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HomeMy WebLinkAbout07-0667UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS 601 Penn Street :CIVIL DIVISION Reading, PA 19601 Plaintiff €Cumberland County V. Karen A. Gallagher 5401 Oxford Drive # 3 NO. 1ULL C Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Sovereign Bank Recording Date: LODGED FOR RECORDING 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 5401 Oxford Drive, # 3 MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 11/21/03 DATE RECORDED: 12/9/03 BOOK: 1847 PAGE: 4159 MODIFICATION AGREEMENT Recorded: 11/22/05 Book: 722 Page: 3687 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 1/31/07: Principal of debt due $91,647.58 Unpaid Interest at 6.250 from 9/1/06 to 1/31/07 (the per diem interest accruing on this debt is $15.58 and that sum should be added each day after 1/31/07) 2,364.52 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of $27.25 should be added in accordance with the terms of the note each month after 1/31/07) 143.83 NSF Fee 60.00 Inspection Fee 9.25 Attorne s Fees (anticipated and actual y principal) to 5% o 4,582.38 TOTAL $99,412.56 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regu lar mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant (s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $99,412.56 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, E UIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN CONDOMINIUM UNIT SITUATED IN VILLAGE OF MORELAND IV, A CONDOMINIUM (THE -CONDOMINIUM"), LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING DESIGNATED AS UNIT NO. 5401-03, IN THE DECLARATION OF THE CONDOMINIUM, DATED SEPTEMBER 14, 1995, RECORDED SEPTEMBER 22, 1995, IN CUMBERLAND COUNTY, MISCELLANEOUS BOOK 504, PAGE 636, AND THE DECLARATION PLANS OF THE CONDOMINIUM, DATED APRIL 7, 1995, RECORDED SEPTEMBER 22, 1995,:IN CUMBERLAND COUNTY PLAN BOOK 70, PAGE 133, UNDER THE PROVISIONS OF THE UNIFORM CONDOMINIUM ACT OF THE. COMMONWEALTH OF PENNSYLVANIA, AS AMENDED FROM TIME TO TIME, (ACT OF JULY 22, 1980, P.L. 286, NO. 82). UNDER AND SUBJECT TO EASEMENTS, COVENANTS, RESTRICTIONS, RESERVATIONS AND RIGHTS- OF-WAY OF RECORD. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date of Notice: December 4, 2006 KAREN A GALLAGHER 5401 OXFORD DRIVE #3 MECHANICSBURG PA 17055 Loan # 0356112746 The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the yrosram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Aeencies serving your County are listed at the end of this Notice. If you have any questions. You may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869). This Notice contains imuortant legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA MIPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDTTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMM SU HIPOTECA. HOMEOWNER'S NAME(S): KAREN A GALLAGHER PROPERTY ADDRESS: 5401 OXFORD DRIVE #3 MECHANICSBURG PA 17055 LOAN ACCT. NO.: 0356112746 CURRENT LENDER/SERVICER: Sovereign Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the 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, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT --The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours) on your property located at 5401 OXFORD DRIVE #3, MECHANICSBURG PA 17055, IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE THE MONTHLY PAYMENTS of $71032 since 10/01/06 to the present. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $2271.56. The total amount includes late charges and any other charges that have accrued to this date. If you disagree with the assertion that a default has occurred or the correctness of the calculated amount required to cure the default, contact: SOVEREIGN BANK OVERNIGHT DELIVERY: MORTGAGE COLLECTIONS DEPARTMENT PO BOX 8627 OR 601 PENN STREET READING PA 19603 READING, PA 19601 1-800-753-7366. 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 $2271.56, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PPgyments must be made either by cash cashier's checL certified check or money order made payable to Sovereign Bank and sent to the above address. 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 ro er . IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's 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 Sheriffs Sale. You may do so by paving 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 another costs connected with the Sheriff's Sale as specified in writing by the lender and by performing oy other requirements under the mort gage. 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 six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SOVEREIGN BANK Address: PO BOX 8627, READING PA 19603 Phone Number: 1-800-753-7366 Fax Number: 1-800-881-9334 Contact Person: Constance M. Cocroft, Vice President EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 may have the right to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ENCLOSURE) You may contact our Mortgage Services Department via E-mail at: MORTSERVO-SOVEREIGNBANK.COM This bank is a debt collector attempting to collect a debt and any information obtained from you will be used for that purpose. HOUSING AND URBAN DEVELOPMENT ("HUD") NOTIFICATION IMPORTANT NOTICE OF THE HOUSING AND COMMUNITY DEVELOPMENT ACT OF 1987 PLEASE READ THIS NOTICE. HOMEOWNERSHIP COUNSELING MAY BE AVAILABLE TO YOU. DATE: December 4, 2006 TO: KAREN A GALLAGHER RE: Account No. 0356112746 FROM: Sovereign Bank The Housing and Community Development Act of 1987 requires that Sovereign Bank notify eligible homeowners with delinquent home loans of the availability of homeownership counseling. Because your home loan is DELINQUENT, you may be eligible for homeownership counseling provided by certain non-profit organizations. PLEASE CALL THE HUD TOLL FREE NUMBER AT 1-800-5694287 FOR MORE INFORMATION. If you have any questions about your home loan you may call or write to Sovereign Bank at MORTGAGE COLLECTIONS DEPARTMENT SOVEREIGN BANK PO BOX 8627 READING PA 19603 1-800-753-7366 Constance M. Cocroft Vice President I I U .S. P ost al Ser vi 1 I M CERT ....._. -1--l IFI ' , _ .. ED .. _ ce MAIL EC IF poftm i fu o Q Cwmw Fee 0 Amum'ReoelPt Fee (r17eM Requked) LO (??WaemerA ry ru Tote( Pie & Feee Ln ,:, - ?-f_n V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. C-?k. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. V( C)' ? a C C-A L/I T r ITI UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Karen A. Gallagher Defendant(s) NO. 07-667 Civil Term MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure upon Defendant(s), Karen A. Gallagher by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) at 5401 Oxford Drive # 3, Mechanicsburg, PA 17055, which is the mortgaged premises. A copy of the Verification of Service is attached hereto as Exhibit A. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit B. 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said Defendant(s), Karen A. Gallagher by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFIC S, P.C. By: Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Karen A. Gallagher Defendant(s) NO. 07-667 Civil Term MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE : A sherif f ' s return of "not found" or the f act that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Verification of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage Foreclosure. A good faith effort to discover the whereabouts of the Defendant(s)has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. By: Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Sovereign Bank :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION :Cumberland County V. Karen A. Gallagher :MORTGAGE FORECLOSURE Defendant(s) :NO. 07-667 Civil Term VERIFICATION OF SERVICE Based upon information supplied by the Sheriff of Cumberland County, service of the Complaint in Mortgage Foreclosure upon the below listed Defendant(s) was unsuccessful in accordance with Pa.R.C.P. 402 or 3129.2: Defendant: Karen A. Gallagher Place of Service: 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Defendant not found because: Moved _ Unknown _No Answer _ Vacant_ Other Per Sheriff's department, after several attempts service was unable to be made. Mark J. Udren, Esquire, the undersigned, understands that the statements herein set forth above are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. February 14, 2007 -J"XNJ Mark J. Udren, Esquire Attorney for Plaintiff EXHIBIT A Players National Locator, inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number. 07010520 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number. Subject: Karen A Gallagher A.K.A.: Karen A Alt Last Known Address: 5401 Oxford Drive #3 Mechanicsburg, PA 17036 Last Known Number. ( ) - Melissa Kozma, being duly swum according to law, deposes and says: 1. 1 am employed in the capacity of. Location Specialist for Players National Locator, Inc. 2. On 0113112007, 1 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as foilows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER(S):218-78-8656 B. EMPLOYMENT SEARCH: We were unable to veft current employment for Karen A Gallagher. C. INQUIRY OF CREDITORS: Creditors Indicated the last reported address for Karen A Gallagher to $401 Oxford Ddve'03, Mechanicsburg, PA 17065 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no liafing for Karen A Gallagher. We called (717) 7374660 and spoke with a relative who stated Karen A Gallagher Is living at 5401 Oxford Drive d3, Mechanicsburg, PA 17035. INQUIRY OF NEIGHBORS - NIA INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of January 29, 2007 the National Change of Address (NCOA) has no change far Karen A Gallagher from 5401 Oxford Drive 93, Mechanicsburg, PA 17055. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: We were unable to verity currant drivers license Information for Karen A Gallagher. OTHER INQUIRIES - A. DEATH RECORDS: As of January 29, 2007 the Social Security Administration has no death record on file for Karen A Gallagher andlor A.K.Ke under the social security number provided. B. PUBLIC LICENSES (PILOT. REAL ESTATE, ETC.): Exhibit B None Found. n,1 1 ..vonIn •, rrr c nren nrly nrn -110"nccu C IORPIJ_MMfJ WIbO•bn in_tc_upP C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: September 1961 Im AFFiANT Melissa IN I d savor to a on 131 007 • htOTARY SEAL" Kristine M- SaOtt, Notary Public $t Lplil6 Coutiy, Stele of Missouri IVI Commission Expires gfy201 Commission Number 06428865 Players National Locafor, Inc. 174 Clarkson Road, Suite 225 StIouis, MO 63011 Phone: (636)234-9922 Fax: (636)230-0558 nj7_J A7n/71n•j etc-[ occn nc7 oca U011t OOM S JIDAVA-MA 4 bdwirfi ln-IF-utr VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief . The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Date: February 14, 2007 Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION ?Cumberland County V. Karen A. Gallagher Defendant(s) :NO. 07-667 Civil Term CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Certified Mail Other Date Served: February 14, 2007 TO: Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 UDREN LAW OFF S, P.C. By: Mark J. Attorney Udren, Esquire for Plaintiff c7 ? , ?' cz7 Co Cn e ? 0 FEB 16 2007 #4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION ;Cumberland County V. Karen A. Gallagher Defendant(s) ENO. 07-667 Civil Term O R D E R AND NOW, this I'S r day of 'rtAbfJ 0.J`sj , 200'? , upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Karen A. Gallagher, shall be complete when Plaintiff or its counsel or agent hers mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Karen A. Gallagher at 5401 Oxford Drive # 3, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 5401 Oxford Drive, # 3, Mechanicsburg, (Lower Allen Township) PA 17055. BY THE COURT: 8' 'Oi WV OZ 83A LOOZ AUVIL,04N,?,.XdUdH 31,14 JO 9 0H?c,,-tJ311J UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION =Cumberland County V. Karen A. Gallagher :NO. 07-667 Civil Term Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: February 28, 2007 UDREN LAW OFFICES, P.C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF r-,.N a C -' ..fit f l L -TI __ ? :1y7 r-w C J = L :a AL 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 pleadinas@udren.com Sovereign Bank Plaintiff V. Karen A. Gallagher Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED : uyt Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Nu UDREN LAW OFFIC P.C. Dated: Mar J. ren, Esquire Attorney for Plaintiff ---------- .... } .. ? o--- C3 ----------- - ?d 'ieey C3 O Ir Q' ru i ru / $ S98:4 2 eBeleod ielol L n Ln C3 0 (aejlnbey,-u, Jopu3) ee:1 k Mlea Pel.w.11 C3 C3 OJOH (Peilnbed luewesjopu3) C3 C3 VgWjeOd ee=l Wl-ij wMed C3 C3 ' ? ead Pelllueo Er a'• g eBelsod C3 C3 ET a- W F- Z iVQ` LIJ ¢ w U- GJ- U w O ¢ 0 J O p Z = 5?o c UJ uj crCC oor U O 0 TS Certified Mail Provides: r A mailing receipt r A unique identifier for your mailpiece r A record of delivery kept by the Postal Service for two years Important Reminders: r Certified Mail may ONLY be combined with First-Class Mailo or Priority Mail. ¦ Certified Mail is not available for any class of international mail. r NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. r For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 38111 to the article and add applicable postage to cover the fee. Endorse mailpiece Return Receipt Requested". To receive a fee waiver for a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is required.. r For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement "Restricted Delivery". r If a postmark on the Certified Mail receipt it desired, ease present the arti- cle at the post office for postmarking. If a postmarkk on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT. Save this receipt and present it when making an inquiry. PS Form 3800, August 2006 (Reverse) PSN 7530-02-000-9047 N W N O Ln N ' O -0 a C3 O 17 rr O E O Ln U rl ru E -0 C3 O N c 2 LL r M E u CV n. rya ? -TI 1 -' t UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Sovereign Bank :COURT OF COMMON PLEAS 601 Penn Street :CIVIL DIVISION Reading, PA 19601 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Karen A. Gallagher :NO. 07-667 Civil Term 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Karen A. Gallagher 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 $99,412.56 Interest Per Complaint 1,075.02 From 2/1/07 to 4/10/07 Late charges per Complaint 54.50 From 2/1/07 to 4/10/07 TOTAL $100,542.08 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has boen given in accordance with Rule 237.1, a copy of which is attached he eto. FILES, Mafk J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: PRO P OTHY FE916 im a IN THE COURT. OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Sovereign Bank :COURT OF COMMON PLEAS `Plaintiff :CIVIL DIVISION :Cumberland County r v. Karen A. Gallagher Defendant(s) NO. 07-667 Civil Term O R D E R AND NOW, this r- day of 20 o, upon consideration of Plaintiff's Motion and t Affidavit of Good Faith investigation attached hereto, it is herfty ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Karen A. Gallagher, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant.(s), Karen A. Gallagher at 5401 Oxford Drive # 3, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 5401 Oxford Drive, # 3, Mechanicsburg, (Lower Allen Township) PA 17055. BY THE COURT: J. TRUE COPY RECORD in estimori? . t my hand he seal u` r'am . T ........... G r- onzmirr • 5 K TU?,N - NOT FOUND 04U0000 CASE NO: 2007-00667 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOVEREIGN BANK VS GALLAGHER KAREN A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT. GALLAGHER KAREN A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named DEFENDANT GALLAGHER KAREN A 5401 OXFORD DRIVE #3 MECHANICSBURG, PA 17055 DEFENDANT MOVED TO NEW YORK, PER POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 18.00 8.80 - 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 41.80 UDREN LAW OFFICES 02/12/2007 Sworn and Subscribed to before me this day of A.D. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 MARK J. VDREN* CHERRY HILL, NEW JERSEY 08003.3620 MART WIIVNEG** 856-669.5400 QAYL SPIVAK ORLOFF*** FAX: 856-669.5399 HEIDI R. SPIVAK*** CHRISTOPHER J. FOX*** MARISA JOY MYERS*** LORRAINE DOYLE" FREDDIE MAC ALAN M. MINATO*** DWI%T MICH VON*** PENNS',VANIA •ADMI N.i, PA, F7. 'ADMITTED NJ, PA, FL DESIGNATED COUNSEL s"ADMITTED PA '''ADMITTED NJ. PA TINA MARIE RICH OFFIGT ADMDJITMATOR PLEASE RESPOND TO NEW JERSEY OFFICE Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Sovereign Bank VS. Karen A. Gallagher Cumberland County To Whom It May Concern: ENNSYLVANIA OFFICE 21 -568A500 2P15-568-1141 FAX C.C.P. No. 07-667 Civil Term In connection with the above captioned matter, enclosed please find Verification of Service by Certified Mail and Regular Mail Pursuant to Court Order. I have enclosed a copy of the first page to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. Sincerely,,. urs, Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. /mt Enclosures UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 0$003-3620 856-669-5400 p_leadinas@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION Cumberland County V. Karen A. Gallagher Defendant(s) .NO. 07-667 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED: 81U?0? Karen A. Gallaher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Nu UDREN.LAW OFP.C. Dated: (v?, Marl J. 6rAttorney for Plaintiff .p v '.EP ij w t 4 r ? ri t' ?.....-- .?..".". p$sl9odlw s ? Q ?- 003 3 `, i 1 Q ' t i eniWClPs C7 C3 t-3 0 lPef"a d?3 d p t r r p?6 ? °, 0 g to Ica ; v I 5col* Certified Mail Provides: ¦ A mailing receipt ¦ A unique identifier for your mallpiece ¦ A record of delivery kept by the Postal Service for two years important Reminders: ¦ Certified Mail may ONLY be combined with First-Class MaI6 or Priority Mauw r Certified Mail is not available for any class of international mail. ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For. valuables, please consider Insured or Registered Mail. ¦ For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 38111 to the article and add applicable postage to cover the fee. Endorse malipiece Return Receipt Requested'. To receive a fee waiver for a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is required. . 4 For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the cleric or mark the mailpiece with the endorsement "Restricted tWivey. IN if a postmark on the Certified Mail receipt i`s desirefl, please present the arti- cle at the post office for postmarking. It a postma on the Certified Mail receipt is not needed, detach and affix label with postage and mail. iMPORTAHr Save this receipt and present it when making an inquiry, PS Form 380(1, August 2008 (Aeveme) PSN 7530.02.000-9047 Er LO r- Rt3 .A f-3 _1 10 CI C7 Q C3 l Ln a ru _o C3 G7 r_ s? r a tt: T C's 2 ! LL I Z co i (0 1. ai a f UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 Sovereign Bank Plaintiff V. Karen A. Gallagher Defendant (s) TO: Karen A. Gallaher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 DATE of Notice: March 29, 2007 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Term 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR -TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ; 800-990-9108 / NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES CT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ANDeIMIS IS AN ATTEMPT COLLECT A DEBT. ANY INFORMATION OBTAINED WILL THAT r? 0. uaren, zsquire odcrest Corporate Center 11 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Sovereign Bank ;COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County Karen A. Gallagher :MORTGAGE FORECLOSURE Defendant(s) =NO. 07-667 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Karen A. Gallagher Age: Over 18 Residence: As captioned abov Employment: Unknown Name: MARK J. REN, ESQ. Titl ATTORNEY FOR PLAINTIFF Sworn to and subscribed Company: UDREN LAW OFFICES, P.C. before-me this llth day f April; 2 0 . y is z n -43 ^Z N C 'WI t 0 d -?I C"? k<' ? l-t C. '- -c7 r y UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Karen A. Gallagher :NO. 07-667 Civil Term Defendant (s) TO: Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered a7eh s *-y n the above proceeding as indicated below. P oX Judgment by Default 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: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Karen A. Gallagher ::NO. 07-667 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $100,542.08 Interest From 4/11/07 2,305.84 to Date of Sale 9/5/07 Ongoing Per Diem of 15.58 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. Mrll J. UZ1ren, ESQU1'RB RNEY FOR PLAINTIFF t 'V ? ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-667 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK, Plaintiff (s) From KAREN A. GALLAGHER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $100,542.08 L.L. $.50 Interest FROM 4/11/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $15.58 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,305.84 Atty's Comm % Atty Paid $182.75 Plaintiff Paid Date: APRIL 12, 2007 Due Prothy $2.00 Other Costs C s R. Lon no ry (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Karen A. Gallagher :NO. 07-667 Civil Term Defendant (s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P. . Lrk J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Karen A. Gallagher :NO. 07-667 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Sovereign Bank, 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: 5401 Oxford Drive, # 3(Lower Allen Township), Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karen A. Gallagher 5401 Oxford Drive # 3 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 Lower Allen Township Auth. 120 Limekiln Road New Cumberland, PA 17070 Village of Moreland Condo P.O. Box 1202 Association Mechanicsburg, PA 17055-9022 4. Name and address of the last recorded holder of every mortgage of record: Name Address Sovereign Bank 601 Penn Street Reading, PA 19601 W- 5. Name and address the property: Name None Address 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 Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 5401 Oxford Drive, # 3 (Lower Allen Township) 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. DATED: April 10, 2007 of every other person who has any record lien on UDREN LAW OFFICES, P.C. for Plaintiff o ::' 2 C --D UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Karen A. Gallagher :NO. 07-667 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Your house (real estate) at 5401 Oxford Drive, # 3(Lower Allen Township), Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 A.M. in the Commissioners Hearing Room, 2nd F1., Courthouse, Carlisle, PA , to enforce the court judgment of $100,542.08, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) «/ ? ' YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 0 D ` ' SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-00667 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOVEREIGN BANK VS GALLAGHER KAREN A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GALLAGHER KAREN A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , GALLAGHER KAREN A 5401 OXFORD DRIVE #3 MECHANICSBURG, PA 17055 DEFENDANT MOVED TO NEW YORK, PER POST OFFICE. Sheriff's Costs: So answers- -?" Docketing 18.00 Service 8.80 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.80?? UDREN LAW OFFICES a?l`' 02/12/2007 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-00667 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOVEREIGN BANK VS GALLAGHER KAREN A MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GALLAGHER KAREN A the DEFENDANT at 1542:00 HOURS, on the 5th day of March , 2007 at 5401 OXFORD DRIVE #3 MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 5401 OXFORD DRIVE #3 MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.56 Posting 6.00 Surcharge 10.00 Postage .39 3#7 44.95 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/06/2007 UDREN LAW OFFICES By : --'/' Deputy S eriff A. D. UDREN LAN OFFICES, P.C. BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 NOODCREST CORPORATE CENTER 111 NOODCRERST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Sovereign Bank 601 Penn Street Reading, PA 19601 Plaintiff V. Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the notice of sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: April 30, 2007 Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 I verify that the statements made herein are.true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 30, 2007 UDREN LAW OFF ES, P.C. Mark J. Udren, Esquire . FEB IN THE COURT. OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Sovereign Bank :COURT OF COMMON PLEAS 'Plaintiff :CIVIL DIVISION :Cumberland County r V. Karen A. Gallagher Defendant(s) :NO. 07-667 Civil Term AND NOW, this A r? day of 2007 upon consideration of Plaintiff's Motion and t Affidavit of Good Faith investigation attached hereto, it is her y ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Karen A. Gallagher, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Karen A. Gallagher at 5401 Oxford Drive # 3, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 5401 Oxford Drive, # 3, Mechanicsburg, (Lower Allen Township) PA 17055. BY THE COURT: ?5j 4n. J. TRUE COP`' F?1711A RECORD In estimom, -yt my hand e seal a ° , ..? d t A rn ? U, "A a O n o. K K o dt--' rt ..a 0w Lin Ln tr tr r ?wo w v ?© C3 ? now C3. o,v ldtW Po'tW Gallag?' 115? 3 v Karen A ford DTI pp. 1l X55 .. ° 5401 lospur9 or PC any,': Mec?n I 4 0 C) o, - lg? C) 0 m ?o? ? zn c' a 0 C3 p CP i r r 0- `L yaw ?? o w U'l LS ° ° fl ? © fl N C) O II n a ?? 3 zo fl s0 ptt teas N?u on s '4 ,?? t'?tS 111tI11i0d los ask zovrop „? tt So #4 ?ttou? u nttxtr ? uo V° ost6 ow-9 V. ci?d low P" F 'o eea4e1°P'g __? ,m x°. ?`?1u?''?t ? gas s++?al s? . LA woo nsw 044 3 we*, WA, la VEM!= Joe"" WAS &AV-w Aso-o- fag ps ?a+t's90°''"u?e ao? ?p,?,ssj L Y m QQ u .Q LL $ Do `r 3 _ .o a r 5 Q m_ 57m °'16 Y w log C u Q m a o C w c c m C c OOD .2 VO r iScrn v « ?r-I> to VZ u p???m3 O ?Sii ? 0.5 C ?°? TVP Q f? ?/ " W 0Ls a 170 m Q w E o a m V Y a V h H as W 0ui O. °a ?OyZ?'Q ?? rn Gv W J ? La z' ?Us0=ES, o CID E Q a LL W ca ccqq Z `i'o E 0 O Z IL_ A& LU r_ E o ti Ug = « a ce) y mZ C p r r r r F-J r ? J era C -., COP) Cam; N N '< UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Sovereign Bank :.COURT OF COMMON PLEAS 601 Penn Street :CIVIL DIVISION Reading, PA 19601 :Cumberland County Plaintiff V. Karen A. Gallagher 5401 Oxford Drive # 3 :NO. 07-667 Civil Term Mechanicsburg., PA 17055 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "Big. 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 t e penal of 18 PS. Section 4904 relating to unsworn falsification t u iti s./) Dated: August 30, 2007 UDREN /l.,ANI aF'FECESL P. C. BY: Mark U en, Esqtht Atto nev for Plainti UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire AM I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Sovereign Bank Plaintiff V. Karen A. Gallagher Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Tenn TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Karen A. Gallagher PROPERTY: 5401 Oxford Drive, # 3, (Lower Allen Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sherifrs Sale on Sgptember 5. 2007, at 10:00 A.M., in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A m LL ?a to L. ?o ? m a app ? s 32b1SOd'S'ti s?3.v as O 0 C Q 13 M O ftc?W4 0? ?+ Oo Z ?Ocabv??' c Q s Wa z o`" a°cm ? o '? Yd ! N NN Z ?Ue 0 O: r ?ol W ?aZ c o s d=pV WNiu1 ?? 3aJ C ym E m NQ?°cln? <o o° W G-, ? ?4 ZaLL°d?rz? •,??° ?a v 4 Z Q a. U.: O 01?-J C N v W uj?wO' J t-°" o ;WY = Z??`C4N?? %-6 Z?? Z WS W0 if 4 ?z cc 6 G v E ?O 00 C" ?$ c ?0 o ? N Z? o 7c $ iiiSSS t?? T I 0 V ® M? I IWE w I? a N r o ? .r r ?- r m a c n°. 0 ,o E O V Z' . g a U. ~ 1 + a u. Cl) Y .? It co r E%HIB1T A col N Vi N LO O a- O O N Q a?i UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CZ11TER 111 WO0DCR38T ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-569-5400 Sovereign Bank 601 Penn Street Reading, PA 19601 Plaintiff V. Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the notice of sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: April 30, 2007 Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 I verify that the statements made herein are..true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 30, 2007 UDREN LA OFF ES, P.C. Mark J. U ren, Esquire EXHIBITS FGo IN TER COURT. OF CON(ON PLEAS OF CUliBBxLAZ?D COUNTY CIVIL DIVISION Sovereign Bank 'Plaintiff V. Karen A. Gallagher Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-667 Civil Term AND NOW, this *ZJ day of 2007 upon rcL - -- - - -- consideration of Plaintiff's Motion and t Affidavit of Good Faith investigation attached hereto, it is her ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Karen A. Gallagher, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Karen A. Gallagher at 5401 Oxford Drive # 3, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at '5401 Oxford Drive, # 3, Mechanicsburg, (Lower Allen Township) PA 17055. BY THE COURT: ?5j 4n J. TRUE COPY FR^1A RECORD and {o Testimony, M NOW seal EXHIBIT B O un 0 m 0 ' w? ?mm • N # J O W L ui t b C c)-'00 o J m Z 33 F U13 i W m pm? ? y ? Z i7n o?Q ru I OFFICIAL' USE zr, c- . 37 rq Ia a 1 O CsrtllMd Fig 1 I p . p R?oNpt k HIM O 1 p i o w ? ?..M..,....- g i n R ced . wy .. ?. o O,G Toad PaMp? & ft" $ JY . .plp 0:0 3iV Karen A. Gallagher 5401 Oxford Drive # 3 W-i Mechanicsburg, -PA 17055_.... F t i1 S l Y .':'o A ? 1 EXHIBIT B I &Wd 3 O Q Q' O 02 w O t O O k? -J ? 0 RJ C ,.I o 13 i s e m0 f Lo . ? fu m(D 3 O W Ln to c m x g ?? 0? jisiw ao te?sw?M?{ tIM N1 w10104 a mm go" q we Mp "M uNtlaom l wu Pw oQrYiod qMo? Mq?i p1w w w w?o•?ppm"uN x*w 04 IR op nin4m Y A o ? M pJ u41 vo tma oomopw V* w" jo 4" as 0 2MK?V?u P? ? jo ooaupp¦ wp o4 popAm p Am AN2p `" puowp w "a • oil ql uo t YdNou unw wl;wv ? wq??ooyaoy¦'M¦I?pNwQd P? ??N+op?e«wa jooud ?PMQ+a o? p * tR jai! • '1lwu Iw+oP?+?MN ?p ? ? ?F M4??+ ol1lM? pP??J ¦ %on AWWd Jo 4"n oorq-? 4" pwA*m oq A'1NQ' 1= 2YMA o+w.oq wW" PAood an Aq *4 AWPOP to PMW V • aoo?cf?wu xwiL?a1 ?M?N?! «?N?v ¦ Ps Fmm SM .kpw 2W2 (RoY.rw) Y EXHIBIT B TM d ? 7 a a?a V ? a IOU g ?roWC? W T ,U r ffi 5JU k ry` F i? pa o o U C to C4 r> m VI ' 42 ?n p O 0 r f $ A a I k? EXHIBIT B I cc It U. r` M U. N a Sovereign Bank VS Karen A. Gallagher In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-667 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on May 09, 2007 at 1050 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Karen A. Gallagher, by posting the premises located at 5401 Oxford Drive, #3, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with a true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2007 at 1350 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Karen A. Gallagher located at 5401 Oxford Drive, # 3, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Karen A. Gallagher, by regular mail to her last known address of 5401 Oxford Drive, # 3, Mechanicsburg, PA 17055. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. So Answers- R. Thomas Kline, Sheriff B Real Estat Sergeant EXHIBIT B f-Z- Q 4z;p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Sovereign Bank is the grantee the same having been sold to said grantee on the 5TH day of Sept A.D., 2007, under and by virtue of a writ Execution issued on the 12th day of April, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 667, at the suit of Sovereign Bank against Karen A Gallagher is duly recorded as Instrument Number 200741612. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a. day of A.D. ? 0 U f, Recorder of Deeds Heoorder of Deeds, Cumberland County, C&dWb. PA MY Cornfh"on E)Oms the First Mw4ey o1JY1. 2010 Sovereign Bank In the Court of Common Pleas of VS Cumberland County, Pennsylvania Karen A. Gallagher Writ No. 2007-667 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on May 09, 2007 at 1050 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Karen A. Gallagher, by posting the premises located at 5401 Oxford Drive, #3, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with a true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2007 at 1350 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Karen A. Gallagher located at 5401 Oxford Drive, # 3, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Karen A. Gallagher, by regular mail to her last known address of 5401 Oxford Drive, # 3, Mechanicsburg, PA 17055. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Sovereign Bank. It being the highest bid and best price received for the same, Sovereign Bank, of 601 Penn Street, Reading, PA 19603, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $993.59. Sheriff s Costs: Docketing $30.00 Poundage 19.48 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 21.12 Levy 15.00 Surcharge 20.00 Posting 6.00 Law Journal 355.00 Patriot News 356.30 Share of Bills 15.69 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 993.59 1401 R. Thomas Kline, Sheriff BY Real Est Sergeant )- av 6?U, 6REN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF r BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION V. :Cumberland County ;MORTGAGE FORECLOSURE Karen A. Gallagher -NO. 07-667 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Sovereign Bank, 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: 5401 Oxford Drive, # 3(Lower Allen Township), Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS 41 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Lower Allen Township Auth. 120 Limekiln Road New Cumberland, PA 17070 Village of Moreland Condo P.O. Box 1202 Association Mechanicsburg, PA 17055-9022 4. Name and address of the last recorded holder of every mortgage of record: Name Address Sovereign Bank 601 Penn Street Reading, PA 19601 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. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 5401 Oxford Drive, # 3 (Lower Allen Township) 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. UDREN LAW OFFICES, P.C. DATED: April 10, 2007 Wk-,C. Udren, ESQ _ A tornev for Plaintiff ALL THAT CERTAIN CONDOMINIUM UNIT SITUATED IN VILLAGE OF MORELAND IV, A CONDOMINIUM (THE "CONDOMINIUM"), LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING DESIGNATED AS UNIT NO. 5401-03, IN THE DECLARATION OF THE CONDOMINIUM, DATED SEPTEMBER 14, 1995, RECORDED SEPTEMBER 22, 1995, IN CUMBERLAND COUNTY, MISCELLANEOUS BOOK 504, PAGE 636, AND THE DECLARATION PLANS OF THE CONDOMINIUM, DATED APRIL 7, 1995, RECORDED SEPTEMBER 22, 1995, IN. CUMBERLAND COUNTY PLAN BOOK 70, PAGE 133, UNDER THE PROVISIONS OF THE UNIFORM !:CONDOMINIUM ACT OF THE COMMONWEALTH OF PENNSYLVANIA, AS AMENDED FROM TIME TO TIME, (ACT OF JULY 22, 1980, P.L. 286, NO. 82). UNDER AND SUBJECT TO EASEMENTS, COVENANTS, RESTRICTIONS, RESERVATIONS AND RIGHTS- OF-WAY OF RECORD. BEING KNOWN AS: 5401 OXFORD DRIVE, # 3 (LOWER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 13-24-0791-002 TITLE TO SAID PREMISES IS VESTED IN KAREN A. GALLAGHER, SINGLE WOMAN BY DEED FROM KIMBERLY M. HOLLICH, SINGLE WOMAN DATED 11/21/03 RECORDED 12/9/03 IN DEED BOOK 260 PAGE 3649. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Sovereign Bank :COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION V. €:Cumberland County :MORTGAGE FORECLOSURE Karen A. Gallagher :NO. 07-667 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Karen A. Gallagher 5401 Oxford Drive # 3 Mechanicsburg, PA 17055 Your house (real estate) at 5401 Oxford Drive, # 3(Lower Allen Township), Mechanicsburg, PA 17055 is scheduled to be sold at the. Sheriff's Sale on September 5, 2007, at 10:00 A.M. in the Commissioners Hearing Room, 2nd F1., Courthouse, Carlisle, PA , to enforce the court judgment of $100,542.08, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-667 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK, Plaintiff (s) From KAREN A. GALLAGHER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $100,542.08 L.L. $.50 Interest FROM 4/11/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $15.58 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,305.84 Atty's Comm % Atty Paid $182.75 Plaintiff Paid Due Prothy $2.00 Other Costs Date: APRIL 12, 2007 (Seal) C-et Taju-4 C is R. Long, ota By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 ftjILA lam =CP `?J Real Estate Sale # 14 On April 20, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 5401 Oxford Drive # 3, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: April 20, 2007 By:U ' Real Esta a Sergeant a tool THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #14 t+? 1F?i+??' ;,9C ;A : Sworn to and subscribed before me this 20th day of August 2007 A.D. CC)NilviCi?V',lE?[..Y:; ? :'Eivlv?l'I.?ELi?!!A Iola ial Seal Terry L. RLsseii, i,;ota:y Public i City Of Ha; rise rg, Dauphin County M Corr,rniss' Expires June 0, 2011 I L- "}6(TI Fr' Pp?n nnin &ggr,,irt;-ofMMgri;;NOTARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 . 7. 1L PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and' says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 20, July 27, and August 3, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 14 Writ No. 2007-667 Civil Sovereign Bank VS. Karen A. Gallagher Atty.: Mark Udren DESCRIPTION ALL THAT CERTAIN condominium unit situated in Village of Moreland IV, a condominium (the condiomin- ium), Lower Allen Township, Cum- berland County, Pennsylvania, being designated as Unit No. 5401-03, in the declaration of the condominium, dated September 14, 1995, recorded September 22, 1995, in Cumberland County, Miscellaneous Book 504, Page 636, and the declaration plans of the condominium, dated April 7, 1995, recorded September 22, 1995, in Cumberland County Plan Book 70, Page 133, under the provisions of the Uniform Condominium Act of Lz_ e_ isa arie Coyne, 1tor SWORN TO AND SUBSCRIBED before me this 3 day of August, 2007 Notary NOTARIAL, SEAL DEBORAN A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My CommisMon Expires Apr 28, 2010