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Home My WebLink About03-0398MARK 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 Wachovia Bank, National' :COURT OF COMMON PLEAS Association, formerly known as : CIVIL DIVISION ATTORNEY FOR PLAINTIFF Vo Deedra K. Keck 141 Fern Avenue Carlisle, PA 17013 Defendant(s) First Union National Bank, as : trustee by: Saxon Mortgage ]Cumberland County Services, Inc. f/k/a Meritech Mortgage Services, Inc. their : attorney-in-fact : 1270 Northland Drive : Suite 200 Mendota Heights, MN 55120 : Plaintiff : COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy ora judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /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: New Century Mortgage Corporation Assignments of Record to: Wachovia Bank, National Association, formerly known as First Union National Bank, as trustee by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services, Inc their attorney-in-fact · 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 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 141 Fern Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: North Middletown Township COUNTY: Cumberland DATE EXECUTED: 7/19/01 DATE RECORDED: 7/31/01 BOOK: 1729 PAGE: 938 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: 5. After demand, the Defendant(s) continues to fail refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments (b) 6 o 1/24/03: or of principal and interest when due in the amounts indicated below; by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 12.25% from 8/01/02 to 1/24/03 (the per diem interest accruing on this debt is $14.92 and that sum should be added each day after 1/24/03) Title Report Court Costs (anticipated, excluding Sheriff,s Sale costs) Late Charges (monthly late charge of $27.37 should 5e added in accordance with the terms of the note each month after 1/24/03) Other Fees Pir Inspection Attorneys Fees (anticipated and actual to 5% of principal) 2,192.13 TOTAL $49,476.07 7. The attorney,s fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner,s Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in $43,842.64 2,580.92 250.00 280.00 109.48 205.00 15.90 accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $49,476.07 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark/J. Udren, ESQUIRE MARK/J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE NORTH MIDDLETOWN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED A1TD DESCRIBED AS FOLLOWS: ~ ..... BEGINNING AT AN IRON PIN ON THE NORTHEP. N LINE OF FEP, N AVENUE AT LINE OF LAND NOW OR .FORMERLY OF JOHN BARRICK, OR., SAID IRON PIN BEING SOUTH 73 DEGI~EES 7 MINUTES 37 SECONDs EAST 134.98 FEET TO THE NORTHWEST CORi~ER OF AEI~ONCA STREET, THENCE BY THE NORTHEI~N LINE OF. FERE AVENuii, NORTH 72 DEGREES 45 MINUTEs 15 SECONDS WEST 24.56 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF DAVID L. SHELLER, NORTH 12 DEGREES 27 MINUTES EAST 82.80 FEET TO AN IRON PIPE; THENCE BY SAME, SOUTH 76 DEGREES 53 MINUTES 14 SECONDS EAST 19.5.40 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLy OF JOEN BAP. RICK, OR., SOUTH 19 DEGREES 6 MINUTEs 37 SECONDS EAST 119.05 FEET TO AN IRON PIN ON THE NORTH SIDE OF FEHN AVEI~u=, THE PLACE OF BEGINNING. CONTAINING 19,591.38 SQUARE FEET. .iL November 7, 2002 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE to help tn anve .vm~r hnme. Thin Notice explains how the pro?am wnrk.s. Tn nee ifHEMAP can heln. you muat ~F,T ~TH A CON~II~,R CRE~i.i, thi~ Notice ~th you when you meet ~th the Cnun~ellnE AEency' hearin~ cnn cnll (717) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. ' LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIE~O EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION NMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERo MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A' REDIMIR SU HIPOTECA. Page 1 of I HOMEOVv3VER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Deedra K. Keck Je ffr_ex_K_e__c_k_ 141 Fern Avenue __C_a_rHsl_e_,_PAJ 7013 901_13737 New Ce_n_tg~_ry Mo__~g~ge C0_rgoration __ __D~eut__sche_B_ank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RE EI,IGIRI,E FOR FINANCIAL A,q~I,~TANCE WHICH CAN ~qAVE ¥OITR HOME FROM FORECI,O~URE AND HEI,P VOU MAKE FUTURE MORTGAGE P~NTE IF YOU CO~LY ~TH T~ PRO~SIONS OF T~ HO~O~R'S - - ~-~RGE~~ ~RT~ ~I~VCE ACT OF ~ ~HE "~T'~, YOU-~Y BE ELIG~LE FOR E~RGEN~ MORTGAGE ASSIST~CE: 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. TEMPOR ARV STAV OF FORECI ,O~qIiRE '-- Under the ACt, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. 'THI~ MEETING MU,qT OCCUR WITHIN TI-rE NFJ(T (~0) DAV~. IF ¥OIT DO NOT APPI,Y FOR EMERGENCY MORTGAG~ AS~qTSTANCF,~ VOIT MIYRT RRING YOIIR MORTGAGE ITP TO DATE TI-W, PART OF 'I'HI~ NOTICE CALI,F,D "HOW TO CIIRF, ¥OIIR MORTGAGE, DEFAIII,T". FXPI,AIN~q HOW TO BRING ¥OIIR MORTGAGE IlP TO DATE ' CON,qlIMF,,R CREDIT COIIN,qEI,ING AGENCIE~ _ 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 &this meeting. The name.q; acldre.q~qe.q and telephone nnmher.s of desiLznated c',,on~l~lTler credit conn,qeling agencie,q for the county in which the i?i,,?erty i.q located are ~et forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPIJCATION FOR MORTGAGE A~q~qI~TANCE _ 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. Page 2 of 2 YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAll, TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME P~RIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. ' NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN t B ~A~R_~_U_P_T_CY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION .EURPOSESOIN-LY_AND SHOiii,I~ NOTBE CONSIDERED AS ANATIEMpIIo COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE ¥OIIR MORTGAGE DEFAIII~T .