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HomeMy WebLinkAbout01-4559 HARX J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. XINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION . : Cumberland County v. Ronald Johnson A/K/A Ronald L, Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) : NO. 01- ~S~'1 CLl~l~h1 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 TUE 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 BBLOW TO FIND OUT WHERE YOU CAN GBT LBGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 AVISQ Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A ON ABOGADO IMMEDrATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO St7PICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEPONO A LA OPICINA Ct7YA DIRECCION SE ENCt7ENTRA ESCRITA ABAJO PARA AVERIGt7AR DONDE SE Pt7EDE CONSEGt7IR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 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 ofit, 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 fmn is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ 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: Option One Mortgage Corporation Assignments of Record to: Wells Fargo Bank Minnesota, National AssOCiation, FKA Norwest Bank Minnesota, National AsSociation, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 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: 23 Wheatfield Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland . DATE EXECUTED: 6/7/99 DATE RECORDED: 6/17/99 BOOK: 1550 PAGE: 901 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 Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 7/17/01: 6. The following amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 9.45% from 4/1/01 to 7/17/01 (the per diem interest accruing on this debt is $44.58 and that sum should be added each day after 7/17/01) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 7/17/01) $172,181. 49 4,825.62 250.00 280,00 Late Charges (monthly late charge of $87,48 should be added on the fifteenth of each month after 7/17/01) Corporate Advance Non-Sufficient Funds Charges Other Fees Attorneys Fees (anticipated and actual to 5% of principal) 0,00 735.36 96.00 15.00 61.48 8.609 0, TOTAL $187,054.02 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, Notice of Intention to Foreclose under Act 6 of 1974 of principal amount exceeds the sum of $50,000.00. the Commonwealth of Pennsylvania is not required as the original Assistance Program, Act 91 of 1983, has been sent as required on specified by the Pennsylvania Homeowner's Emergency Mortgage The notice the date appearing on the copy attached hereto as Exhibit "A", 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 $187,054.02 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~Udren, ESQU',. MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY ,RONALD S. RAFFENSPERGER, REGISTERED SURVEYOR, DATED SEPTElfBER 18, 1986, AND RECORDED IN CllHBERLAND COUNTY PLAN BOOK 52, PAGE-142, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: / L BEGINNING AT A POINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET SOUTH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF_WAY LINE OF WILD ROSE CIRCLE; THENCE ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINUTES EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT NO. ,32; THENCE ALONG LOT NO. 32 SOUTH 4 DEGREES 35 MINUTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF_WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CURVE TO THE RIGHT HAVING A RADIUS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 17,671 SQUARE FEET, MORE OR LESS. BEING IMPROVED WITH A DWELLING HOUSE, KNOWN AS AND NUMBERED 23 WHEATFrELD DRIVE, CARLISLE, PA 17013, 0."-05-01 MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 L AN= 1742659 DATE-D4-D4 USER=RF3 KEY-OP171 VERS=012 TITLE=part 1 Pennsylvania NOI L1NES-PER-PAGE~NO CONDITIONS~4 April 04, 2001 Ronald Johnson Catherine Johnson 23 Wheatfield Drive Carlisle, PA 17013 '. Homeowners Name: Ronald Johnson Catherine Johnson Property Address: 23 Wheatfield Driv, Carlisle PA 17013 Loan Account No.: 174265-9 Original Lender: OPTION ONE Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU_MAY_BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE_AN~HELP_YOU_MAKE_FUTURE .MORTGAGE_~AYMENTS 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 designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) 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 CUR~ YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING-YOUR MORTGAGE Up TO- DATE~ - _ _ _ _ _ _ _ _ _ OPl71 (I:/l-Idit) ",*1 'INfr *f 1'000 # 'l't>O., EXHIBIT A Ie FORM~ U.3-0 0003 "VII, 4~H" If J., OOiJ) Slqlj 42. €~ U~-U~-Ol MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN- 1742659 DATE=04-04 USER-RF3 KEY=OP171 VERS-012 TITLE-Part 1 Pennsylvania NOI LINES-PER-PAGE=NO CONDITIONS_4 Re: Loan No. 174265-9 '. 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 Noti~ 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. OP171 lc FORM= U;:l-U':'-Ul MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN_ 1742659 DATE~04-04 USERzRF3 KEY=OP172 VERS-023 TITLE=Part 2 Pennsylvania NOI LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 174265-9 ********************************************************************** 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: 23 Wheatfield Driv, Carlisle PA 17013 IS-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 @ $ 1,458.00 2 MONTHS @ $ 1,458.00 $ - 4374.00 Ib) Previous late charges; $ - 385.44 (c) Other charges; Escrow, Inspection, NSF checks $ - 15.00 Id) Other provisions of the mortgage Obligation, if any $ - 15.48 (e) TOTAL AMOUNT OF (a) Ib) and Ie) REQUIRED AS OF THIS DATE $ - 4789.92 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 100 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 $3389.92, 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: _ _ Overnight_Mail_Address 3 Ada Irvine, Ca. 92618 Western Union Quick_Collect Pay to: OPtion One Mortgage Corporation Code City: Option, Ca You can Cure any other default by taking the fOllowing action within thirty 130) days of the date of this letter. (Do_not_use_if_not {applicable. ) OPl72 lc FORM= U,:J-U,:)-Ul MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN= 1742659 DATE-04-04 USER-RF3 KEY=OP173 VERS=Oll TITLE=Part 3 Pennsylvania NOI LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 174265-9 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 in~nds 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 Iender 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 (3D) 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 byjperforming 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. OPI73 .__...~~.-.__. Ic FORM... 05-05-01 MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN_ "742659 DATE-04_04 USER=RF3 KEY-OP174 VERS=016 TITLE-Part 4 PennsYlvania NOI LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 174265-9 HOW_TO_CONTACT_THE_LENDER: " Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Office hours: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-784-6032 RAMON FIGUEROA X 5815 Monday through Thursday 7:00 a.m. to 9:00 ~.m. PST Friday 7:00 a.m. to 6:00 p.m. PST. 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-Qr '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. YQU_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 1 C FORM_ Y E RTF TeA T T 0 ~ 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. Udren, ESQUIRE UDREN & ASSOCIATES '6q. P .t ~~~~~ 6 D "l ~ ~ I C () ~ r;.. ~ j ~ ~~ ~ -......c. -C.-' ~~j C) ,'--\ ~:> C-; r. , :.,) \> ".,1 '("I, ::..<~ (~.~' " re . . .. SHERIFF'S RETURN - REGULAR CASE NO: 2001-04559 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS JOHNSON RONALD ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON CATHERINE the DEFENDANT , at 0831:00 HOURS, on the 1st day of August , 2001 at 23 WHEATFIELD DRIVE CARLISLE, PA 17013 by handing to RONALD JOHNSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r~ ~.,<~/~ R. Thomas Kline 08/02/2001 MARK UDREN Sworn and Subscribed to before By: 8. 'J 9JJ~ J ~/If7.A ~ Deputy Sheriff me this ~ ~ day of ()Z?; ~ AD <.., ~ci~ rothonotary'~ . '. CASE NO: 2001-04559 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS JOHNSON RONALD ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON RONALD the DEFENDANT , at 0831:00 HOURS, on the 1st day of Auqust at 23 WHEATFIELD DRIVE , 2001 CARLISLE, PA 17013 by handing to RONALD JOHNSON a true and attested copy of COMPLAINT _ MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.90 .00 10.00 .00 31.90 So Answers: r~~r'<~ R. Thomas Kline 08/02/2001 MARK UDREN Sworn and Subscribed to before By: ~ IJJt iIt . Deputy Sheri ,~ me this ~~ day of 12 ~ """J A.D. ? rotfln~ ~ MARX 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 Wells Fargo Bank Minnesota, National ASsociation,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Plaintiff . . NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: September 4, 2001 MAR N & ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff BY: . . ... , . V F. R I F J CAT JON 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. Name: Title Company: %' - \ 1:::)- 0 \ Date: , '. . ... I i ~ 0 ~ \ - \ II ~ ':;:I ;"'i::O , ~~F;; -..J ''':X; , ,') i :!=::O .boo 23y. I !{3 :z ,j::H '('5 I - z \ - om ~ " -1 - 35 \0 -< MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 ~040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1.999-BC4 P.O. Box 57038 Irvine, CA 9261.9-7038 plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : cumberland County : MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 1.701.3 Defendant(s) . . NO. 01.-4559 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DI.MI.GES 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 7/1.8/01. to 9/4/01. Late charges per Complaint From 7/1.8/01. to 9/4/01. Escrow payment per complaint From N/A to N/A $1.87,054.02 2,1.84.42 87.48 .Q TOTAL $189.32<;.92 I hereby certify that Defendant are as shown above, accordance with Rule 237.1., a (1.) the addresses of the plaintiff and d (2) that notice has been given in op 0 which is attached hereto. DAMAGES ARE HEREBY ASSESSED DATE:~ I] ( .Jt'Y~1 &: ASSOCIATES ICATED 4 n.(/)~J }2, PRO PROTHY , . 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff ATTORNEY FOR PLAINTIFF v. i COURT OF COMMON PLEAS ~ CIVIL DIVISION County \ NO. 01-4559 Civil Te~ Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) DATED: TO: August 24, 2001 Ronald Johnson a/k/a Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 rMPORTUIT NOTrCE 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 00 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 Lawyer Referral service Cumberland county Bar Association 2 Liberty Avenue carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTrFrC1crON rMPORTUlTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA. SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA. DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES . DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE pARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THB FAIR DBBT COLLBCTION PRACTICBS ACT. THIS LAW FIRM IS DBEMED TO BB A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BB USBD FOR THAT PURPOSE. , ", MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O, Box 57038 Irvine, CA 92619-7038 plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF 1 COURT OF COMMON PLEAS E CIVIL DIVISION I Cumberland county ~ MORTGAGE FORECLOSURE NO, 01-4559 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF tRu -tpd\A..-'U BrfJ1\Cf--' 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: COUNTY OF SS Defendant: Age: Residence: Employment: Ronald Johnson a/k/a Ronald L. Johnson Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Catherine Johnson a/k/a Cathy L. Johnson over 18 As captioned above Unknown Sworn to and subscribed before me th's 10 day (!..v~v'" , 200\. Name: Title: Compan ~" ~:~;.:t l' MalaY P\dC - carrarilI ! z omge eauntY 1 i_ _ _ ~~~~2:~ 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 Wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : cumberland county : MORTGAGE FORECLOSURE v. . . NO. 01-4559 Civil Term Ronald Johnson A/K/A Ronald L. Johnson catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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. prothonotary ~ 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. ESqllire At this telephone number: 856-482-6900 " . " ~ 'D ~ ~ i fk ~ (') 0 ~ I ~I en 'r' ! ,.., - --r'l I R' ~ ~ -0 r0F I ~?i I "='t9 I -.J :0 I C).L. "~'-ft..J ~ f'" ;,::0 ",. :r.: :~~ t) ~8 :x 0- -:>-0 V - of'n :l>c: - ""' " ~ ~ ~ \0 -< 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) . . NO. 01-4559 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189.325 9/. Interest From September 5. 2001 to Date of Sale Dec@mher 5./.001 Per diem @$44.58 4.101.36 (Costs to be added) $ REN & ASSOCIATES M rk J. A TORNEY (") 0 0 - ~"ltv~ I~ " - en :.:1 ~ ~ .to. ..() I'T1 -,-Lc "'1'1 ':'- . ~..Q!'l. :-h ~ -0 rnr=-:- it) ..{) ~S6B~~ I ,y..m 8 ~ -.l 06 fi- 0 i~ ;<0 :0- :;:i~ri I I II j I ~ ~8 :x ";=-" ~ ' )- 7-"70 r- ~ - (':)'" .c: ~ ~ ~ ~ ~ r ~~ .. ~ f' ~ ~ \0 -< f - ~ , 0-:; l; '" - - '"' ..... ~ --.~ 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. . Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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) ____B. 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: ----A . ~B. ____C. ____D. ____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): --1LA . ____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 is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: Ma k J. Ad ress ~ 0 0 " U') --.{ ~fB fT1 ::1: . -0 m~ ~~ I ~g6 -.J ;'~') :C'Sr>, ;,;:0 :Do -1:-,..: ~8 :x 0- .".0 - Om :;>~ .. ~ \0 -< 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . NO. 01-4559 Civil Term Defendant(s) C E R T I FIe ATE 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. rk J. Udren, ESQUIRE ORNEY FOR PLAINTIFF (") 0 ~ ~ en ";:1 ~i fTI :::L..." ." r-J1r= ~' I ~g~ -.I C) j( " ,.. '7 , l!t:: S:D i8 :x :.".~ - 0 '~ .. ~ \.0 - MARX 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . . NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive, Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive, Carlisle, PA 17013 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 ,. .... and address of the la't recOrded holder of every mortgage of record: Name Address Plaintiff herein. Citifinancial, Inc. See Caption above. 5. 'ame and addxe,s of every other per'on who has any record lien on the property: Name Address 1 Valley St., Ste. 103, Carlisle, PA 17013 NONE ,. .... and address of eVery other per'on who ha, any record intere't in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 COurthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N.Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address TenantS/Occupants 23 Wheatfield Drive, Carlisle, PA 17013 r Verify that the 'tatement, made in this affidavit are true and correct to the hest of my personal knoWledge or info_tion and helief. r under'tand that fal'e 'tatement, herein are made 'Ubject to the penalties of 18 Pa.c.S. 'ec. "0' relating to unsworn fal'ification to authoritie,. DATED: September 4, 2001 J UDREN & ASSOCIATES ark . Udren, ESQ. ttorney for Plaintiff .... -" . ~ 0 0 -i' ~ ...-1 ~gj :J::-n '"" ',np= << elm ~~ -J ?~C( ,:::,c:.> ;.:::0 ~ ... -n i~ I::J:D '7~ - S\ ., ~ - ~ \D MARX 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. " Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . . NO. 01-4559 Civil Term Defendant(s) TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NOTICE OF SHERIFF'S SAT.E OF RF.~L PROPERTY Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court jUdgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NO~~C~ : ~R'~ ~GHTS YOU Ml>.Y FlF: AFlI.F: TO PR~ ;; HI' S r To prevent this Sheriff's Sale, you must take immediate a~tion' 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (8;61 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the jUdgment, if the jUdgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ ~ -::ILL : ~r: : S= y= P~TY ANn YOU HAVl< EVEN rF THE SHERIFF I S S~~E ~~ S 1;: . OTHER RIGHTS 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 'Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. ~..' 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNoT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ~ c:> 0 -n tn -.,,1 Ig} lTt :;: ::n .,~ -0 ~~ I .., -> ~~:> CJ :P -rJ ",", :c:: --.." ~O :J: 0- ~~ 5>8 ~-I - S .. ~ .0 ~ , ~. ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY RONALD S. RAFFENSPERGER, REGISTERED SURVEYOR, DATED SEPTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COUNTY PLAN BOOK 52, PAGE.142, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET SOUTH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF-WAY LINE OF WILD ROSE CIRCLE; THENCE ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINUTES BAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT NO. 32; THENCE ALONG LOT NO. 32 SOUTH 4 DEGREES 35 MINUTES BAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CURVE TO THE RIGHT RAVING A RADIUS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. H " CONTAINING 17,671 SQUARE FEET, MORE OR LESS. BEING KNOWN AS 23 WHEATFIELD AVENuE, CARLISLE, PA 170;1.3, PROPERTY ID NO.: 21-05-0433-090 TITLE OF SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L.JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE. DATED OS/27/1999, RECORDED 06/17/1999, IN DEED BOOK 201, PAGE 979. / I , -. " MAR1C J. UDREN &: ASSOCIATES BY: Hark J. Odren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SOITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Ronald Johnson a/k/a Ronald L. Johnson &: Catherine Johnson a/k/a Cathy L. Johnson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 26, 2001, Bankruptcy Case No. 01-05206. ~ . Mark J. Udren, Esquire MARK J. UDREN &: ASSOCIATES Attorney for Plaintiff 2 0 .s;(, - t g .-t .-I f\1~ - 8~ di 1'> ..., :;:I. ii :]I: ~:Il ca og .t:" ~ &" I I j MAR1C 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . . NO. 01-4559 civil Term Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $J.a9. 325.921./ Interest From 9/5/2001 to Date of Sale Marc~ 2004 Per diem @$44.58 40.612 38 (Costs to be added) $__ MARK J. UDREN &: ASSOCIATES k J. Ud~ire ATTORNEY FOR PLAINTIFF ,~~ -, ~ ~ - ...c. ........ """'~ o ~ X C:::[' '-.. 0\ ,," , )-:- : o . " ,"-) :,'-1 .J C\ ~/J ) MARK J. ODREN &: ASSOCIATES BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SOITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . NO. 01-4559 Civil Term WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 23 Wheatfield Drive Carlisle, PA 17013 SEE LEGAL DESCRIPTION ATTACHED $189,325.92 40,612.38 Amount due Interest From 9/5/2001 to Date of Sale March 3. 20Q4 Per diem @$44.58 ~ (Costs to be added) $ Prothonotary By Clerk Date ~~ ~~ ~ ::: ~ ~, ~ ~, (~ '2>,~ , \ ~ 0-> ~ ~ I cl __\::t , \ . _ __ c)..J 1:: ---- eN '6 '?\~~ ~ ~ ~ ~9-- \ ...I:) ~ <J"o 0' C <::J l -r.'" {;) ~'l ...-_.' /.,1 ~~; ,- C--: ' .. t.~;C -. 0" c' ( i"_.! :.n "J -.--"-------.--- MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SOITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/KIA Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . NO. 01-4559 Civil Term WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 23 Wheatfield Drive Carlisle, PA 17013 SEE LEGAL DESCRIPTION ATTACHED $189.325.92 40.612.38 Amount due Interest From 9/5/2001 to Date of Sale March 3. 2004 Per diem @$44.58 (Costs to be added) $- Prothonotary By Clerk Date COURT OF COMMON PLEAS NO. 01-4559 Civil Term ------------------------------------- ------------------------------------- Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 vs. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson ------------------------------------- ------------------------------------- WRIT OF EXECUTION ------------------------------------- ------------------------------------- REAL DEBT $ '189.325.92 INTEREST $ 40.6]2.38 from 9/5/20~ to Date of Sale March 3, 2nnA Per diem @$44.58 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ , ',-. PREMISES TO BE SOLD: 23 Wheatfield Drive Carlisle, PA 17013 J. dren~~'re K J. UDREN -&E~~IATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 (856)482-6900 \ ALL THOSE CE1l.TAIN PIECE OR PARCEL OJ!' LAND SITUATE IN HJ:DDLBSE% TOWNSHIP, CllHBERLAND COtlNTY, PEllNSYLVANU, DOWN AS LOT #31, AS DESCRIBED IN- ACCORDANCE WJ:TH SUBDIVISION PLAN OJ!' THE MBl\D'OWS, PLAN #2, BY ~ONALD S. IlAI!'FENSPBllQBR. REQISTBRBD SURVEYOR, DATED SEPTEIIIlBll. 18, 1986, JUIID RECORDED IN CllHBERLAND COUNTY pLAN BOOK 52, PAGE .142, HORE PARTICULARLY BOllNDED AND DESCRIBED AS I!'OLLOWS TO WJ:T, BEGINNING AT A POINT ON THE EASTERN IUGKT-OJ!' -WAY LINE OJ!' WHBATFIBLD DRIVB, SAID POINT BEING IlEI!'E1l.ANCBD AND LOCATED 155.00 J!'EET SOUTH OJ!' THE INTE1l.SECTION OJ!' THE EASTERN IUGKT-OJ!'-WAY LINE OJ!' WHBATFIELD DIl.IVB AND THE SOl1THBll.1l IUGKT-OJ!'-WAY LINE OJ!' W.ILD 1l.0SE CIIl.CLB; THENCE ALONG LOT NO. 30 NOIl.TH 85 DEGIl.BBS 25 ......1l.JSS BAST A ,DISTANCE OJ!' 157.27 I!'EBT TO A POINT AT LOT NO. '.32; THENCE ALONG LOT NO. 32 SOUTH 4 DBGREES 35 JIINllTES EAST A DISTANCE OJ!' 150.00 I!'EBT TO A POINT AT THE NOW NOIl.THBll.N RIGKT-OJ!'-WAY LINE 01' WlIEATPIELD DIl.IVB; THENCE ALONG SAID RIGKT-OJ!'-WAY AND A CtlRVE TO THE IUGHT HAVING A RADIUS OJ!' 150.00 I!'BBT AN ARC LENGTH OJ!' 235.51 I!'EBT TO A POINT, THE PLACE 01' BEGDIlIDIQ. CONTAINING 17,671 SQUAIl.B I!'EBT, HORE 011. LESS. BEING DlPIl.OVED WJ:TH A DWELLING HOUSE, DOWN AS AND NllHIlEll.BD 23 WHBATFIBLD DIl.IVB. CARLrSLB. PA 17013. BEING KNOWN AS: PROPERTY ID NO.: 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 21-05-0433-Oc90 j TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE AS TENANS BY THE ENTIRETY BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 5/27/99 RECORDED 6/17/99 BOOK 201 PAGE 979. r~ ~,~ ;l) ~~ >z., c>> ~ ~ c:1 ....... -C: ....... .c:, ....... ~ \;' ~ -\:. --- "> ..(:. ' ......... .......... c.N .t::: --....... IN '6 ~~~ ~ :- ~,,\~,9..., -'l -.C'\ Vo C1' c:. C:! ( -,., . 6~ ::- ...,\ ..<- . ~~~ i. ;~i- "'--- j< {', .... t.' ~ ~/ , "'..J ~', "1 ,-:1 Jl '.1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE Plaintiff (s) From RONALD JOHNSON, a/k/a RONALD L. JOHNSON AND CATHERINE JOHNSON a/k/a C ATHYL. JOHNSON, 23 WHEATLEY DRIVE, CARLISLE PA 17013. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 23 WHEATLEY DRIVE, CARLISLE P A 17013 (SEE LEGAL DESCRIIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest 9/5/01 TO 3/3/04 @ $44.58 PER DIEM = $40,612.38 Arty's Comm % Due Prothy 1.00 Arty Paid 278.95 Other Costs Plaintiff Paid Date: NOVEMBER 21, 2003 (Seal) CURTIS R. LONG Protho~ota: JJ/t.~. By, ~, fL1U f . 1../' Dep REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856482-6900 Supreme Court ID No. 04302 IN /742Co5q CHAPTER 13 ..... IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLV -- IN RE: Ronald L. Johnson Cathy Johnson B~f{-cy....D Wells Fargo Bank Minnesota, National Association, f/kfa Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Movant CASE NO. 01-05206 MDF 11 D.S.C. SEC. 362 ~-. -....._~-_..~.~,. ~/ / , vs. Ronald L. Johnson Cathy Johnson Debtor(s) FILED HARRISBURG PA OCT 2 2 2003 (j;!/J and Charles J. DeHart, III, Esquire Trustee CIeri<, U.S. Bankruptcy Court RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this ~~,.J> day of Oaob<<Z- ,20 DJ ,itisORDERED 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 D.S.C. 362, is modified with respect to premises: 23 Wheatfield Drive Carlisle, PA 17013 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriff's 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. Is! WiARY D. FRANCE Bankruptcy Judge E,\WPS1\EKY\2002\023311S.COD c C i..~. -;:..;( 0.:)1' ...~". .>:.'! ",; cr~_1 r-~': -, "1 ., MARK J. ODREN &: ASSOCIATES BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) C E R T ATTORNEY FOR PLAINTIFF - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE - . NO. 01-4559 Civil Term - I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN &: SOCIATES squire TIFF (~, " ;.) :-n (:) MARK J. ODREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . . NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO ROLE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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. Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 Citifinancial, Inc. Address to follow 5. Name and address on the property: Name of every other person who has any record lien 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 Real Estate Tax Dept. Address 1 Courthouse Carlisle, PA Square 17013 Domestic Relations Section 13 North Hanover Street 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 23 Wheatfield Drive Carlisle, PA 17013 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: November 11, 2003 .~) . CI ....:- CJ ,- {...J 1-..'. ,) :'1 CD MAR1C J. UDREN &: ASSOCIATES BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 . . NO. 01-4559 Civil Term Defendant(s) NOTICE OF SHERIFF I S S.l>.T.E OF R'RIH. PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NO'tICE OF OWNER!.lLRIGHTS YOlLMAY. BE AP.T,E TO PREVF.1'lT THIS SHERIFF'S RAI.E To prevent this Sheriff's Sale, you must take ~.diate~~ 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: (8S6) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ARLE TO SAVE YOUR PROPERTY AND YOU HAVE O'l'HER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLA~ 1. If the Sheriff's Sale is not stopped, your property wil1 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 calI 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 wil1 state who wil1 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 SHOllLD 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 Lawyer Referral Service cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 , t'_" ."\ r._ .~ " ",." CD 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-4559 Civil Term Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO.1'ICE OF SHERIFF' S SJ!.T.'R OF ~'Rl\.T. PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 lHH,F. TO PRE\TmT THIS SHF.1UFF'S SlIT,E To prevent this Sheriff's Sale, you must take jmmeniate. action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, yOu may call: (856)-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOO MAY STILL B~. ~~LE TO SAVE YOUR PROPERTY AND YOO HAVE OTHER RIGHTS EVEN IF THE SHERTFF 'S SAT,'Il: DOES TAKE PT,l\.CE. 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 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 "T' l! i -", (" ~ -..._~ t-', ._,- ~ ) ':1 (:J MAR1C J. UDREN &: ASSOCIATES BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SOITE 500 CHERRY HILL, NJ 08034. 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) SOGGESTION OF BANKRUPT~ To the Prothonotary: Kindly note on the record that the above Defendants, Ronald L. Johnson &: Cathy Johnson, have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 26, 2001, Bankruptcy Case No. 01-05206. Bankruptcy was reinstated December 4, 2003. Mark J. Udren;1Eequire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff g ..., c:> () = -;1 ;?" ...., -p i~~ = ::;l ~.T:i t~ rn ...1_ -,-':- " n1/: ?-: t- -om ~<!:;-~~ 1.0 'o'J: b ~:~~=-: -,~ -r: :r- -r-~ ( } -~. ,c-.__ C ~A"''" ..:.:,( ) 5- ;.'o:-:,n1 c. <2 '.' 7": ---I ~ ;~ N -" Wells Fargo Bank Minnesota, In the Court of Common Pleas of National Association, f/k/a Norwest Cumberland County, Pennsylvania Bank Minnesota, National Association Writ No, 2001-4559 Civil Term As Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS Ronald Johnson alk/a Ronald L. Johnson and Catherine Johnson alk/a Cathy L. Johnson R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Poundage Advertising Mileage Levy Surcharge Law Library Prothonotary Share of Bills 30.00 2.49 15,00 4.14 15.00 30.00 1.00 29.32 $ 126.95 paid by attorney 01/13/04 Sworn and subscribed to before me So ~ This~dayof(~_"-'<h' j""'"') ~-., / j R. Thomas Kline, Sheriff 200f,A.D'(__)1/l~ () flvpjJv;# ~ _,/ ;'-', BY _ ~ i'Ut'l. Prothonotary Real Es te Deputy ~ \,<Y" c."~ ~04\gO ~ /Lj~'/)7 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term TO THE SHERIFF: PRAECIPE TO ISSUE WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 09/05/01 to Date of Sale December 8, 2004 Per diem @$44.58 $189,325.92 53,094.78 (Costs to be added) $ UDREN LAW OFFICES, P.C. tcJ P r ~ ~ ~ -t- if ~ 70P t-\ .... ~ ::c: ~ ~ t -.c: 'tq. :--- o <> ~ .r.! .t. ....-- ~..Q""""'.c'f-J./:: !) . "l fI) C/) 6"'" lrt cg~O~:O.Q C C C' frt CIl . I:' ~,~': '.' ~2 -"'r: (.. :::-.1 .... - :; C_~) ,-,,-) C,"'j .,'; '.c... , \ .. . . IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Ronald L. Johnson Cathy Johnson CHAPTER 13 Wells Fargo Bank Minnesota, National Association, flk/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999cBC4 Movant CASE NO. 01-05206MDF 11 U.S.c. SEC, 362 vs. Ronald L. Johnson Cathy Johnson Debtor(s) FILED HARRISBURG PA and Charles J. DeHart, m, Esquire Trustee MAY 25 2004 wlr Cleric, U,S. Banlcruptcy Court RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this )(lI.., day of AND DECREED that: I^~o . 20 l) i , it is ORDERED The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.c. 362, is modified with respect to premises: 23 Wheatfield Drive Carlisle, P A 17013 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 survi vo the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. 'l~~ Bankruptcy Judge~ 1;: E,\WPS1\BKY\2002\023311Scod.wpd 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/KIA Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. '"'0 :_;-"1 , -, =c ,.,-, '-,) r~ - 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 wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #l ABOVE 3. Name lien on Name and address of every judgment creditor the real property to be sold: Address whose judgment is a record None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancial, Inc. I Valley Street, Suite 103 Carlisle, PA 17013 Wells Fargo Bank National Association P.O. Box 57038 Irvine, CA 92619-7038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of the property and whose Name every other person who has any record interest interest may be affected by the sale: Address in Real Estate Tax Dept. I 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 23 Wheatfield Drive Carlisle, PA 17013 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: June 30, 2004 h..._) (,~ ~ \_-' UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff , COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NOTICE OF SHERIFF S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 charges, costs and reasonable attorney's fees. you may call: (856) 669-5400, mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition aSking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need 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 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 f"_) ('-'.. ::;:.1 " 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NOTICE OF SHERIFF'S TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF i COURT OF COMMON PLEAS ~ CIVIL DIVISION ! Cumberland County FORECLOSURE i 01-4559 civil Term SALE OF REAL PROPERTY Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 i scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:0 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, CarlislE PA, to enforce the court judgment of $189,325.92, obtained by Plaintil above (the mortgagee) against you. If the sale is postponed, tJ 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 canceled if you pay to the charges, costs and reasonable attorney's fees. you may call, (856) -669-5400, mortgagee the back payment, ] To find out how much you must l 2, You may be able to stop the sale by filing a petition asking the Court to st or open the judgment, if the judgment was improperly entered. You may also 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 {See notice on page two 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 856-669-5400, 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, FA 17013 717-249-3166 or 800-990-9108 t~-' ,. J ( c:.. ~.. -:-; (- ~\ -"- --.,~- UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit 'B". All Notices were served within 3129. This Affidavit is made subject to relating to unsworn falsification Dated: November 18, 2004 BY: Mark J. Udren, Esquire h by Pa Rule C.P. Section 4904 , P.C. 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) DATE: October 12, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER (S): Ronald Johnson aka Ronald L. Jolulson Catherine Johnson aka Catherine IJ. Johnson PROPERTY: 23 Wheatfield Drive Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff I s Sale on December 8, 2004, at 10: 00 A.M., at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. 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Wells Fargo Bank Minnesota, National In The Court of Common Pleas of Association f/k/a Norwest Bank Minnesota Cumberland COlmty, Pennsylvania National Association, as Trustee for SASCOWrit No. 2001-4559 Civil Term Mortgage Loan Trust 1999- BC-4 VS Ronald Johnson alkJa Ronald L. Johnson and Catherine Johnson alkJa Cathy L. Johnson Valerie Weary, Deputy Sheriff, who being duly swom according to law, states that on September 17, 2004 at 4:24 o'clock PM, she served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: RonaldJohnsona/kla Ronald L. Johnson and Catherine Johnson alkJa Cathy L. Johnson, by making known unto Ronald Johnson, personally and husband of Catherine Johnson, at 23 Wheatfield Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2004 at 1 :00 0' clock P.M., he posted a tIue copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson a/kIa Ronald L. Johnson and Catherine Johnson a/kIa Cathy L. Johnson located at 23 Wheatfield Drive, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly swom 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 defendants, to wit: Ronald Johnson a/kIa Ronald L. Johnson and Catherine Johnson a/kIa Cathy L. Johnson, by regular mail to their last known address of 23 Wheatfield Drive, Carlisle, P A 17013. These letters were mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. This _ day of So Answers: ;~~~cr.t: ~ ~..tei. ~ R. Thomas Kline, ~heriff By0orJ"J~~ Re~:puty Swom and subscribed to before me 2004, A.D. Prothonotary ~"F, ~ :;:>"'(~ ~~ ~-;-,) '. (") f"'.,:) 0 = s; = II .r- ~-,.... z :I!:o c) t', , 1'1'1, ' i c> -;>. , ...c: 1"11 p_ ...=-:" , N -'0 en -')5:' ~) '-'> 6 r..: _,~C) ,,~. ,... ..,..; ~lk; -0 _'--1'1 ::J~ ',,,~('5 N om --I ~ .. '1". c.n :;:-J 0"\ -< 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Carlisle, PA Drive 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Ronald L. Johnson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on November 12, 2005 Bankruptcy Case No. 04-bk-06765. Mark J. Udren, Esquire 0126812 UD EN LAW OFFICES, P.C. At rney for Plaintiff ~ At>. ~ ~> ~v ~ r:;? oJ'. /' - ----- Wells Fargo Bank Minnesota, National In The Court of Common Pleas of Association flk/a Norwest Bank Minnesota Cumberland County, Pennsylvania National Association, as Trustee for SASCO Writ No. 2001-4559 Civil Term Mortgage Loan Trust 1999-BC-4 VS Ronald Johnson alk/a Ronald L. Johnson and Catherine Johnson alk/a Cathy L. Johnson Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on September 17,2004 at 4:24 o'clock PM, she served a true copy of the within Re I Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Ronald Johnson alk/a Ronald L, Johnson and Catherine Johnson alk/a Cathy L. Johnson, by making known unto Ronald Johnson, personally and husband of Catherine Johnson, at 23 Wheatfield Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2004 at 1:00 o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson alk/a Ronald L. Johnson and Catherine Johnson alk/a Cath L. Johnson located at 23 Wheatfield Drive, Carlisle, 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 defendants, to wit: Ronald Johnson alk/a Ronald L. Johnson and Catherine Johnson aI a Cathy L. John50n, by regular mail to their last known address of23 Wheatfield Drive, Carlisle, PAl 701 3. The5e letters were mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, states this it is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs: Docketing 30.00 Poundage 14.96 Posting Bills 15.00 Advertising 15,00 Prothonotary 1.00 Mileage 8.88 Levy 15.00 Surcharge 30,00 \{ " / Y'i 4 'DqJI La.... l&t/'6' Law Journal Patriot News Share of Bills 309.43 293.30 30.42 $762.99 Sworn and subscribed to before me 2005, A. ;:J}2:.s~J~~ R. Thomas Kline, Sheriff BY 0tc.L~~~t11 Real Estate eputy , ,; 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 P INTIFF , Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA Norw st Bank Minnesota, National Association, as Trustee for SASCO Mort ge Loan Trust, 1999-BC4, 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 he real property located at: 23 Wheatfield Drive, Carlisle, PA 17013 I. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # I ABOVE 3. Name and lien on the Name address of every judgment creditor real property to be sold: Address whose judgment i a record None , 4. Name and address of the last recorded holder of every mor gage of record: Name Address plaintiff herein. . See Caption above. Citifinancial, Inc. I Valley Street, Suite 103 Carlisle, PA 17013 Wells Fargo Bank National Association P.O. Box 57038 Irvine, CA 92619-7038 5. Name and address of every other person who has any record lie on the property: Name Address None 6. Name and address of the property and whose Name every other person who has any record int interest may be affected by the sale: Address rest in Real Estate Tax Dept. I 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. 28094 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plain iff has in the property which may be aff cted by Address Tenants/Occupants 23 Wheatfield Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and bel' ef . I understand that false statements herein are made subject to the p nalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to aut rities. UDREN LAW OFFICES, P,C. DATED: June 30, 2004 . ,~ ATTORNEY FOR P AINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson NO. 01-4559 civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NOTICE OF SHERIFF S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA scheduled to be sold at the Sheriff's Sale on December 8, 2004, A.M, in the Commissioners Hearing Room, 2nd Floor, Courthouse, PA, to enforce the court judgment of $189,325.92, obtained by above (the mortgagee) against you. If the sale is postp 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 canceled if you pay to the charges, costs and reasonable attorneyls fees. you may call: (856) -669-5400, mortgagee the back pa To find out how much yo 17013 is at IO:OO arlisle, laintiff ed, the ent, late must pay, 2. You may be able to stop the sale by filing a petition asking the Cour to strike or open the judgment, if the judgment was improperly entered. You m y also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceeding You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you conta t one, the (See notice on page two on how r , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHE EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. RIGHTS 1, If the Sheriff's Sale is not stopped, your property will be s ld to the highest bidder. You may find out tne price bid by calling 856-669-5400, 2. You may be able to petition the Court to set aside the sale if th bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the Sheriff the f II amount due in the sale, To find out if this has happened, you may call 856-669-54 0, 4. If the amount due from the Buyer is not paid to the Sheriff, you w'll remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amo t due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for y ur house. A schedule of distribution of the money bid for your house will be filed by t e Sheriff within 30 days after the sale, This schedule will state who will be rece'ving that money. The money will be paid out in accordance with this schedule unless xceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff ithin 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 WHE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 I" . 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 P AINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson NO. OI-4559 civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NOTICE OF SHERIFF S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA scheduled to be sold at the Sheriff's Sale on December 8, 2004, A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, PA, to enforce the court judgment of $189,325,92, obtained by above (the mortgagee) against you. If the sale is postp property will be relisted for the Next Available Sale. 17013 is at 10:OO arlisle, laintiff ned, the NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffrs Sale, you must take immediate action: 1, The sale will be cancelled if you pay to the charges, costs and reasonable attorney1s fees. you may call, (856) 669-5400, mortgagee the To find out how much y to strike y also ask 2. You may be able to stop the sale by filing a petition asking the COll or open the judgment, if the judgment was improperly entered. You the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceeding 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 cont ct one, the (See notice on pag two on how , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHE EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. RIGHTS 1, If the Sheriff's Sale i.s not stopped, your property will be so d 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 id 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 fu 1 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 wi 1 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 amou paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, may bring legal proceedings to evict you. due is e buyer 6. You may be entitled to a share of the money which was paid for you 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 receiv ng that money. The money will be paid out in accordance with this schedule unless ex eptions (reasons why the proposed distribution is wrong) are filed with the Sheriff wi hin ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting y ur 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 ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 , ~.,. , . ALL THOS2 CEl/.TAIN, PI2CE Oll. P AllCBL OJ!' I.Al'lD SI'l't1ATE m HIDDLESU TOWl!lSRIl', C1JMElJmLA1iIl COllllTY. PEltNsn.VAltIA. DOWN AS LOT #3~, AS DESClUlIED m- ACCORDANCE WITH SUBDIVISION PLAN OF THE !!lUoD'OWS. PLAN #2, BY ~ONALD S. RAl!'l!'BNSPB1I.GB1I.. REGJ:S SURVEYOR. DATED SEPTmmEll. ~8, ~986. A:IID RECOl!DED IN ctnmJmLA1iIl COURTY PLAN BO It 52, PAGE -142, JroRE PAll.TI~Y 1l0UllDED A:IID DBSClUBED AS J!'OLLOWS TO nT: BEGINNING AT A POINT ON 'nIE EASTEll.N RIGHT-OF -WAY LDm OF WHBATFrm.o DRIVE. POINT lllUNG RBFEll.ANcED AND LOCATED ~55. DD J!'Erl' SOtlT.ll: OF 'nIE INTERS2CTION OJ!' EASTEll.N RIGHT-OF-WAY r.nm OF WEEATF:IELD DRIVE A:IID T:B:B SOlJTllElm RIGHT-OF-WAY OF w;tIJJ ROSE C:IRCLE; TlD!:NCE ALONG LOT NO. 30 NORTH 85 DEGlU:BS 25 l!1.u>IuuS BAST A . DISTANCE OF ~57.27 FEET TO A POJ:N'1' AT LOT NO. ',32; THENCE ALONG LOT NO. 32 SO 4 DEGREES 35 MJ:Nl1':I:ES BAS'l' A DISTANCE OF ~50.00 FEET TO A PO:t1l'T A'l' THE NOW NOR I"~ UGHT-OF-WAY t.:I1I'E OF WREATFIELD DRIVE; TlD!:NCE ALONG SArD lUGHT-OJ!'-WAY A:IID A TO = lUGHT 1lAVl:NG A RAD:tUS OF ~50 100 FEET AN AllC LENGTH OF 235.51 FEET TO A POINT, THE PLACE OF llEG=G. CON'l'AJ:1I'DlG ~ 7. 67~ SQtrA1l.B FEET. KOll.B OR LESS. BEING KNOWN AS: PROPERTY ID NO. : 23 WHEATFIELD DRIVE, CARLISLE, PA 17013 21-05-0433-090 TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CAT JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETY BY DEED CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE OS/27/99 RECORDED 06/17/99 IN DEED BOOK 201 PAGE 979. L. FROM ATED WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, FKA NORWEST BANK MINNESOTA NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, I999-BC4, Plaintiff (s) From RONALD JOHNSON AlKJA RONALD L JOHNSON, CATHERINE JOHNSON AlKJA CATHY L. JOHNSON, (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 fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defenda (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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 LL Interest FROM 9/5/01 TO DATE OF SALE 12/8/04 - PER DIEM@ $44.58 - $53,094.78 Atty's Corum % Due Prothy $1.00 Atty Paid $420.30 Plaintiff Paid Date: JULY 20, 2004 Other Costs CURTIS R. LONG (Seal) By: 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 Real Estate Sale #16 On August 27,2004 the Sherifflevied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, P A Known and numbered as 23 Wheatfield Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 27,2004 By:~4~-~ Real Esta~ De;u~y , r ....=) c:;:;:;l c:;:;;l ~ GfE) liV\1 '1," ': ,1,1), S H N3d . , ."1 f' L ,'1 c "I \ 7 l~! ,-.oJ L v \ AI ~ ..i\;> " : ,~; 1':".1U REAL ESTATE SALE No. 16 Writ No. 2001-4559 Civil TllI'ii1 Wells FIIIlID Bank MinneSota, NatIonal Association f/kJa ' Norwest Bank Mh1nes0t8, National AssocIatIOn. as Trull1ee for SASCO Mortgage . Loan1iu&t 1999-T1c-4 " ~ . , Ronald JohnsOn , aJlds Ronald"L Johnson and Cattierlns Johnson aJlda Cathr L Johnson . Ally: M8rk Udren DESCRIP110N ,-t ".;.......-..",. ';,.........:.....-,.,..<...'".,.. , :UL,~OSEMi'~ ~.~ ~ oflandland "Sltuate 1D' ,uw_p, uuu~ County, Pennsylvania, known" as Lot 11)1, as described jn acconIance with subdivision l'bm of the Meadows, Plan, iI2," by Ronald S. RaffenSpeIgef, " Registered Surveyor, "' dated september 1S, 1986; and reconleiI in Combedand Coonti Plan Book 52, Page 142, more ~y boonded and describe<! as follows In Wit: .'...' "'_.' _.w '~'~ ,-_,:,,:,>",-,,";:,:\,,'-"',- BEGINNING at a point on the eastern right-of- way lliJe of Wbeatfield Drive, said point being referenced and locat<d 155.00 feet south of the inte1iectilBl of the eastern, iigbt-9f- line of Wbeatfield Drive and the soothem ~-of-way line of Wild Rnse Circle; 1hem:e'.alting Lot No" 30 north 85"dq:rees 25 minutes ease a distance of 15717 feetln a point at Lot No. 32;'thence along Lot No, 32 south 4 degrees 35 JIIinutes east a distance of 150,00 feet In a point 01 the now northern right-of-way:line of Wheatfield Drive; thence along said righI-of-way and a curve In the right having a radius of 150,00 feet an arc length of 235.61 feet In ,a point, the place of BEGINNING, ' CONTAINING 17,011 sqoare feet, more or less, BFJNG KNOWN AS: 23 Wbeatfield Drive, CilI!isJe,PA 17013. PROPERlY ID #21-05-0433-090. 'lTILE 10 SAID PREMISES is vested in Ronald L. JoImson and Cathy: L. Johnson, husband and wife. as tenants by the eotirety by deed from Charles T, Watkins and Vrrginia Ie- Watkins, husband and wife. dated OSfl71'JiJ reconIedll6l17l99inDeedBook201 Page 979, . REAL ESTATE SALE NO. 16 Wrtt No. 2001-4559 Civil Wells Fargo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust 1999-BC-4 V" Ronald Johnson, a/k/a Ronald L. Johnson and Cathertne Johnson, a/k/a Cathy L. Johnson Atty.: Mark Udren ALL THOSE CERTAIN piece or parcel of land situate in Middlesex Township, Cumberland County, Pennsylvania, known as Lot #31, as descrtbed in accordance with Sub- d1v1slon Plan of The Meadows, Plan #2, by Ronald S. Raffensperger, Registered Surveyor, dated Septem- ber 18, 1986, and recorded in Cum- berland County Plan Book 52, Page 142, more particularly bounded and descrtbed as follows to wit: BEGINNING at a point on the eastern right-of-way line of Wheat- field Drive, said point being refer- anced and located 155.00 feet South of the intersection of the eastern right-of-way line of Wheatfie1d Drive and the southern right-of-way line of Wild Rose Circle: thence along Lot No. 30 North 85 degrees 25 minutes East a distance of 157.27 feet to a point at Lot No. 32: thence along Lot No. 32 South 4 degrees 35 minutes East a distance of 150- .00 feet to a point at the now north- ern right-of-way line of Wheatfield Drive; thence along said right-of-way and a curve to the rtght having a radius of 150.00 feet an arc length of 235.61 feet to a point, the place of beginning. CONTAINING 17,671 square feet more or less. BEING KNOWN AS: 23 Wheat. field Drive, Carlisle, PA 17013. PROPERlY ID NO.: 21-05-0433- 090. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Johnson and Cathy L. Johnson, husband and wife, as tenants by the entirety by Deed from Charles T. Watldns and Virginia K. Watldns, husband and wife dated OS/27/99 recorded 06/ 17/99 in Deed Book 201 page 979. 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/KIA Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189.325.92 Interest From 9/5/01 77.435.46 to Date of Sale June 7. 2006 Ongoing Per Diem of $44.58 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. \~ " /\ /\ Vark J. UdJ\s:zl, IiEUIRE ATTORN Y FOR PL TIFF ~ ~ r ~ ~ r ~ ?- :r hf V) R , (J ~ t~ C> ~ ~ 0 \J-) \"'" 0 l..l .c:. ~ -.c:::. -..r::. --.. -- ........ -:! - .J;) - J:: Ii"" ).J .t -- ..... "'9 Vl lr1 -ClV\ 1.J .- 111. )..> C- O 0 B II') -0 ...0 ..0 ...{) c-()O (;;-0 V'l U1 \ \ \ , \ \ I \ , - - - , - ~ ~ - ~ - - - - - - " - - - - - - - - - - - - - - -w::: ~ - Irt 0- ..0 \) C ~ () \ D-J - () p.- ':1..:b -~ ----- ,-:' ~. ' ,--.,'"' '.--' - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, 1999-BC4, Plaintiff (s) From RONALD JOHNSON A/K/A RONALD L. JOHNSON AND CATHERINE JOHNSON A/K/A CATHY L. JOHNSON (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 LL Interest FROM 9/5/01 TO DATE OF SALE 6/7/06 - ONGOING PER DIEM OF $44.58 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $77,435.46 Atty's Comm % Due Prothy $1.00 Atty Paid $1,198.29 Plaintiff Paid Date: JANUARY 24, 2006 Other Costs ,Q~1 (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 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA INRE: Ronald L. Johnson Cathy Johnson, De btor( s) i CHAPTER 13 I CASE NO. ] .04.bl.06765 MDF Option One Mortgage Corporation, Movant, vs, Ronald L. Johnson Cathy Johnson, Charles 1. DeHart III, Trustee Respondent(s), ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY Upon consideration of the motion of Option One Mortgage Corporation for Relief from the Automatic Stay, it is hereby ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided under 11 U,S,C, 9362, is modified with respect to premises: 23 Wheatfield Drive, Carlisle, P A 17013 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; and it is further ORDERED THAT: 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, By IlIe COW'1. This electronic order is signed and filed on the same date, Dated: December 22, 2005 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. ... r 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #l 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. Citifinancial, Inc. I Valley Street, Suite 103 Carlisle, PA 17013 5. Name and address the property: Name of every other person who has any record lien on Address None 6. Name and address in the property and Name of every other person whose interest may be Address who has any record interest affected by the sale: Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 2S1230 Harrisburg, PA 1712S-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 23 Wheatfield Drive Carlisle, PA 17013 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 IS Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: January 23, 2006 . ~.. ,_-:-' -, . 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffls Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the 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 the more chance you will have of stopping the sale. how to obtain an attorney.) sooner you contact one, (See notice on page two on ..... . 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 paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 --.--- -- ( .~~ - L 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:OO A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 attorneyls 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 the more chance you will have of stopping the sale. how to obtain an attorney.) sooner you contact one, (See notice on page two on I '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 untiJ paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 , <-' :~-;- 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON P EAS CIVIL DIVISION Cumberland County v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF NO. 01-4559 Civil Term AFFIDAVIT OF SERVICE PORSOANT TO Pa.R.C. .ROLE 3129.1 Plaintiff, by its/hiS/her Attorney, Mark J. Udren, Esquire, hereby verifies that: l. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent t every recorded lienholder and everr other interested party known as of the date of the filing of the Praec~pe for the Writ of Execution, 0 the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defenda and certified mail on the date appearing on the att which was signed for by Defendant(s) on the date sp Return Receipt. Copies of the said Notice and Retu hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, th personal service on the date specified on the attac attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof 0 Order is attached hereto as Exhibit "B". t(s) by regular mail ched Return Receipt, cified on the said n Receipt are attached n service was by ed Return of Service, compliance with said All Notices were served within the time limits set forth by Pa Rule C.P. 3l29. This Affidavit is made subject to the p relating to unsworn falsification to au Dated: May 19, 2006 BY: 4904 . UDREN LAW OFFICES, P.C. BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SOITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff TTORNEY FOR PLAINTIFF COURT OF COMMO PLEAS CIVIL DIVISION Cumberland Cou ty NO. 01-4559 Ci il Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) DATE: January 23, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson PROPERTY: 23 Wheatfield Drive, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be s ld at the Cumberland County Sheriff's Sale on June 7, 2006, at Commissioners Hearing Room, 2nd Floor, Courthous records indicate that you may hold a mortgage or ju which will be extinguished by the sale. You may w to protect your interests. 10:00 A.M., at the , Carlisle, PA. Our gment on the property sh to attend the sale A Schedule of Distribution will be filed by t e Sheriff on a date specified by the Sheriff not later that 30 days aft r sale. Distribution will be made in accordance with the schedule unles exceptions are filed thereto within 10 days after the filing of the sc edule. EXHIBIT A t;:;il IT" , \ 'Ir.\\\\ "', II I \ (" 1-1 ~ \-~\\i\D!\, ~i' \ I ,-1 I I 1 .( I ,~,~w ~, \ 1" ,- - , -hll~\, '.1 'j J- f' _-\ 1'1 'I h\li\W, ' · 1~1 -I-+-, ,-r I 1, f I I tJ\i'i' lh Ir;s 1 J -+ I \ \ \ \lt~JI\ !r. 1"" I 1 I \ \ ~ 111ft\1 \ 1 b.t lJn\~ I I 1 _I -+ +-\ I I _I " ,_I~\ti\a\\ i in. ~-, I I. I , , I 1 -,ptl' 3 ,IU I \ 1 -r---r---o I \ I _ i_jldl . li!l ~ n~~w;~~ ~\ ~ '> ~ i\\ lM'". .Jr\ '~ ~ I II \ I I \ \ Ii ~/ D~ i is ~ II!-i'>~ ~ I \ \ " --1 - fi -. g ~i-~ii ~ I \ I \ I \ 1 ~l-_" z II ~!!i i~ Iii 1?Ii \ I I I ~1~) .~i qi\~li! ,~I 1 1 I Ii _\! i\!i ~. i'\\li~~tl \ 1 , I~! _\ i ~~I;f i Ulllllh~ ~~l:i, I r' ..... -I ft ~~Ii. UiqtaftiU\ \ 1 \-:\ i . !;'i ' \\~I ~ ~bl! z ,;.,S · -" - r i i I I ~'i ~ · \ b I '" I! J" . , ~ L---, · f'l~ \! ~ 1 · -. . ~ l' .";"BITA <( z l5 .10 1'" ,'" 'I .. 1 ii .:?- ~ lot \~ co ~ !!o 5 r .L'" , . . . Wells Fargo Bank Minnesota, National Association flk/a Norwest Bank Minnesota National Association as Trustee for SASCO Mortgage Loan Trust VS Ronald Johnson alk/a Ronald 1. Johnson and Catherine Johnson alk/a Cathy 1. Johnson In the Court of C mmon Pleas of Cumberland Co ty, Pennsylvania Writ No. 2001-4559 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn acco ing to law, states that on March 14, 2006 at 2:45 o'clock PM, he served a true copy of the with n Real Estate Writ, Notice and Description, in the above entitled action, upon the within named efendants, to wit: Ronald Johnson alk/a Ronald 1. Johnson and Catherine Johnson, alk/a Cathy . Johnson, by making known unto Ronald Johnson, personally and husband of Catherine 1. ohnson alk/a Cathy 1. Johnson, at 23 Wheatfield Drive, Carlisle, Cumberland County, Penn ylvania, its contents and at the same time handing to him personally the said true and correct cop of the same. William Cline, Deputy Sheriff, who being duly sworn accordi g to law, states that on April 04, 2006 at 5: II o'clock P.M., he posted a true copy of the with n Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the propert of Ronald Johnson and Catherine Johnson located at 23 Wheatfield Drive, Carlisle, Pennsylv ia, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to aw, states he served the above Real Estate Writ, Notice, Poster and Description in the followi g manner: The Sheriff mailed a notice of the pendency of the action to the within named defi ndants, to wit: Ronald Johnson and Catherine Johnson by regular mail to their last known ad ess of23 Wheatfield Drive, Carlisle, PA 17013. These letters were mailed under the date f April 03, 2006 and never returned to the Sheriff's Office. Sworn and subscribed to before me This _ day of So Answers: R.~~,S~ :;d'-., - Prothonotary B~_~ Real Estate Sergeant 2006, A.D. XHIBIT B < . (') ~ 0 t;~ ,:;:::3 -fl ,,~ 7:$. ~..,., ":;.00 -" PlF:': '-" ~nt3 ~;1 - {-)L ::;:,{i......' .,,..' -" ~ ;.';r:U - ':-yC) q Om _-, ..,.. ~ 1'> COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Wells Fargo Bank N A Tr is the grantee the same having been sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 24th day of Jan, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 4559, at the suit of Wells Fargo bank Minnesota N A Tr against Ronald Johnson aka Ronald L & Catherine aka Cathy L is duly recorded in Deed Book No. 276, Page 4441. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~1 day of ,~ , A.D. ;Le) 0 <0 ~~. ~, ~ ~rderofDeeds RIcoIdIt' of Deeda, Cumbet1and CoIIlty. CId8II. PA ~ Ctll";liIiIarI Elqlil8IIle FiIIl MoIldIy 01_1010 , Wells Fargo Bank Minnesota, National Association flk/a Norwest Bank Minnesota National Association as Trustee for SASCO Mortgage Loan Trust VS Ronald Johnson aIkIa Ronald L. Johnson and Catherine Johnson aIkIa Cathy L. Johnson In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4559 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 14,2006 at 2:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Ronald Johnson aIkIa Ronald L. Johnson and Catherine Johnson, aIkIa Cathy L. Johnson, by making known unto Ronald Johnson, personally and husband of Catherine L. Johnson aIkIa Cathy L. Johnson, at 23 Wheatfie1d Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy ofthe same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 04, 2006 at 5:11 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson and Catherine Johnson located at 23 Wheatfield Drive, Carlisle, 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 defendants, to wit: Ronald Johnson and Catherine Johnson by regular mail to their last known address of23 Wheatfield Drive, Carlisle, P A 17013. These letters were mailed under the date of April 03, 2006 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 June 7, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren for Wells Fargo Bank N.A., as Trustee for Structures Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC-4. It being the highest bid and best price received for the same, Wells Fargo Bank: N.A., as Trustee for Structures Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass- Through Certificates, Series 1999-BC-4 of P.O. Box 57038, Irvine, CA 92619, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$1,018.33. Sheriffs Costs: Docketing Poundage Posting Bills Advertising $30.00 19.96 15.00 15.00 ,. Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed S~:~~ ~ ,~ ~ ~ R. Thomas Kline, Sheriff -i~ 30.00 10.00 .50 1.00 12.32 9.28 15.00 30.00 377.00 369.20 19.57 25.00 39.50 n $1,018.33 I 16f6(.//j~ ~ ~ 3D- /tV I ~l) , U<.. ~S 73(, ,Zv, If39['1 ." ) . . 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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 .1' I 4. Name and adaress of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancialt Inc. l Valley Streett Suite 103 Carlislet PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlislet PA 17013 Domestic Relations Section 13 N. Hanover Street Carlislet PA 17013 Commonwealth of PAt Department of Revenue Bureau of Compliancet PO Box 281230 Harrisburgt 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 23 Wheatfield Drive Carlislet PA 17013 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 OFFICESt P.C. DATED: January 23, 2006 f ,~/\ f\ Mar!i J. ~nt\ t~, ~orney or PlIai if r UDREN LAW'OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01~4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 ~ediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 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 Lawyer Referral Service cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 .#' , 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant{s) NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) -669- 5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ , YOU MAY STILL BE ABLE TO SAVE .YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped,' your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ..- .-_.. .~'."~-.'~~ '.~.- ALL 'l'JiOSE CEltTA:t1i,. P:r:ECE OR. PAltCELOF LAND SrrtIATE:m H:r:DDLESEX 'l'01mSmP I cmmElU.A:RD COtmTY, P~S'ILV.urn, DOWN AS LOT #:31, AS DESClUmm :m-ACCOlUJAl'lCE wrrx smmmSJ:ON PLAN OF TEE MEAI)"OWS, PLAN #2, BY ~ S. ltAFFEliSPD.GD., UGJ:STERED S1J:R.VEYOR, DA'l'ED SEP'l'EHBD. 18, ~986, AmJ RECORDED m CtlHl31l!'RT.:A'Im CotmTY PI..A!1' BOOK 52, PAGE -142, HO:i.E PART:r:Ct7LAlU.Y BOmmED AmJ DESClUBED AS FOLLOWS TO w:r:T: BEG:I:NliDiG AT A PO::c:rr ON TEE EASTElUf RJ:GRT-OF -WAY LINE OF WEEATF:I:ELD DlU"VE, SAJ:D POrN"l' BEmG ~ ABD LOCATED ~S5. 00 FEET SOlJ"l'R OF Tm!: J:J!ITERSEC"l':r:Olr OF 'mE EASTElUf,1U:GR'l'-OF-WA,Y LnlE OF WlmAT!'IELD D:i.IVE ABD nm SOtl"J:':HElUi 1U:Gl!T-OF-W,Ay LmE OF w.J:LD ROSE C:r:RCLE; TRENCE ALONG LOT NO. 30 NORTH 85 DEGXEES 25 Il!llztU:J:~ EAST A . D:r:STANCE OF 157.27 FEET '1'0 A PODlT AT LOT NO. .32; TIlENCE ALONG LOT :HO. 32 SOUTB: 4 , DEGREES :35 HniDTES EAST A DIS'I'AllCE OF ~50. 00 FEET TO A PODlT AT '.I"RE NOW B'ORTRElUf \\. lUGRT-OF-WAY LINE OF WHEATF:r:ELD DRIVE; TBER'CE ALONG SAJ:D lUGlrl'-OF-WAY .A1m A Cllltn TO '!'XE lUGR'l" B:AVDlG A RADIUS OF 150'l,oO FEET A:N ARC LENGTR OF 2:35.6~ FEET TO A. POrN"l', THE PLACE OF BEGnm:olG. CONTAI:ND1'G ~7, 671 SQO'All.E FEET, HORE OR LESS. BE ING KNOWN AS: 23 WHEATFIELD DRIVE, CARLISLE, PA 17013 PROPERTY ID NO. : 21-05-0433-090 TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L. JOHNSON I HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETY BY DEED FROM CHARLES T. WJ:..TKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED OS/27/99 RECORDED 06/17/99 IN DEED BOOK 201 PAGE 979. WRIT OF EXECUTiON and/or ATTACHMENT . COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, 1999-BC4, Plaintiff (s) From RONALD JOHNSON AlKlA RONALD L. JOHNSON AND CATHERINE JOHNSON AlKlA CATHY L. JOHNSON (l) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S} as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s} is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest FROM 9/5/01 TO DATE OF SALE 6/7/06 - ONGOING PER DIEM OF $44.58 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $77,435.46 Atty's Comm % Due Prothy $1.00 Atty Paid $1,198.29 Other Costs Plaintiff Paid (Seal) ~~ By: Date: JANUARY 24, 2006 Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court In No. 04302 Real Estate Sale # 05 On February 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, P A Known and numbered as 23 Wheatfield Dr., Carlisle, more fully described on Exhibit" A" Date: February 03, 2006 By: J~cLc( ~tt, Real Estate Sergeant ~ ~ ~ ~ filed with this writ and by this reference incorporated herein. ES:I d QZ NVr qOOl V'd 'J..INi10J Ot{Q' -ltJ38~nJ .:bIlH3HS 3Hl :.10331.:1.:10 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA SSe 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 10qal courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7, 14,21,2006 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. SWORN TO AND SUBSC ED before me this 21 day of April. 2006 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle 8oro, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 5 Writ No. 2001-4559 Civil Wells Fargo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota National Association, as Trustee for SASCO Mortgage Loan Trust vs. Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson Atty.: Mark Udren ALL THOSE CERTAIN, piece or parcel of land situate in Middlesex Township, Cumberland County, Pennsylvania, known as Lot #31, as described in accordance with subdMsion plan of The Meadows, Plan #2. by Ronald S. Raffensperger. Registered Surveyor, dated Septem- ber 18, 1986, and recorded in Cumberland County Plan Book 52, Page 142. more particularly bounded and described as follows to wit: BEGINNING at a point on the eastern right-of-way line of Wheatfield Drive. said point being referenced and located 155.00 feet south of the intersection of the east- ern right-of-way line of Wheatfield Drive and the southern right-of-way line of Wild Rose Circle; Thence along Lot No. 30 North 85 degrees 25 minutes East a distance of 157.27 feet to a point at Lot No. 32; Thence along Lot No. 32 South 4 degrees 35 minutes East a dis- tance of 150.00 feet to a point at the now northern right-of-way line of Wheatfield Drive; Thence along said right-of-way and a curve to the right having a radius of 150.00 feet an arc length of 235.61 feet to a point. the place of beginning. CONTAINING 17.671 SgUARE FEET, MORE OR LESS. BEING KNOWN AS: 23 WHEATFIELD DRIVE, CARLISLE, PA 17013. PROPER1Y ID NO.: 21-05-0433- 090. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Johnson and Cathy L. Johnson, husband and wife, as tenants by the entirety by Deed from Charles T. Watkins and Virginia K. Watkins, husband and wife dated OS/27/99 recorded 06/ 17/99 in Deed Book 201 Page 979. , , .. ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The 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 heteto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. 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 pursuantl to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Oompany and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #5 Sworn to and sub ~ NOT Y PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COuNTY COURTHOUSE CARLISLE, PA. 17013 ~~