 PHONE 949.790.8~OO J 800.326.'500. FAXL\NE. 949.790.e~82 @ " - ~ ~ .......- ,~ ~" ',,,' '., "-.', ',;.,' " -~ 10 . . e. Re: Loan No. 158438-2 OPTION ONE MORTGAGE CORPORATION ********************************************************************** NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1620 W Lisburn Road, Mechanicsburg PA 17055 lS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: 1 MONTHS @ $ 1,086.61 2 MONTHS @ $ 1,086.61 $ 3259.83 (b) Previous late charges; $ 140.82 (c) Other charges; Escrow, Inspection, NSF checks $ 15.00 (d) Other provisions of the mortgage obligation, if any $ 8.25 (e) TOTAL' AMOUNT OF (a) (b) and (c) REQUIRED AS OF tHIS DATE $ 3423.90 B. YOU HAVE FAI~ED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $3423.90, PLUS ANY MORTGAGE PAYMENTS AND LATE 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 and send to: Option One Mortgage Corporation 3 Ada Irvine, Ca. 92618 You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable. ) OPl72 @ CORPORATE OFFICES - 3 ADA'" IRVINE - CALIFORNIA 92618-2304 - P.O_ BOX 57'04-1 ... IRVINE'" CAL.IFORNIA 92619-704-1 PHONE 949.790.8100/800.326.1$00'" FAXL.INE 949.7'90.8"182 , Co ,.~. - )0' "', -,.2.'" ]~'.... :.uliGI e. OPTION . ONE Re: Loan No. 158438-2 MORTGAGE CORPORATION IF yOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to .its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required ,to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due 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 or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN 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. OP173 ~-=.._. CORPORjIo.TE OFFICES" 3 ADA" IRVINE - CALIFORNIA 926'6-2304 .. p.o. BOX 57041 .. IRVINE" CALIFORNIA 926'9-704'1 L:.J PHONE 949.790.8100 I 800.326.1500" FAX'-INE 949.790.8182 r__" . " " ,', -~,- 1 " " "'" ~,--- "" "i e. OPTION . ONE MORTGAGe COFlPORATION Re: Loan No. 158438-2 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-790-8182 CINDY VASQUEZ X8216 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * TO SELL THE PROPERTY TO OBTAIN .MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. : * TO HAVE ,THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 CORPORATE OFFices.. 3 AOA" IRVINE - CALIFORNIA 9261a~2304 - p.o. aox 57041 . IRVINe.. CALIFORNIA 92619-7041 Pl-lONE 949.790.8100 I 800.326.1500.. FAXL.INE 949.790.6182 (E) ,1>' " "'~d!:: l...cxV\ #JfIQJlt. Z 145 513 429 Certified Fee ". Special Delivery Fee Restricted Delivery Fee '" m Return Receipt Showing 10 Whom & Date DeUve(ed .~ Return Receipl Showing III Whom, <: Date, & Addressee's Address o g TOTAL Postage & Fees $ C"') Postmark or Dale E (; "- in Q. Z 145 513 430 ..,')S Postal Service f:leceipt for Certified Mail No Insurance Coverage Provided. 00 not use for International Mail See reverse Sent 10 ,~ Postage Certified Fee Special Delivery Fee Restricted Delivery Fee '" m Return Receipt Showing to ..... Whom & Date Delivered .5.. RetumReceipt Showing 10 Whom, <( Date, & Addressee's AddwSS o ;: TOTAL Postage & Fees $ C"') Postmark or Date E (; "- en Q. ~- ~"- V E R I FIe A T TON Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark MARK Udren, ESQUIRE UDREN & ASSOCIATES -'~ 1 ''It" ~~!Oi!lllE!!liil'llijH~.li\'l!Ili';illill8!!ti~li""J.Jli'_""'iirlk'H~i,":-<i~lli!l;M~~""""''''"" ~1 :2~ l-J ~ ~'-l () , """i~~'-"'. """"l""'I<ri"-'''>lllllil!ti;;iI!llf ~ -. ., ~~........,,.;' '" ~ ~~ ."--.' ~ .- r ~ I i i<l ~ ~ -( t-r 0 ~ 8 a 0 0 0 c: 0 -n <_:... :c-" v i:~-_, -;:J ~ m :::-0 z: / r:' --:-) -. c.-" 1'0 Sl~ -' . - < --v -\"" , :F; c; ~..~ ;:-"525 :e- el :,,) z:srn -- c.:: z :::_4 =:2 c- :'6 <'"' -< rr 1 , ~ - Co.. ~ SHERIFF'S RETURN - REGULAR ( , . CASE NO: 2000-02281 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA ET AL VS POESCHL JOSEPH J ET AL RICHARD SMITH ,,~ ~" - "' ~, ',;1 , Sheriff or eputy Sheriff of , Cumberland County, pensylvania, who being d ly sworn according to law, says, the within COMPLAINT - MORT FORE POESCHL JOSEPH J as served upon DEFENDANT , at 0016:30 HOURS, on the 2 th day of April at 1620 W LISBURN ROAD MECHANICSBURG, PA 17055 NANCY L. POESCHL (WIFE) by handing to a true and attested copy of COMPLAINT - MOR FORE NOT! CE the , 2000 together with and at the same time directing Her attentio to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.32 .00 10.00 .00 32.32 So ~t- R. Thomas 04/27/2000 MARK J. UDRE me this ~ Sworn ,and Subscribed to before By: day of ~ c76vV' A.D. ~afruU-~/ A~~~ othonotary/ Deputy Sheriff ~ -, . ~ ~.- .."" ~.-. "'c . ,-" ~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-02281 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA ET AL VS POESCHL JOSEPH J ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon POESCHL NANCY L the DEFENDANT , at 0016:30 HOURS, on the 26th day of April , 2000 at 1620 W LISBURN ROAD MECHANICSBURG, PA 17055 by handing to NANCY L. POESCHL a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~rYJ'.- ~/ R. Thomas Kline 04/27/2000 MARK J. UDREN Sworn and Subscribed to before By: me this :5~ day of ~. tHvV A.D. ~~ C~ '~~..- ~. - '(J "-J'tl;~ rXhonotary I ~ ,.... ~ """""', _..~~~ " -, ~ J. ......... MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 104~0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 00-2281 civil term v. Joseph J. Poeschl Nancy L. Poeschl Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. MARK J. lIDREN & ASSOCIATES DATED: June 27, 2000 BY: 4. Udren, Esquire ey for Plaintiff It ~"""- -=~ "~~".. - ~~~.- " J.J!!i '. " -- V E R I FIe A T ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1JrV4."1 /~-r doo1 . .fJ,-~ f 1J.!/1A~ ~i tl~: JENr'~'E PALACIOS ASSistant Secretary Company: j~~l\b';f;;OOiI1i!!~~frilMijfJ.l!rd~~iDlMf:",^-*,'A''''',)m;j,"""",,~;-jo''i;!J~hit..lf~...~'" ui_~ k-~ ~ tli~ ,'",;,,- (") C <~ -0("' llldl Z~~, '-' j /.:: c-- Cf) c'-;~ ~c; -,.; ?:8 Pc:' z =2 .~, .- . o ,.>~. ~~ () "n ..., s , -'}] "n -> -,,-,''-, . ~ '..,i ,--,", i.':?tq _-.~ , , j , ~ -< ""D :x f>.) (:J c'"' - ~ ~ " ," ~ ~ . " ........ ~~ ~. "'",_ -" .J ", r . MARX J. UDREN & ASSOCIATES BY: Mark.J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY H!LL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Joseph J. Poeschl Nancy I."-_J?oes<::l1:L _ ~'. _____u 1620 -W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES : NO. 00-2281 civil term - -----..------- TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 04/07/00 to 06/27/00 Late charges per Complaint From 04/15/00 to 06/27/00 Escrow-paymentmjJer'Cbmplaint From 05/01/00 to 06/27/00 $117,327.85 2,313.22 164.07 ~ -------~3 5 0-32 TOTAL $120.155.46 I hereby certify that (1) the addresses of Defendant are as shown above, and (2) that notice accordance with Rule 237.1, a copy of which MARK the Plaintiff and s been given in ed hereto. DATE: Ju.ly J 4 dLbO , Mark j' dren, ESQUIRE Attor.~TY for Plaintiff M '~'~~ ~ I.r .)12 , 'pU PROTHY DAMAGES ARE HEREBY ASSESSED .",;,~--~.--"=~~ ~.,'-- o. _ H - -" ~~ '-~~I f' , HARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant (s) NO. 00-2281 civil term June 16, 2000 Joseph J. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFlCACION IMPORTANTE DATED: TO: USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CABO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ' (10) DIM 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 ASSIST,ENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A. DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~"' ~h ", """iLl."""'"'.L,,,,,,.~ P"""="'...'. '," - ~~,> ,"' - , u,~ ~ . Ffi <' . MARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) NO. 00-2281 civil term DATED: TO: June 16, 2000 Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO :tI. LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SINNECESIDAD 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 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~"'^"- ""' " , ~ ..."~ , - --- -, ' ~"- "in r . I . ,,~ . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 : NO. 00-2281 civil term Defendant(s) TO: JOSEPH J. POESCHL 1620 W. Lisburn Road Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ~ ---------X---JUaglllent by Default Prothonotary Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 856-482-6900 ~__bl.""""''''~ ~~ ~ "~_~ -< " , .."'"," ~ ~ ~ "-~;t;>.1;i ,- . , . . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust "-999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Joseph J. Poeschl Nancy L, _ Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER-AND--ASSE.S.SMENT OF DAMAGES : NO. 00-2281 civil term . TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 04/07/00 to 06/27/00 Late charges per Complaint From 04/15/00 to 06/27/00 Escrow payment per Complaint'~ From 05/01/00 to 06/27/00 $117,327.85 2,313.22 164.07 liQ.32 TOTAL $120 155 46 I hereby certify that (1) the addresses of Defendant are as shown above, and (2) that notice accordance with Rule 237.1, a copy of which MARK the Plaintiff and s been given in ed hereto. Mark J. dren, ESQUIRE Attorrley for Plaintiff . f DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY li&I'IC.Iii' 'l"lii~";'" ~o_'I~~f.L~~~~~"'liti,H;jfu~;JltlW.'fIid1$t.l "'''~'~-''- < oili!ilIiV"'~ t @ ~ ~ ~ ~ --{) , 0 0- f ..0 ~ ~ -U ~ ~ W --.. p:; fl1' "-..J ..... J r: ""'-""","", o c ijiff Z:" z;; ,s.:~ ;:5::':: :.s "-..: -----.. -~ -,,,,,t i ~~~~ Z --i -< ~~ ~ ' 1 . ~. ..,>, . C) ,<~ c} 'Tl L r~= ''''f , '--'1 l.:J -0 .-.-; ~~~) 1'., ~.~:~ u ~"'1 ,~ 5cJ -< (;:I ~~ "~~. ~- .~, - ..1>1;(-.' 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. . ---- --- ---------------~ ." -------~- Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 : NO. 00-2281 civil term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 1620 West Lisburn Road Mechanicsburg, PA 17055 Amount due $120.155.46 ~ ~- ---Ihterest--FrolU -Jli:l1:e-28-:-Z0-0-O--~-~----- to Date of Sale December 6 2QQO~ Per diem @$28.21 ~U-4.570.02 (Costs to be added) $ MARK J. UDREN & ASSOC TES Mark J. U ren, ESQUIRE ATTORN Y FOR PLAINTIFF , ",.i...i;~'-' .>-.L;~'"-"~'--"=~i~~~jl~MliII' ~~;;i!;~l!.""a~~IiIIlI- . w_ '':;'0 -~~' ,- ~. ~"~~~.- '" "_ 0 I., Ii I: i \ ...... ll,. <- ~o(q 0- ~ ...... ~ (J ..f.;J. ~ , ..0 VI ~ J.Jtl ~ :--- w B ~ . 7~ 2-> 8 0 . . '1 0 r"., () c- D 0 J0 C' }..> I 0 0 ~ I , c a Q if> , ""'o~ , ~ 0f L.. G ...J 2rY-i c:: ~ '0, ,- ", l'- , ::: .... "'7-" ...., ~ .... "' ~_r- ~ ~~ cn~~ '-J ;::$-- ""0 <,Cl , "' .. .. '~ J:> _~ ::~"-? :z:c. -~ " .... ;s:'-' jI C ~ :z: -; -< '':;' ~''''"''''''~~ ~,'~-~~--~'_."" ~.-.,~=... 1 , ~~ '- -..\, 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. , --------------..---.------------ ---I Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 : NO. 00-2281 civil term Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: ____A. In Assumpsit (Contract) ~. In Trespass (Accident) ~C. In Mortgage Foreclosure ____D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: -----.J\. . ---"LB. ____C. ~. ____E . ____F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): ~. ____B. ____C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above state which Defendant is resident of the Pennsylvania. Resident: is not applicable, Commonwealth of Mark J. Address ESQUIRE # as above , i;'~""" -A';mia~~I~~Iii~'~~Jbi&ja.'1>:~~~iIit_ '.".' '~ ," l1riIW.\llliiilliIil~'~""""""'"~ ~ "-..- "' 0 ('::1 i..-::J c: 0 ;;: -(1 'Jr" S:: rTlf-n ~= Z-T' -- 2:(~ , :T'i (j)<::,:~ r--- ,~ ~cS ",0 ""- ~> ~C " C' ::~ ~~~~ ~~ Pc f)? u 2: ~ =< -- C) ::u -< __'~lffl/lll!l~- <h~'"" ~ . -'- -' ~,- ., 'IJi~4 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 00-2281 civil term v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF ~ COUNTY OF D ~ 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: SS Defendant: Age: Residence: Employment: Joseph J. Poeschl Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Nancy L. Poeschl Over 18 As captioned above Unknown 9~(/J1()11~ I P dAA./Q- Name: Title. JENNIE PALACIOS Company: Assistant Secretary )....... ... ..... ..... ~ ..... ...... .... ..... .... .... ..... ..... ogKATHERINE J. MILCHAKL COMM."1205572 :. Cl : NOTARY PU8L1C.CALlFORNIACil ~ ORANGE COUII/TY 0 J . ' COMM. EXP. DEC. 202002'" ,. ....... - ~ ..". ...... ..... - ~ ....... - - '. - 4. .8~'"" i 'l<M""'~~~,~~~,~'B~~~~;-k","",:*4..'<lit,"~,",N&tl!i.~li~~--""~" Od. ~~ ...""""~.j ~P'""""""1lIliikti - ~..... 0 (.:J C- c: 0 '.~) -o~- -"I ( -, liln-; S= " Zx: i-' :;-:':r- .,:; ~:!:! C/)..J> .....,....-.,. .- -~ 'or' ,,- r:: c -- i-" V ~~~ ....J 'i> =H z() :z: -< 5>0 :~~;: I:') c: '" C)'l> Z --I ~ p. -< C:' :-0 -< o ~ ,,~ ~ "",~ ~~' -' ~ ""-". 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. - ------------- Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 . --- ------------- -------- ....---------------- -- ----------------- : NO. 00-2281 civil term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied r Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \ Mark J. Udren, ESQUIRE ATTO EY FOR PLAINTIFF ",~'M"_~ Ie 'A ""d.lllltlliIl~If~_t"f 1'-jil.t.,,,,jl""OO~,u,-~raJttiAi!llii!!1.' ""'-."'<''-.'' '"",""~",,~ ~~ ",' ~ ~ - ..,,~., -=~" ~ . C) (:) .' C ,::1 ~..i :;?" ,~ ufr~ gJh~i ~_:U - zr- '. (J)}:" ~!:; . :J -< >' -, ~C ""f; ''''J '--,.' 'So , ::8 zO :J:!: -::) --.(-; ":C'-- C) >c ",-, ~S ,n 4 > ",>.~"~ -< (::J :D -< ~ llIlL ~ ,~.,- . "I <-. . .' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Joseph J. Poeschl NancYu:L--"__P()_~s~hl ,~_________________ 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) : NO. 00-2281 civil term AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2, 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: 1620 W. Lisburn Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) , Name Address JOJSEPH J. POESCHL 1620 W. LISBURN RD., MECHANICSBURG, PA 17055 NANCY L. POESCHL It20W .LISBURN Rb:,MECHANICSBURG,PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. " , ~~"~"d._~' , .', ~ ~ ' ~if, c. ,'. .. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and __<3,c!ci~E!f3f3_0f_u<=~~ry___otI1E!r_person of__whom_tJl_e__plaintiff_l1<3,s__ knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1620 W. Lisburn Road, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: June 27, 2000 Mark J. Udren, ESQ. Attor y for Plaintiff , ~ii~"'~~~'i'~'''''''~~~~~~I~lf).Ji$'''''''-i'''1.i<'il!:d'''';'''' -,"" ,,!~". "" ,:~.~"";",;:>. rlilli~~"'':~ '~l!i""'" o S;; ...,..,::..". n'lfI) ~~E; c!5-T-- r:;~: K.....-. )~~ 2,,1 "}:;,:O -c 2: =<' ~ ~, C) ,"" , , " C;) (::J '- ~:= o .(..;" .~ v .~ -~ t'....) ",^~ I ...- " . '-IlIiIIW*U ~ < . ~"~ , 'rl!;t:.'" - r , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 ~CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. ___ - _______n___ __ __ _ Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 : NO. 00-2281 civil term .,\, Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOSEPH J. POESCHL 1620 W. Lisburn Road Mechanicsburg, PA 17055 NANCY L. POESCHL 1620 W. Lisburn Road Mechanicsburg, PA 17055 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 6, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, COMMISSIONERS HEARING ROOM, 2ND FLOOR, CARLISLE, PA to enforce the court judgment of $120, 155.46, bl5tained by Plaintiff-aoove- (the mortgagee)- against you .--un-- the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BI< ART,I< '1'0 PREVENT THIS SHERIFF'S SAT,I< To prevent this Sheriff's Sale, you must take immediate actio~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (80;6) 48?-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one I the (See notice on page two on how . ,- ....~, - , - . ~ .. t YOILMAY STILL-BE-AaLE TOSA'IlE YOUR PROPERTY-AND YOU HAVE OTHEL:&IGHTS EVEN ~F THE SHERIF~S SALE DOES TAKE P~~L 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 __dis.t:ribution of the money bid for ycmr hou_~~_~:L~_l_.Ee filed by the Sher~f~_____ ___ -----~.d thin 30 "days-- affer-- the sale. This schedute -, wilT-s-tate 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 THJ:S PAPER TO YOUR LAWYER AT ONCE. J:F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFJ:CE LJ:STED BELOW TO FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVJ:CE Cumberland. County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE. LICENCIPADOS__DE_FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 . !tiftlll""" .>..;,.J~IiIiIlll8W~~i:~m;~~~~ll-'~_'i;i.~" <<.,- e "'-~~"-'...;~ ~~~ i~~ () c: U~' III 'cc ;:?L,t Z,-,c, 0))" ~f:~) )o>c ?-(~, J-~C ~ "' (~ ~,- ~ , ; C) a '- c.:: ,~ C) -r., .'-1 ""to :2: -,:-n r-, ,~ 3~~~ , ':,:C) fE'" -< j.~ - --~~ ".- ,. ,."..~~ ^' t ~RK 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 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland~ County v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) : NO. 00-2281 civil term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 plaintiff, by its/hi~/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 E:lChibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order'is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: U' UDREN & ASSOCIATES Dated: October 24, 2000 Mark J. Udren, Esquire Attorney for Plaintiff ;- ~ .. ~ .- -~~~- ~~;y' . ' . p 1IIi@L~", .:J<.,IO 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 Norwe~t Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 00-2281 civil term v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Llsburn Road Mechanicsburg, PA 17055 Defendant(s) DATE: July 18, 2000 ~ TO: ALL PARTIES IN INTEREST AND ClA,~S NOTICE ,OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): JOSEPH J. POESCHL & NANCY L. POESCHL PROPERTY: 1620 W. Lisburn Road Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING .;.it. , , The above captioh~d property is scheduled to be sold at the C~erland County Sheriff's Sale on December 6. 2000, at 10:00 AM, at the COMMIS~IbNERS 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 ffn~~IT A of the schedule. .~ .. ~ . -u en "T1 o 3 "" '" .... NO~_-.l II~:~~ co-ow -0 -< ~I~ ~ ~ 1~~I~d ~ t} ,~ ~,$'~r- ffi Q1.l/NnO G ... l& ....-.: --IC 00 N "'"''''Tl _00 f"o-o --tr -<<>N3 ;;:: " '" e- '" n o 3 "R '" ;; 0. e- '< .... '< -c '" :l: "- ;; -~ .' ~'" - - ~-< lA' 0 ;i'iii 0.- , <To ~ , C- ~g- " " .....0 ~ "3i . o . " ;ll-< .0 0- . !eo <z - ~ 5 .-U!?g- .", ". e -." Q(i' ~o o. m " 6 " 3" . " .~ ." ~ ~ \~:f I - ~ . ;; ~ m .!!. " '" o ~ CD ~ "'C !:1. " "'C '" " -~ ~~~;i 8~.sz:; C' "u,~!la: ~3 oi.~ s~[:~~ ~~3~g8' ~ ~~~a2. " IV"CI U1::1 < g=~8,ge. 2:;~r8: =. ; ~;..;'~; !!. e....~ ~D gg::;lg"'~ e.~ogR~ ~ ;;-~;; r:: g ;::~ !i! g ~ & fi!,: :~g. o.~~~5g e.g~3~;' i_a.","'" 6.~3~cr!: = 5; '" 3 'g a. oS lt~~:: 2: tllllllS''''!!l iii is.i-a.3:::I \i n!.~ ~~ :g;~Ri "CI 3 ~"CI r::... ~:.g~ ~~ 8;"'!!'..~i-;. -< CD "CI 1II iD ;;: o~5lgao. ~!~tr'~~ Q,:l ~ "CI c: ,- ..!!.c:;!l-l ag~:g; o!!.~~5"3 ~ECn~~t n "" II 3 Il 3 Qi r" e:. 0: :: .. og. ~ ~. "CI~~~;;;6. ~::~~t:3 !!. g n" ,0::1 . -~ 8- '=t:'" .:; 2,01.... "CI - ""...."CI '" ~'E;5e 1 ... E ;;' ii' 2.!!!.II~~ ,.' ~ ': ~_.~ '" .... ~I '"I ... "" '" - ~ Q>~ , 5. . ",0.3 CD Q-CD [~t ' m '" 0.., z> ~"'<n C. t:::..? 3 i'r-" ;;;-~ T ' ". ~~ ~ -,"""", ..._~, '"" ~I - ... - "" - o to - '" I~~.J ~? ~~ b}~. ~ )~ .~ ~ ~/"l ./~~ " 0--; \.y litf!ff~f ;:. ;:: ~ ~ +- ~t- '\ ~I' s '" ":r: J' '. Sl ~1,s. ~ ",:..:;t " ~ :;: ~~ ~ ~ ~ ~ .fj;t~..;- P. " ~ " -~ -'" ~ ,\i'~i~;~~~ ~o:~ ~~?-){ .~ "t;J'i<- ~ _.; '\-. ~'t 2 ~".l :; 6- ~~~?~~ f ~ \"" 7 ~ t ~ f~f ~ ~'i 't:::i.~ ~ '" e- ::'~r t"~ &~ ~ "\ ~ ~ {""-.... ~ ~ , , I I I I I I I I I I I I I I I I I I I I I I I I I I ~~, ..'~~-'- ,~ z . 3 m a - o "'s: ol> nZ:O :c,,^ m-'- ::CZC:' :oOol> -(Ul:o:E ;!;;!;mo r-QZ-n ~,::r:.Ii'O~ z:El>() '-;:t>cnm o-<COcn "'UlO 8cQ A~~ mm '"Ul o o , ." .~ ;; '" m 0000 (")(1 $";;:1 ~g~.[ ::l ClI'" ClI C.m 0. , . 0. -n . . OOi!'O mSnAl )( -:=-1lI -; i~ 5 CII (lIc..:1 <II ('l ;;:;"::0 ;:QCllm ~g. g -Q. .g- o - ~ Q :I: 9~ OD:;lJ(") Cole.. ClI:r ~ S ~ ~~ Q. lCI S:~;'1lI 0""0 iil '0 S. 0 o.~ :::~-g ;.~.g :;0:- III -~::. t[~~~~;. .:. I; a~. ~ ... c, 0 iilg ~ <=' ~ E ~t: (D . 1i ~ ~i =: CD ~ 8~ ~ 06.;- ~ ~ " , ,,":::of;' ~?J-'?" " . . " "'oS. g 9 - 00> 0.'- e:;;.sr g:~!::!. , 0 0 ~m3 o 0 ~ 0-- 'E. 3 ii :}: ~; o5'~ =10 ij; ~ :.~ !2:Qc.. = . . . -n'" m T . ~ ;ll ::o~ m 3 0 . !!. ~rtHIB/T A ',<..,.,, ...._."~,......-;"-,..--".....~... _._-'.,,-........_, ... . :i'~;&I ~c~ "' 'If!!M~ifiMli~_ Iii""'- ~"' ''''~ "'" ~,' lli'OO'~ . 0 CJ C' C 0 -n s: Z ;:g ff~ ,:.:':) Z:-U ,-.:;:: " -y r'H ".'j ~ . . Ci)~';:. <.: :~.c"~ ;s -'<-~~ ~c; ""1:' -)c; :;:1 )> ,.-- zV ~;;~ ._-u (..,) Pc ~'. --, ~ .:::> jJ .j;"" -'< . u_ - "~ '~~;-" Norwest Bank Minnesota, N,A. -vs- Joseph 1. Poeschl and Nancy 1. Poeschl In The Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-2281 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED, Sheriff's Costs: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail Levy Postpone Sale Surcharge Share of Bills Law Journal Patriot News 30.00 13.28 15.00 15.00 .50 1.00 9.92 1.60 15.00 20.00 30.00 23.15 260.75 252.45 $ 687.65 pd by atty 12/01/00 Sworn and subscribed to before me ~r't-t:~~ R. Thomas Kline, Sheriff This 6'~ day of /J)p"'-"AL ..J 2000,A.D.q~-, 12.~~ Pr thonotary B'(&:H.J~& Real Estate Deputy j'U I. 3b~)D ()"'- ,~ID'I73)/ lIi .",.~-~ ,"" ~ -~, ~~. .- , " -" '-'S:":: r ..<i... , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust -1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Joseph J. Poeschl Nancy L.Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) : NO. 00-2281 civil term AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2, 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: 1620 W. Lisburn Road, Mechanicsburg, PA 17055 J.. Name and address of Owner(s) or reputed Owner(s): Name Address JOJSEPH J. POESCHL 1620 W. LISBURN RD., MECHANICSBURG, PA 17055 NANCY L. POESCHL 1620 W. LISBURN RD., MECHANICSBURG,~A 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. co ~~_..~ - ~~ ," ,- -"';J . ,." ,~. ,,-", ,- .. :,-,~ ' . "":t." , '", ". 'c", "".'..<; '--"'_':e~_,.:="........,.., , " . 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff_ has in the property which may be affected by Address Tenants/Occupants 1620 W. Lisburn Road, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: June 27, 2000 Mark J. Udren, ESQ. Attorn y for Plaintiff ~-- ~~"' .,~ "~' ~~~.~. "~~~ -.... ~~~ ~~" I ? ;' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American R~sidential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 : NO. 00-2281 civil term ..\ . Defendant(s) NO'l'LCE OF SHERll'F I S SA~QFJl.EAL~OPERTY TO: JOSEPH J. POESCHL 1620 W. Lisburn Road Mechanicsburg, PA 17055 NANCY L. POESCHL 1620 W. Lisburn Road Mechanicsburg, PA 17055 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 6, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, COMMISSIONERS HEARING ROOM, 2ND FLOOR, CARLISLE, PA to enforce the court judgment of $120,155.46, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NMI.CE-~WNE~~GH'l'S YOU MAY BE ART,E TO PREVENT THIS SliERTFF'S SALE To prevent this Sheriff's Sale, you must take immed~ate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: la56) 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how , ~...._""-~~~<....... ""4. ~ - " ~ . . tiEl '.-..<,",-"-. '- , YOU MAY~ .~.STILL.. BE ABLE TO SAVE_YOUR ~ PROPERTY AND YOU_ HAVE.OTHER_RIGHTS EVEN IF_THE_SHERIFF--'-S SALE DOESJAKE,!'LACE.. 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 wi thin 3 0 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 THJ:S PAPER TO YOUR LAWYER AT ONCE. J:F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFJ:CE LISTED BELOW TO FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVJ:CE cumberland. County Bar Association 2 'Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 - ~_.- ,-. -~~- -,.....ij JU,L THAT CERTAIN LAND AND REAL ESTATE I AND E'TJERY TRACT, PARCEL I LOT AND PIECE THEREOF SJ:TUATE J:N MONROE TOWNSHJ:P, CUMBERLAND COUNTY, PENNSYLVANJ:A, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POJ:NT ON THE NORTHERN SJ:DE OF LJ:SBURN ROAD (L.R. 21013) ON THE DJ:VJ:DJ:NG LINE BETWEEN LOTS NOS, 67 AND 68 ON THE HEREJ:NAIi'TEI~, l1ENTJ:ONED PLAN OF LOTS; TH~CE BY SAJ:D DrvIDJ:NG LIEN AND THE DJ:VJ:DJ:NG LINE BETWEEN LOTS NOS. 67 AND 69 ON SAID PLAN Oli' LOTS, NORTH 21 DEGREES 59 MJ:NUTES 20 SECONDS EAST 249,05 FEET TO A POJ:NT; THENCE SOUTH 73 DEGREES 29 MJ:NUTES EAST 100.45 FEET TO A l?OINT; THENCE BY THE DIVJ:D!NG LINE BET"AEEN LOTS NOS. 66 AND 67 ON SAID ~LAN OF LO~S, SO~H 2~ DEGREES 59 MX~ES 20 SECONDS WEST 259.64 TO A POINT ON TH~ NORTHERN SIDE OF LISBURN ROAD AFORESAID; THENCE BY THE NORTHERN SIDE OF SAID ROAD, NORTH 68 DEGREES 00 MJ:NUTES 40 SECONDS WEST 100 FEET TO THE PLACE OF BEGJ:NNJ:NG. BEING KNOWN AS 1620 WEST LISBURN ROAD " PROPERTY I!J NO. 22-26-0227-028' . TITLE TO SAID PREMISES IS VES'rED IN JOSEPH J. POESCHL AND NANCY L. POESCHL, HIS WIFE BY DEED FROM JOHN B. LAMPI AND PATRICIA A. LAMPI, HIS WIFE DATED 8/29/1986 AND RECORDED 8/29/1986 IN DEED BOOK 32 D PAGE 504 j I .-~ - -..- , ~ '""',1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-2281 Civil Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Nm:west Bank Minnesota, N.A. PLAINTIFF(S) from Joseph J. poeschl and Nancy L. Poeschl, 1620 W. Lisburn Road, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed toal\ach.,the pr9perty of the defendant(s) not levied upon in the possession of , ' GARNISHEE(S) as follows: ,~, " and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and ,from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the dllfendant(s) not levied upon an subjectto attachment is found inthe possession of anyone other than a named garnishee, you ari! direbtl!dto notifyhirnlherthat he/she has been added as a garnishee and is enjoined as above -~ ' Amount Due $1 ?n, 1 SS 4fi from 6/28/00 to date of sale Interest 12/6/M $4,515.02 peL dielll @28.21 Atty'S Comm % AttyPaid $120.32 Plaintnf Paid L.L. Due Prothy Other Costs $.50 $l.00 Date: July 14, 2000 curtis R. Long Prothonotary, Civil Division <-by: Mo/Y1L ~" 7J;rf7/?'-~/ . ~ Deputy REQUESTING PARTY: Name Mark J. Udren, ESG. Address: 1040 N. Kinqs Hiqhway, Suite 500 Cherry Hill. NJ 08034 Attorney for: Pl aintiff Telephone: 856-482-6900 Supreme Court ID No. 04102 j~~ .1 I '~ ~tl_alliG~~' '- - V'~H'. ~lIIillt~ ""llM$WI~_ffii;1l'Lil"ill,~~~LIiII'- <. ~ "'~-<."-=~,~ -.' ., ~w.."~~- _". '0 REAL ESTATE SALE No.p ."'I~;n~ ..II , the sheriff levied upon the defendants interest in the real property situated inry?1~A _,0 -!:,AJ:y.-lJfl " Gumberland County, Pa., known'lnd numbered as: cyy/p-<.d;lV",,~11'1 and more tu:" bed on Exhibit "A" filed with this writ and by this reference incorporated herein. '~.(# ~.2,7, ;7-= !/!2d2:lf c- 3d i lnr I"~ Aj_L, ;1..:1 it,:;:: \' , , i' I I I I s c:;r;] t:::tri) = @ =-:-', L.rLr'"'~,_ UDREN LAW OFFICES, P.C. BY: ~Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 221 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 Civil Term Defendant(s) , PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due Interest From 6/28/00 to Date of Sale September 8, 2004 Per diem @$27.63 $120,155.46 42,384.42 (Costs to be added) $ Mar J. U ren, ESQUIRE ATTORNEY FOR PLAINTIFF , - - ,. - - ~~~~;~.., -. 1l~~~Jij~i!5~~~ :-,-" '-'~" .---~""-" - .~ , , 7\J P -::; p ~ 6"'- "69- r ~~ t ~ .... <:"Q - W ....... :- 0 tI)..Q"l~ 6"" ,lU ~ 0 . D'c~i' ~ - -'= o w 0 "'.... "- 0 ~Q ~ ~ cCocn c~o r ~Q ~ 0 I I I ' ':tJ ~i' - ~~r ~ ... ... +. ~ .. ~ - - ~~ ... ~ . ... h ... .. ~ ... ... ... -r <-~,w _ H...... ,; Ii I; ,., i I I , I; I , NO 0 ~ 0 = I c = -n ~, -"'" s!Z!J ~, 50 3 u....... ~ VJ ;j;>> fT1rr, -< ~ '.1 ~~ " tv , -<.C.:e 0'\ ~& I ~c.~ X:!l , J;O -0 0 3 ~O -'f:.;;:;C) ,m >c r;-? ~ ~ N :xl "" -< 1.~Ii.,.J"i."~' ~W"'fJ'O"~ ~ .L.;....... ~^ ~ ~ ~ '-'='~~-<J WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-2281 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION AS INDENTURE TRUSTEE FOR AMERICAN RESIDENTIAL EAGLE BOND TRUST 1999-2, Plaintiff (s) From JOSEPH J. POESCHL AND NANCY L. POESCHL (1) You are directed to levy npon 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, yon are directed to notify him/her that be/she has been added as a garnishee and is enjoined as above stated. Amount Due $120,155.46 L.L. Interest FROM 6/28/00 TO DATE OF SALE 9/8/04 PER DIEM @$27.63 -- $42,384.42 Atty's Comm % Due Prothy $1.00 Atty Paid $820.47 Other Costs PlaintitTPaid Date: MAY 26, 2004 CURTIS R. LONG (Seal) prothon~ <-Bv: IJ~ p~ ~(".oA"I'-' J Deputy REQUESTING PARTY: Name MARK J. UDREN ESQillRE Address: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SillTE 200 CHERRY IDLL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ill No. 04302 "" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Resi4ential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ,P.C Mark J. Ud en, ESQUIRE ATTORNEY FOR PLAINTIFF I : II ~.- ~~ o1._'.l....iliIi~IIt'iIii!lJi!~!l!l~"'-,~--""-..';@..~ll!I~..Mi!ti@!~i1li!~'Ilr............ llIIiilllll ~ ~ .. . ~_~r """ i i-, I r,:1 ,I II !:i " ., i'l ;:! II [I I n ,..., ~ = c:: = :s:: .c- .....,.....<. 3 :I!...,., '-"''--;..-' "'" :nr-; m- z:rJ -< .-:: -;,.,- r"'~ N -urn ~?:i~ cr> g~ !<:C::1 -0 :.c ,{ ;:C~ 0- ::.:: 0 ::-.~~C) 5m PC ~ ~ Z ::;! r0 :n cr> '< \~ IN RE: Joseph John Poeschl Nancy Louise Poeschl d/b/a Prof Administrative Resources LJV / j8l{3f:~ IN THE UNITED STATES BANKRUPTCY -0-V)/9 / L"/ 3 COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA -;rij T U:? ~.~ ((Sl)YLA CHAPTER 13 ~-, Option One Mortgage Corporation Movant CASE NO. 00-04984 MDF 11 U.S.C. SEe. 362 vs. Joseph John Poeschl Nancy Louise Poeschl d/b/a Prof Administrative Resources Debtor(s) and Charles J. DeHart, Ill, Esquire Trustee RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this ~~-#--- day of ~ A..... ~: 0 , 20~, it is ORDERED AND DECREED that: ~ The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 V.S.C. 362, is modified with respect to premises: 1620 W. Lisburn Road Mechanicsburg, P A 17055 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. IlliMAF!Y D. ~E Bankruptcy Judge FilED HARRISBURG PA E,\WP51\BKY\2002\0230990cod.wpd APR - 6 2004 ~!..rk, ,U.8, Bankruptcy Court /Vnt.rL--- ,-) '""""'"~ ~ cc. Heidi R. Spivak, Esquire Marisa Joy Myers, Esquire UDREN LAW OFFICES, P.C. W oodcrest Corporate Center 111 W oodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 Charles 1. DeHart, ill, Esquire, Trustee P,O. Box 410 Humme1stown, P A 17036 Michael S. Travis, Esq. 4076 Market Street, Suite 209 Camp Hill, PA 17011 Joseph John Poeschl Nancy Louise Poeschl d/b/a Prof Administrative Resources 1620 W. Lisburn Road Mechanicsburg, PA 17055 E:\WP51\BKY\2002\0230990cod.wpd . ~ ,.- , - -~ '''- .'J' ," 1', UDREN LAW OFFICES, P.C. 'BY: Mark J. Udren, Esquire ~ ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2, 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: 1620 W. Lisburn Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Joseph J. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 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. ~ ~ ..c" , - -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 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 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 1620 W. Lisburn Road Mechanicsburg, PA 17055 Michael Travis, Esq. 4076 Market St., Suite 209 Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: May 20, 2004 I." ".~r ~~ii'~~~mt.;~':itl~~ "Ilillloaj" ' -== --' '-'~. " . . , .... (") ...., = 0 ~ = ~~ J:- '"T'l W~:.(! ::.:;g: :r." n~r:-i "'"' -.7> ..._~ -< m- ..:--. -~-' -0::;; ~~~; 1'0 en ::09 00 ~t:.~. ~~ri )>r~ -0 0:0 7~"; 3: j;() 3M c N Z ~ ::;J 1'0 cn -, en -< ;>-- ~ ~J ~ "_ ,~ ~ ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF _'J' I ! ~ Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph J. Poeschl c/o Michael Travis, Esq. 4076 Market St., Suite 209 Camp Hill, PA 17011 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10: 00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $120,155.46, 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 Sheriff1s 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 attorney1s 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 856-482-6900. 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. amoWlt. due 6900. 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 856-482- 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 THJ:S 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 FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVJ:CE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 . llilililiIUI8Il11tlIIIMWlillldIII1B1a.'ijl,\jj~~J:ililill;liI!"I"",I~iiltj'jfi~i~~.r;,i!jlii!lij@!<illli<_~i""lt~ll;lli:lr.""'"~-""ml.il' I" " _"..m.~""'......,," tiIi!iu "'-"'''''jl ,. lII!. - '.. ~ (') '" C = ~ <,,> <:" J:" ~m 3 ':r :,;........ -< rnfiJ &3' N ~~ ~t~~ m ~' )>.~-- " :E ~~~ :3: o::ij -0 ..i:"-n r::- 0' z :;1 =< N :JJ o~ -< -""""- .1.._ _ .~~ . ~. , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $120,155.46, 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 I 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 onel the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) -' .' , ~ , "...0 ,. 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 schedula 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 THJ:S PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LJ:STED BELOW TO FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 A8S0CIATION DE LICENCIDAD08 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 I 1~IdUIID -"~llIlil.iiljjlfllllill~~_iIIIlflIIl."-<>.''"'"~JIII,'-"jji.!dh.l'Jiiffi!l;dl'I_~tfftl(-~iiiluiil!iiW''''''''''''''' - , 1iilI-'-.~""'-'- 'l:IilIlilIliIlllllJ J111ii11iiii ",,", ?2 ,.s:: l~~: <t::~' ~~ $i8 '-.. ;..::: --I -< .~ '" <::> = J:- ::;;: ~ o -n :;:i fl1~ iS$; ::;1-,..- o::i:i ZO om );! 'D ,'< -< l\j Q) -0 ::!;: r:-! r", 0"\ ""- -~ '. " - , "< , ,~ "c'.'J " UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~1~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box,8517 Portland, OR 97207 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 00-2281 Civil Term v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Joseph John Poeschl has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on November 14, 2000, Bankruptcy Case No. 00-04984. Bankruptcy reimposed May 12, 2004. 0019463 Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for plaintiff _*Uililifll~,J~-"'~lIl~i'&!illil!<~~~!iMJ:Il!lll!iillai@.'~lull~~",,",;~l'n:',~~'~ ~- "~'"~ -, ~ ."L ~~~..~ ".;~- - ,~ ~-~~ 0 '" l:;;:) 0 :;:::.c:; = '" ..<c" <:'::' :2~ ..,..':;;....;:.- <- :--i':~ ;-.:.c; C.: ~~. ~ ,- n1r-: :':~- ." f'.) -011.] ::~J :uy w OC' r< -4_--;,,: ~C~ -0 ?~:l ~. L..", ~-'. -to" ',,;;.() ~:c: W :Sr'n Z; D ~ -< l.D ~ f~ " ~ -" Norwest Bank Minnesota, et al VS Joseph J. Poeschl and Nancy L. Poeschl In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-2281 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark J, Udren. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Surcharge Law Journal Patriot News Share of Bills 30.00 8.39 15,00 15.00 1.00 15.00 6,66 30,00 184.80 91.49 30.49 $ 427.83 Sworn and subscribed to before me So Answers: This.3A dayof 4~ ?"'""'~~ n R. Thomas Kline, Sh'eriff 2004, A.D,'--I'r' Cl n. .1//,. ), ~ Prothonotary , \,0--0 i.:.k yr;! D J:3 ~ d50f,b ;." - ~~ - UDREN LAW OFFICES, P.C. 'BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2, 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: 1620 W. Lisburn Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Joseph J. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 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 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 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 1620 W. Lisburn Road Mechanicsburg, PA 17055 Michael Travis, Esq. 4076 Market St., Suite 209 Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: May 20, 2004 " -.. -~ , , ~ I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ~TY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 g COURT OF COMMON PLEAS g CIVIL DIVISION i Cumberland County I MORTGAGE FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 NO. 00-2281 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph J. Poeschl c/o Michael Travis, Esq. 4076 Market St., Suite 209 Camp Hill, PA 17011 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $120,155.46, 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 Sheriff1s 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 attorney1s 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 RJ:GHTS 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. amount due 6900. 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 856-482- 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. 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. 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. J:F 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 17013-3387 717-2493166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 0...., - ~~ 'j;!.; - "" .,,,", ~ " ~ ., .. ~ ,.c. .I1iL PDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ~~TTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County FORECLOSURE Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 ~ NO. 00-2281 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nancy L. Poeschl 1620 W. Lisburn Road Mechanicsburg, PA 17055 Your house (real estate) at 1620 W. Lisburn Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $120,155.46, 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.) - -~.. [I~, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER ~~IGHTS 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, amount due 6900. 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 856-482- 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 THJ:S PAPER TO YOUR LAWYER AT ONCE. J:F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED 2ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVJ:CE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-2493166 or 800-990-9108 ~ ~ ~. kl~..,"" ALL THAT CERTAIN LAND AND REAL ESTATE, AND "EWBY TRACT, PARCEL, LOT AND PIECE TllEREOF SJ:TUATE J:N MONROE TOWNSHJ:P, CUMBEBLAND COUNTY, PENNSYLVANJ:A, BOUNDI!:D AND DESCR.J:BED AS FOLLOWS: BEGJ:NNJ:NG AT A POJ:N'l! ON THE NORTHEllN SJ:DE OIi'LJ:SBURN ROAD (L.R. 21013) ON THE DJ:VJ:DJ:NG LJ:NE BETWEEN LOTS NOS. 67 AND 68 ON THE HEREJ:NAli'TER MEN'.l!J:ONI!:D PLAN Oli' LOTS; THENCE BY SAJ:D DJ:VJ:DJ:NG :LJ:EN AND THE DJ:VJ:DJ:NG LJ:NE BETWEEN LO':!!S NOS. 67 AND 69 ON SAJ:D PLAN Oli' LOTS, NORTH 21 DEGREES 59 MJ:NUTES 20 SECONDS EAST 249.05 FEET TO A POJ:N'l!; THENCE SOUTH 73 DEGREES 29 MJ:NU'l!ES EAST 100,45 FEET TO A POJ:NT; THENCE BY THE DJ:VJ:DJ:NG LJ:NE BETWEEN :LOTS NOS. 66 AND 67 ON SAJ:D PLAN Oli' LOTS, SOU'l!H 21 DEGREES 59 MJ:NUTES 20 SECONDS WEST 258.64 TO A POJ:NT ON Till!: NORTIIEBN SJ:DE Oli' LJ:SBURN ROAD Ali'ORESAJ:D, THENCE BY THE NOl1!rHI!lllN SJ:DI!: OF SAJ:D ROAD, NOl1!rH 68 DEGREES 00 =ES,40 SECONDS WEST 100 FEE':!! TO 'l'lIE PLACE Oli' BEGJ:NNJ:NG. BEJ:NG LOT NO. 67 OF SEC'l!:tON Ii' ON Till!: PLAN.'OIi'LOTS KNOWN AS MONROE ESTATES AS RECOIlDED :m THE OFIi'J:CE Oli' 'l'lIE RECOBDER Oli' DEEDS 1i'0R CUMBEIlLAND COUNTY J:N ]?LAN BOOK 23, PAGE 177. BEING KNOWN AS: 1620 WEST LISBURN ROAD, MECHANICSBURG, PA l7055 PROPERTY ID NO. 22-26-0227-028 TITLE TO SAID PREMISES IS VESTED IN JOSEPH J. POESCHL AND NANCY L. POESCHL, HIS WIFE BY DEED FROM JOHN B. LAMPI AND PATRICIA A. LAMPI, HIS WIFE DATED 8/29/86 RECORDED 8/29/86 IN DEED BOOK 32 D PAGE 504 "'" H ~~ --~ ri.""~.~~ ~ .~ ~ ..._,_ "~ -'..._.,-~ ~: ~~ -< '~"\(J WRIT OF EXECUTION and/'!.f ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-2281 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION AS INDENTURE TRUSTEE FOR AMERICAN RESIDENTIAL EAGLE BOND TRUST 1999-2, Plaintiff (s) From JOSEPH J. POESCHL AND NANCY L. POESCHL (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) Vouare 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 enj oined as above stated. Amowt Due $120,155.46 L.L. Interest FROM 6/28/00 TO DATE OF SALE 9/8/04 PER DIEM @$27.63 - $42,384.42 Atty's Comm % Due Prothy $1.00 Atty Paid $820.47 Other Costs Plaintiff Paid Date: MAY 26, 2004 CURTIS R. LONG (Seal) ProthO~ p ~ '---By: ~ . 'C/l/Z/v, I Deputy REQUESTING PARTY: Name MARK J. UDREN ESQUIRE Address: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SmTE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supren1e Court ill No. 04302 ;~1liti@~41l~iilIliIllilfilj_ji",-""",''','''h''';'~.'''Jl>)tl;~~~~\WI$!!;~lilM"d'F~i','1\'''-;",,""NI,i'il-',l'"~"~KE~,'ilii...-....._~jiWIIlil'l.liiti!4mIiilAAJliOlIId!iiMII__I;>~lfl~'Mliil~iiO~mil~ ~- OJ. 1 Iill-~'u" Real Estate Sale #33 On June 10, 2004 the sherifflevied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, P A Known and numbered as 1620 West Lisburn Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 10, 2004 By:J~J.q5~ Real Esta~e Deputy (", \..\""1 cI --"\ \ _ n, ",-\.:J. \,\..... " I. !"..~' ,~' '11\\'" J "~' -, ~ , ~\~ ~ 1 ~'l',\ \\\1 b" b L \:10." .~, ""no ,,"~"..O\~"() U'''4,''. \" j" ).i:"II~ "\U,v i.1I'I:I\\'.> , ~ ~ ~ .. " . ,-,' THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Connnonwealth of Pennsylvania, Counly of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws ofthe Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the Cily of Harrisburg, Counly of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the Cily, Counly and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, aud all have been continuously published ever since; That the printed uotice or publicatiou which is securely attached hereto is exactly as printed and published iu their regular daily andlor Sunday/ Metro editions which appeared on the 27th day(s) of July 2004. 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 aud character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verifY this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Counly of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. , , ALL THAT CERTAIN land and real estate, and every tract, parcel, lot and nIece thereof situate.in 1!onroe Township, Cumberland County, ~sylvama, bounded and described as follows: :. '",:BEGINNING at a poinl on the Northern side of Us bum Road (LR.21013l on the dividing line . . . . hetweo, Lot, Nos, 67 ,nd 68 on the Iwreinaft" PublIsher's Receipt for Advertlsmg Cost mentioned Plan of Lo", thon", by ,.d dividing'h f Th P 'N d Th S d P . Nfl line. and the dividing line between Lots No.~. 67 :> er 0 . e atriot- ews ~ e un ay ~tn~t- ews, newspa~ers 0 genera ~ 69 on said Plan of Lots, North 21 degrees 59 ~dge receIpt of the aforesaId notice and pubhcation costs and certifies that the same have mmlltes 20 seconds East 249.05 feet to a point; i ~ce South ?3 degrees 29 minutes East IOQ.45 , feet to a pom~ thence by the dividing line between Lots Nos, 66 and 67 on said Plan ofiots SO)lth21 degrees 59 minutes 20 seconds We~ . 158.64,to a pciinfoJitheNorthern Side of Lis burn R9ad aforesaid; thence by the Northern side of swd .road, North 68 degrees 00 minutes 40 seConds West 100 feet to the Place of BEGJl\'NlNG, .. BEENG Lot No. 67 of Section F on the Plan of LoiS known as Monroe Estates as recorded in ! the. Office of the Recorder of Deeds for Cuiiib. .. erland County In pJan Book 23, Page 177. ."II.BING KNOWN AS: 1620 West Llsbum , Ro~d, Mechamcs-burg, PA 17055. PROPERTY ill NO,: 22.26.0227.028, TITLE; TO SAID premises is Vested in , Joseph J. Voeschl and Nancy 1. Poeschl, IUs wife, by Deed from John B. Lampi and Patricia A. Lamp;' his wife., d!Jteo 8129/E6 re....orded &'29/.86 in Deed Book 320 Page 504. . PUBLICATION COpy S ALE#33 ,. . ,ilEAL ESTATE SALE No. 33 Writ No. 2000-2281 Civil Term Norwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999.2 Va" Joseph J.Poeschl and Nancy L. Poeschl Atty: Mark Udren DESCRIPTION CUMBERLAND COUNTY SHERIFFS OFFICE CU1vlBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 91.49 By..........................,........................................, ~~ " "~""'"'-- ~.- " . . . M~ "~= ~ -:,,' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929),P, L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, v!z: JULY 16, 23, 30, 2004 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~~%~di" SWORN TO AND SUBSCRIBED before me this 30 dayof JULY 2004 L~ N TARALSEAl LOIS E. SNYDER, Notary Public Carlisle 60ro, Cumberland County My Commission Expires March 5, 2005 . MAL 1!iS1'A'rt!~E NO. 33 Writ No, 2001>"2281 Civil Norwest Bank MiIjnesota, Natlonah Association as Inpenture Trustee for American Re~E;identia1 Eagle Bond Tru~t 1999.2 . VB,. Josepb J. POeschl and Nancy L. Roeschl Atty.: Mark J. Udren AlL THAT CERTAIN land and real estate, and every tract, parcel, lot and piece thereof situate in Monroe Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point on the northern side of LislDum Road (L,R. 210 13) on the dividing line between Lots Nos. 67 and 68 on the herein- after mentioned Plan of Lots; thence by said dividing lien and the diviq", iug line between Lots Nos. 67 aild I 69 on said Plan of Lots, North 21 degrees 59 minutes 20 seconds East 249.05 feet to a point; thence South 73 degrees 29 minutes East 100,45 reet to a point; thence by. ' the dividing line between Lo'tS -NO's:" 1 66 and 67 on said Plan of Lots. South 21 degrees 59 minutes 20 seconds West 258.64 to a point on the northern side of Lisburn Road aforesaid: thence by the northern side of said road, North 68 degrees. 00 minutes 40 seconds West 100 reet to the place or beginning. BEING Lot No. 67 of Section F on the Plan of Lots known as Mon- ! roe Estates as recorded in the Of- i flce of the Recorder of Deeds for Cumberland County in Plan Book 23, Page 177, BEING KNOWN AS; 1620 West Lisburn Road, Mechanicsburg, PA 17055 Propert;y lD No. 22-26-0227- 028. TITLE TO SAID PREMISES IS VESTED IN Joseph J. Poeschl and Nancy L. Poeschl, his wife by Deed from John B. Lampi and Patricia A. Lampi, his wife dated 8/29/86 re- corded 8/29/86 in Deed Book 32 D Page 504. '" '"-" ~ .' " " ~,' . '.' ~'"' ~-", '..;~'~'- ;; "".,' -c,,,,, ~". ,_ " ~ ~ ~ - ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Northwest Bank Minnesota, National Association as Indenture Trustee for American Residential Eagle Bond Trust 1999-2 Plaintiff v. Joseph J. Poeschl Nancy L. Poeschl Defendant ~.~ ~ , ", t .,,-,_ 'n -\ ~_, trl~~ ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION County NO. 00-2281 Civil Term PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: Auqust 4. 2006 ~~ Mark J: Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff ~~~"j'.!j/;'''!I;!M'IHEM~oIill;~lW=''''''''"''''''-_l!IlIWlli!~oSM-~~"J'-'';';'' " .Ii.. ~-ntllli aT ~ ~. ~ ~"""."~ 0 /'oJ = 0 C = " -n~ 0"> , ,-.., ". 3'! r-nr';'- c:: Z'-T' G> rn ::v r- 6:~ s- N -0 en lJr. -/" " ~' Ul (~ j j"'--~' ;=- La ::< "- ~ ~~-1 -0 -r- -,; ~F c:..'--~r -",. '-.:::J _....J ~ "/'C) >c W 5in Z -, =2 N 55 -.; -< .