(BrinE it n? tn date), NATURE OF THE DI~,FAIILT .- The MORTGAGE debt held by the above lender on your property located at: 141 Fern Avenue 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: Monthly Pa_y~__~_n_ts of $5_47.3_4 for_Se_~p_tember__l~2_002_thr_ou_~gh November L~2002 = $!_6_4_2_~.2_.__ Mont_hl~ Late Ch_ar_ges of~27.37 for Se_l~._tember 1~2002 thro_ugh_ October 1, 2002 = $54.74 Other charges (explain/itemize): __O__th_e_r__F__ees ~.$_10_0.00 TOT__A~_. AMDUNT P.A_~T DUE: $1706.76_ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not me ifn,~t applicable): N/A HOW TO CURE THE DEFAIII~T _ 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 ~ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payment~ mu~t h~ made either hv each. ca~hier'~ cheek eert/fied check or money order made payahl~.~ and ~ent to: ' ' : Mark J. lldr~n & A~eiatex 1040 N. Kings Highway: ,qult~ ~flO Cherry. I-Iill: N.I f180~/I You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not uae if not applicable ): N/A Page 3 of 3 IF YOU DO NOT CURE THE DEFAIq,T __ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to e~ereige its rights to accelerate the mortgage debt, This means that the entire outstanding balance of this debt will be considered due inimediately'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 fnreclnge upon your mortgaged prnperty.. IF THE MORTGAGE lg FORECI,OSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the mount you owe the lender, which may also include other reasonable costs. If yin! cure the defmllt within .the THIRT~ (30~ DAY. nerlod, you will not ~,i- required to pay attorney's fees : . ' .... OTHER I,ENDER REMEDIE~ The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TI') CURE THE BEFAIII,T PRIOR TO SHERIFF'S gAI,E -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you grill have the fight to cure the default and prevent the gale at any time np to one hour before the Sheriff's Sale You may do go by paying the total amount then past dne~ phm any late or other charges then due. reaaonahle attorney's fees and coats connected with the foreclosure gale and any other cogt~q connected with the ShefifF'g Sale az specific, 1 in writing by the lender and by performing any other reqnirement~ under the mortgag,~ 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. EARl,FEaST POggIRI.F, gHF. RIFF,,g gAI,E DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of th'e Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment Or action will be by contacting the lender. HOW TO CONTACT THI~. I,ENBER: Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person: ._S__a~_on .M~o~g.a~e__S_e_rvice_s~ I_n_c_. .................. P.O. Box 161489 Fort Worth,_ _T_X_76161__-1489 __800-8_7__4-__9516 N/A _Cu s t o _m_e__r _S_e_r vic e EFFECT OF ,gHF. RIFF',g gA1,E - 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. AgSIIMPTION OF MORTGAGE _ You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements ofthemortgage are satisfied. Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we wilI 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 itto 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, orany disputed.portion of it~~ until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will.then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will beused 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 Page 5 of 5 YOII MAY AI,80 HAVE, THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAUL~T. (HO. WEVER,.YOU DO NOT HAVE THIS RIGHT TO CUR~ YOUR DEFAULT ~ MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTE~,ICE OF: A DEFAULT..IN-ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MQR~TGAGE 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. CON,qlYMER CREDIT COIINgEI,ING AGENCIE,q SERVING YOUR COIINT¥ CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 5414670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CIIMRERT,AND CO1)NTY Financial Counseling Services of Fran!din 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 :.-.'; ;'::;';' :.:-: '. .:.;...: ;:..' : OFF CIA . (:0qb o? ."~C) L USE Hem c~ C3 l Sent To ~. , , I CIty, Stale, X..IR+ 4 ~ t VERIFICATION Pa.C.S. Section authorities. 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 4904 re~lating to unsworn falsification to Ma / ~ MARKIJ. UDREN & ASSOCIATES 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 Wachovia Bank, National 'COURT OF COMMON PLEAS Association, formerly known as ' CIVIL DIVISION First Union National Bank, as trustee by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services, Inc. their attorney-in-fact 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF - Cumberland County NO. 03-398 Vo ' Deedra K. Keck 141 Fern Avenue ' Carlisle, PA 17013 - Defendant (s) . TO THE PROTHONOTARY: Please mark the above captioned matter SETTLED, DISCONTINUED and ENDED, upon payment of your costs only. Mark J. Udren, Es~u~'~e~ Mark J. Udren & Associates Attorney for Plaintiff Dated: SHERIFF'S RETURN - REGULAR CASE NO: 2003-00398 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WACHOVIA BANK NATIONAL ASSN VS KECK DEEDRA K KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KECK DEEDP~A K the DEFENDANT , at 1537:00 HOURS, on the 4th day of February , 2003 at 141 FERN AVENUE CARLISLE, PA 17013 by handing to DEEDP~A KECK a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this y~ day of 7 , A.D. -I IProGf~-enet~ry'" SO Answers: R. Thomas Kline 02/05/2003 MARK UDREN By: