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HomeMy WebLinkAbout03-1253MARK 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 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County V. Nathaniel Q. Wilkinson Tammy Wilkinson : NO. Cv ,Y 135 East Penn Street Carlisle, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 demands. y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 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 of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /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: N/A Assignments of Record to: N/A Recording Date: N/A 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: 135 East Penn Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 01/18/02 DATE RECORDED: 02/05/02 BOOK: 1748 PAGE: 1543 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 02/24/03: Principal of debt due $54,165.77 Unpaid Interest at 9.2% from 10/01/02 to 02/24/03 (the per diem interest accruing on this debt is $13.65 and that sum should be added each day after 02/24/03) 1,988.75 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $79.79 and that sum should be added on the first of each month after 02/24/03) (123.12) Late Charges (monthly late charge of $26.73 should be added in accordance with the terms of the note each month after 02/24/03) 187.11 Suspense Balance (106.54) Attorneys Fees (anticipated and actual to 5% of principal) 2,708.79 TOTAL $59,350.76 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant (s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $59,350.76 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, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL-THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON, ERECTED SITUATED IN THE BOROUGH OF CARLISLE,'CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY AN 18-FOOT.WIDE ALLEY; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KELLER'S HEIRS; ON THE SOUTH BY EAST PENN STREET; AND ON THE WEST BY PROPERTY NOW OF FORMERLY OF JAMES C. HOLMES, HAVING FRONTAGE OF 20 FEET ON EAST PENN STREET, AND EXTENDING IN DEPTH AT AN EVEN WIDTH OF 120 FEET TO THE ALLEY AFORESAID. BEING KNOWN AND DESIGNATED AT TAX PARCEL NO. 02-20-1800-203 IN THE DEED REGISTRY OFFICE OF FULTON COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 135 E. PENN STREET. UNDER AND SUBJECT TO COAL AND MINING RIGHTS, EASEMENTS, RIGHT OF WAYS, OIL AND GAS LEASES, COVENANTS, CONDITIONS, RESTRICTIONS, ETC., AS THE SAME MAY APPEAR IN PRIOR INSTRUMENTS OF RECORD AND ON THE AFORESAID RECORDED PLAN. 'LOAN NO 105655436 January 06, 2003 DATE LETTER VER REQ DESCRIPTION DATE 02124/03 01/06/03 OP171 016 GG1 Part 1 Penns lvania NOI Nathaniel Q. Wilkinson 135 E Penn St Carlisle, PA 17013-2435 as(o- oaoa- om- 946( CB-?-) Homeowners Name: Nathaniel Q. Wilkinson Property Address: 135 E Penn St, Carlisle PA 17013 Loan Account No.: 0005655436 PF: 1 SC F EX'qIRITA 'LOAN NO DATE 0005655436 01/06/03 Original Lender: Option One Current Lender/Servicer: Op EMERGENCY LETTER VER REQ DESCRIPTION DATE 02/24/03 OP171 016 GG1 Part 1 Pennsylvania NOI Mortgage tion One Mortgage Corporation HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: PF: 1 SC F 2 SC B s LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP171 016 GG1 Part 1 Pennsylvania NOI * 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 PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP171 016 GG1 Part 1 Pennsylvania NOI NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MUHIUAUE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO UAIt. OP 1 71 P F: 1 SC F 2 SC B I "LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP171 016 GG1 Part 1 Pennsylvania NOI Re: Loan No. 0005655436 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 wni.cn the property is located are set forth at the end of this Notice, or you may contact HUD directly at 800-569-4287 or visit the HUD PF: 1 SC F 2 SC B .. LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP171 016 GG1 Part 1 Pennsylvania NOI website at www.hud.gov/offices/hsg/sfh/hcc/hceprofl4.cfm. 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. P F: 1 SC F 2 SC B . LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02124/03 0005656436 01/06/03 OP171 016 GG1 Part 1 Pennsylvania NOI 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. OP 171 PF: 2 SC B .. LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP172 024 GG1 Part 2 Pennsylvania NOI Re: Loan No. 0005655436 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). PF: 1 SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP172 024 GG1 Part 2 Pennsylvania NOI NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 135 E Penn St, Carlisle PA 17013 15 StRIDUSLY 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 @ $ 525.36 2 MONTHS @ $ 525.36 (b) Previous late charges; (c) Other charges; Escrow, Inspection, NSF checks (d) Other provisions of the mortgage obligation, PF: 1 SC F 2 SC B $ 1576.08 $ 133.65 'LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP172 024 GG1 Part 2 Pennsylvania NOI if any. (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 1709.73 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $1709.73, 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: PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP172 024 GG1 Part 2 Pennsylvania NOI Overnight Mail Address Western Union Quick Collect 3 Ada Pay to: Option One Mortgage Corporation Irvine, Ca. 92618 Code City: Option, Ca You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable.) O P 172 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP173 012 GG1 Part 3 Pennsylvania NOI Re: Loan No. 0005655436 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your PF: 1 SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP173 012 GG1 Part 3 Pennsylvania NOI mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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. PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP173 012 GG1 Part 3 Pennsylvania NOI OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs ?:?niric? Seca wi.zn the snerITT's sale as specified in writing by the PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP173 012 GG1 Part 3 Pennsylvania NOI lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or.action will be by contacting the lender. OP1 73 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP174 024 GG1 Part 4 Pennsylvania NOI Re: Loan No. 0005655436 HOW TO CONTACT THE LENDER: Name of Lender: Option One Mortgage Corporation Address: 7515 Irvine Center Drive Attn : Tommi Tedford Address: Irvine, CA. 92618 Phone Number: 800-326-1500, Ext. 48004 Fax Number: 949-784-6033 PF: 1 SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP174 024 GG1 Part 4 Pennsylvania NOI Contact Person: Option One ext 48004 Office hours: Monday through Thursday 8:00 a.m. to 8:00 p.m. PST Friday 8:00 a.m. to 5:00 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 may or x may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP174 024 GG1 Part 4 Pennsylvania NOI * 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 PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP174 024 GG1 Part 4 Pennsylvania NOI ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP 1 74 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower January 06, 2003 TAmmy Wilkinson 135 E penn St Carlisle, Pa. 17013 Homeowners Name: Nathaniel Q. Wilkinson Property Address: 135 E Penn St, Carlisle PA 17013 PF: 1 SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower Loan Account No.: 0005655436 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 AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: PF : 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower * 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 PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OP 1 38 PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower Re: Loan No. 0005655436 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24!03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower 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 PF : 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 02/24/03 0005655436 01/06/03 OP138 003 GG1 PA Act 6/91 - Multi Borrower 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. OP 1 38 PF: 2 SC B V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES LZ SHERIFF'S RETURN - REGULAR CASE NO: 2003-01253 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OPTION ONE MORTGAGE CORP VS WILKINSON NATHANIEL Q ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILKINSON NATHANIEL Q the DEFENDANT at 134500 HOURS, on the 26th day of March 2003 at GIANT 1604 INDUSTRIAL DRIVE CARLISLE, PA 17013 by handing to NATHANIEL Q WILKINSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments 135 EAST PENN STREET IS VACANT. Sheriff's Costs: Docketing 18.00 Service 3 45 Affidavit . Surcharge .00 10.00 .00 - 3 1 45 Sworn and Subscribed to before By: me this o V. day of ? -Ztr[? 3 A.D. rothonotary So Answers: R. Thomas Kline 03/27/2003 MARK UDF SHERIFF'S RETURN - REGULAR CASE NO: 2003-01253 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OPTION ONE MORTGAGE CORP VS WILKINSON NATHANIEL Q ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILKINSON TAMMY the DEFENDANT , at 1105:00 HOURS, on the 26th day of March 2003 at 7 WILBERT DRIVE CARLISLE, PA 17013 by handing to TAMMY WILKINSON 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 Service 6.00 Affidavit 3.45 Surcharge .00 10.00 .00 19.45 Sworn and Subscribed to before me this le day of - w n,, j °ZVA3 A.D. i.i? ?n s A Prothonotary So Answers: R. Thomas Kline 03/27/2003 MARK UDREN By: eP y She iff • • s MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Option One Mortgage :COURT OF COMMON PLEAS Corporation ;CIVIL DIVISION P.O. Box 57038 =Cumberland County Irvine, CA 92619-7038 :MORTGAGE FORECLOSURE Plaintiff V. Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER 1?ND ASSE?G?Nm OF DAMA r? 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 Plaintiffs damages as follows: As set forth in Complaint $59,350.76 InterFromP2/25/031 ton 5/20/03 1,160.25 Late charges per Complaint 80.19 From 2/25/03 to 5/20/03 Escrow payment per Complaint 239.37 From 2/25/03 to 5/20/03 TOTAL $60,830--57 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J. UDREN & ASSOCIATES ja4rtorn Udre nEsquire, ESQUIRE ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : IV-.n,4 J _ ina La?? PRO PROTHY MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Option One Mortgage Corporation Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson Defendant(s) DATED: May 7, 2003 TO: Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1253 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT ?O COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage Corporation Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson Defendant(s) DATED: May 7, 2003 TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1253 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 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 PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-91080 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. - 4 MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION P.O. Box 57038 :Cumberland County Irvine, CA 92619-7038 Plaintiff 'MORTGAGE FORECLOSURE V. Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey COUNTY OF Camden SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Nathaniel Q. Wilkinson Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Tammy Wilkinson Age: Over 18 Residence: As captioned above Employment: Unknown Sworn to and subscribed before me this 20th day of May, 003. ti. Notary Pub is Qfthiii. 6/31/ ame:Mar J. Udren, Esq. Title:Attorney for Plaintiff Company:Mark J. Udren & Associates qtb b Er . MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage "COURT OF COMMON PLEAS Corporation ?CIVIL DIVISION P.O. Box 57038 ;Cumberland County Irvine, CA 92619-7038 :MORTGAGE FORECLOSURE Plaintiff V. Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $60,810 . 577 Interest From 5/2110' 1,446-90 to Date of Sale September 3, 00 Per diem @$13.65 (Costs to be added) $ MARK J. UDREN & ASSOCIATES ark J. dren, Esquire, ESQUIRE ATTORNEY FOR PLAINTIFF A C d C ?I w !? ..o to -o -- ?? f 1 ' , V ftb 1 c 4'Il €. ' -i U? C-D r\1 "T7 r=? -r; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1253 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION, Plaintiff (s) From NATHANIEL Q. WILKINSON AND TAMMY WILKINSON, 135 EAST PENN STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $60,830.57 L.L. $.50 Interest FROM 5/21/03 TO DATE OF SALE 9/3/03 - PER DIEM @$13.65 - $1,446.90 Atty's Comm % Due Prothy $1.00 Atty Paid $132.90 Other Costs Plaintiff Paid Date: MAY 22, 2003 CURTIS R. LONG Prothonota (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage COURT OF COMMON PLEAS Corporation ECIVIL DIVISION P.O. Box 57038 'Cumberland County Irvine, CA 92619-7038 ;MORTGAGE FORECLOSURE Plaintiff V. Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, 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 & ASSOCIATES 2 ark J. Udren, Esquire, ESQUIRE ATTORNEY FOR PLAINTIFF _ r o _0 MARK J. UDREN & ASSOCIATES EtY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-1253 AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, 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: 135 East Penn Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same As No 1 Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Richard B. Steffy and Dana H. Steffy Husband and Wife See Caption above. Address to Follow 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse SQ. Carlisle, PA 17013 Domestic Relations Section 13 Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue 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 135 East Penn Street 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. DATED: May 20, 2003 MARK J. UDREN & ASSOCIATES _ Mark J. ren, Esquire, ESQ. Attorney f r Plaintiff r.. 3 TLS _? -< ro V71RK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION P.O. Box 57038 :Cumberland County Irvine, CA 92619-7038 :MORTGAGE FORECLOSURE Plaintiff V. Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) NO'VICE'- OF SHERIFF" S SALR OF REAr PROPER't'y TO: Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 3, 2003, at 10:00am in the Commissioners Hearing Room 2nd Floor, Courthouse Carlisle, PA, to enforce the court judgment of $60,830.57, 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 RIGHTR YOU MAY $ ARTF O PREVENT TH HFRTFF1S SALE To prevent this Sheriff's Sale, you must take immediate actions 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900- 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY ST r.r gE ABLE T9 SAVE YOUR PROPrta'rv A1?*+? ypU HpyE OTH R RI HT EVEN IF THE ? 'S SALT DOE TAKL P AC]3 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 TARS THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 -I-, p,TTORN$Y FOR PLAINTIFF . ASSOCIAT$S MARK J. ea. Esquire, Esquire Mark J- Udr BY NO. 04302 E 500 N I.D. SIGHWAY? SUIT 1040 N. RINGSNJ 08034 CgERRY HIT'T. - COMMON PLEAS 856-482-6900 COURT OF Mortgage :CIVIL DIVISION :Cumberland County Option one Corporation CLOSURE 57038 1038 GE FORE P.O. gox - 19 : MORTGA Irvine, CA 926 plaintiff V. 110. 03-1253 Nathaniel 0• Wilkinson Tammy Wilkinson, treet 135 East Penn 11013 Carlisle, Defendant (s) Wilkinson TO: Nathaniel 4. Tammy WilkinsoStreet 135 East Penn 17013 17013 is Carlisle, PA Street Carlisle, A 2003 at 135 East Penn ale on September your house (real estate) at Courthouse Carlisle, be sold at the SherifRoom 2nd Floor, plaintiff scheduled to . Commissioners judgment Hearing s of $60,830-57? obtained by oned, the in the ale is postp 10-.00am the court J If the PA, to enforce the ) against You' Available Sale. above (the mortgagee the Next property will be relisted for 1 ? -- ? „r. ? e SALE Is Sale, you must take - ent, lat this Sheriff the back palm To prevent to the ou must pay celled if You Pay fees . To find out how much Y The will be can le attorney s t 1. charges a costs and reasonable to stril 4the Cour you may call: -- petition asking you may also a; the sale by filing a ro erly entered. 2. y may be able to stop ent was imP p the judgment, if the judo good cause* or open postpone the salefor roceedings• the Court to the sale through other legal p you contact one, 3. You may also be able to stop our rights- The sooner 1' on page two on 1 to assert Y le (See notice need an attorney the sa - You may you will have of to obtain an stopping more chance YattorneY • ) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS MV'EN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff fIs 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 TARS THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 C ,-, -? ro 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 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF .COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County :NO. 03-1253 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, 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"._ /l All Notices were served within the ?i 3129. This Affidavit is made subject to tt relating to unsworn falsification to Dated: July 24, 2003 BY: forth by Pa Rule C.P. tips If 18 Pa.C.S. Section 4904 Lt es.I V ..., v1. .., Attorney for Plaintiff VNNA7A-NN:7d 0e :?I jqj q! - erIV CO rVI J?.'JY?.?? III! MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-1253 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, 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: 135 East Penn Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same As No 1 Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Richard B. Steffy and 346 Veterans Way, Elliotsburg, PA Dana H. Steffy 17024-9165 Husband and Wife 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse SQ. Carlisle, PA 17013 Domestic Relations Section 13 Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue 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 135 East Penn Street Carlisle, PA 17013 WJW Enterprises, Inc. 3141 Pinney-Topper Rd., Ashtabula, PA 44004 I verify that the statements made in t i afAO are true and correct to the best of my personal know edg r tion and belief. I understand that false statements h?rei a e mject to the penalties of 18 Pa.C.S. sec. 4904 relating t un wo f a n to authorities. & ASSOCIATES DATED: July 24, 2003 Mark J. Udren, Esquire, Attorney for Plaintiff b?nn?m,?sNr?t?d .?'lrj':%ellu i C ??( it'd ?- Jill £,? ??T'?iv ? ? ?Q „%j ?..? _. fl ??? .w-Ct:, I;, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant (s) DATE: June 23, 2003 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1253 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF RE LI, PROPERTY OWNER(S): Nathan Q. Wilkinson and Tammy Wilkinson PROPERTY: 135 East Penn Street Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ""bA land County Sheriff's Sale on emb z at 10: 00am, in the Commisioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. E IrKA H'?IT r In w O o m w 4 N V N 2 v7 m m a A mi O• 0 a a V ? M CL ` Q Fed ? ?j 5 at 3pmR? 43m s. C d 0m64?? 3 °.78 ,a g. _y y? O N p pO Q M ? Q V yo P 0 n 6 7 3 m .@a3-mg 3$?n°m ??pp °m 2n° Zma m-y,mi ;'m`a R°. ? a 6 c ` .. m NE ?Pg?o m c $ ? ? o at A w W V A W N V Jut 24'1,3r o QD o am do c -$' mm? o.m H 3 z a U . °d oz 33 Dda ad no;r _1 9) ca 93 c 0 o d a Q ZLO >m ° m a -3Cri _ m, w 'O d a.y, C S C x = :z CL (D ((?? G O d ^. N N 1-0 7 m 6 a6 ?a N a m 0=00 ,-? m Cn d Ofd o O m A OF1 O =d- A a o w' ;L . ?? W H A 2 c j CO) C mSS d m y 6 L UW a to C W= N w N j 1 C7 0 a m a O 1 N +a co ? d 'm N C - • vi a ,, m N gd m m a T u D w ???? O I D m 0 0 0 ce Ohm' d am^ US-POSTAGE?m? N m I T O mN A O _ o O= m a z m ? S 5 N °on°a DD "N a A^wdmy d C ?i O d N C C ? . c @ o ? m x m ?m o ¢ma 6 3 0 my o o m N Ona °-?3 4 a 0 r? a a>- m H m ry ?7? ^m3 A ?Oa a m % ?. P O 6 m a _ a T N m ? d s Option One Mortgage Corporation VS Nathaniel Q. Wilkinson and Tammy Wilkinson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1253 Civil Term Harold Weary, Deputy.$heriff, who being duly sworn according to law, states that on June It, 2003 at 9:45 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Nathaniel Q. Wilkinson, by making known unto A.J. Apgar, adult step-son of defendant, at 135 East Penn Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2003 at 9:45 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tammy Wilkinson, by making known unto A.J. Apgar, adult son of defendant, at 135 East Penn Street, 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-July 8, 2003 at 4:55 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 Nathaniel Q. Wilkinson and Tammy Wilkinson located at 135 East Penn Street, C&y i S A Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Nathaniel Q. Wilkinson, by regular mail to his last known address of 135 East Penn Street, Carlisle, PA 17013. This letter was mailed under the date of July 3, 2003 and never returned to the Sheriffs Office. 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 one of the within named defendants, to wit: Tammy Wilkinson, by regular mail to her last known address of 135 East Penn Street, Carlisle, PA 17013. This letter was mailed under the date of July 3, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me Sp This day of R. Thomas Kline, Sheriff 2003, A.D. 13Y - Prothonotary Real Estat eputy ISdT c7 o O ?= w -n .rl ice'` xs hr in .J""! i rn Y MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1253 SUGG ZTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendants, Nathaniel Q. Wilkinson & Tammy L. Wilkinson, have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 2, 2003, Bankruptcy Case No. 03-05123. Mark J. MARK J. Atto ney `Esquire, Esquire & ASSOCIATES Plaintiff c 6. fll V G " J ?J rn Option One Mortgage Corporation VS Nathaniel Q. Wilkinson and Tammy Wilkinson In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1253 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff's Costs Docketing 30.00 Poundage 11.86 Posting Handbills 15.00 Advertising 15.00 Mileage 6.90 Levy 15.00 Surcharge 30.00 Law Library 50 Prothonotary 1.00 Postpone Sale 20.00 Law Journal 232.85 Patriot News 197.83 Share of Bills 28.90 $ 604.84 paid by attorney 12/08/03 Sworn and subscribed to before me So Ans/we/r y, .ism y's8?' . .- This day of R. Thomas Kline, Sheriff 2003, A.D. Lv. w' //L Gf l ff BYE Prothonotary Real 4Este Deputy CV, 4304s' jp, /9.,'Fy3 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 34 Writ No. 2003-1253 Civil Option One Mortgage Corporation VS. Nathaniel Q. Wilkinson and Tammy Wilkinson Atty.: Mark J. Udren ALL THAT CERTAIN tract of land, together with the improvements thereon, erected situated in the Bor- ough of Carlisle. Cumberland Coun- ty, Pennsylvania, more particularly bounded and described as follows: ON the North by an 18-foot wide alley: on the East by property now or formerly of John Keller's heirs: on the South by East Penn Street; and on the West by property now or formerly of James C. Holmes, having frontage of 20 feet on East Penn Street, and extending in depth at an even width of 120 feet to the alley aforesaid. BEING known and designated at Tax Parcel No. 02-20-1800-203 in the Deed Registry Office of Fulton County. Pennsylvania. HAVING erected thereon a dwell- ing known as 135 E. Penn Street. UNDER AND SUBJECT to coal and mining rights, easements, right of ways, off and gas leases, covenants, conditions, restrictions, etc., as the same may appear in prior instru- ments of record and on the afore- said recorded plan. BEING KNOWN AS 135 East Penn Street. Carlisle, PA 17013. PROPERTY ID NO: 02-20-1800- 203. TITLE TO SAID PREMISES IS VESTED IN Nathaniel Q. Wilkinson and Tammy Wilkinson by Deed from Dana H. Steffy and Richard B. Steffy, husband and wife dated 01/ 18/02, recorded 02/05/02, in Deed Book 250, Page 1333. a Mane Coyne, Edit TO AND SUBSCRIBED before me this day of AUGUST, 2003 NpTomtm U LQIS E. SNYI)ER, WAY A1bec VvG?i.3P{?'?.dw''?d, '.7om, CGf?fi,??6.SI wl Coin @ My cords M , ?BIC11 rS, i alley: on the East oy propei o, uow or formerly of John Keller's heirs: on the South by East Penn Street: and on the West by property now or formerly of James C. Holmes, having frontage of 20 feet on East Penn Street, and extending in depth at an even width of 120 feet to the alley aforesaid. BEING known and designated at Tax Parcel No. 02-20-1800-203 in the Deed Registry Office of Fulton County, Pennsylvania. HAVING erected thereon a dwell- ing known as 135 E. Penn Street. UNDER AND SUBJECT to coal and mining rights, easements, right of ways, oil and gas leases, covenants. conditions, restrictions, etc., as the same may appear In prior instru- ments of record and on the afore- said recorded plan. BEING KNOWN AS 135 East Penn Street, Carlisle. PA 17013. PROPERTY ID NO: 02-20-1800- 203. TITLE TO SAID PREMISES IS VESTED IN Nathaniel Q. Wilkinson and Tammy Wilkinson by Deed from Dana H. Steffy and Richard B. Steffy, husband and wife dated 01/ 18/02. recorded 02/05/02, in Deed Book 250. Page 1333. 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 Asst. 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 hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 4...... ^,?..... r?.............. PUBLICATION ........9d: COPY Sworn ubscr ibed before is 3th day of ugus 0 A.D. SALE#34 1 Terry L. Russell, Notary PuNc City Of Harrisburg, Dat0h C xr y t- MyCornrnlsslonExpires June 6,2006 NOT Y PUBLIC herobsr.PeMxyl` r4aAss°awmOlNOlanes My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 196.08 Probating same Notary Fee(s) $ 1.75 Total $ 197.83 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff €:Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson :NO. 03-1253 Tammy Wilkinson Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $60,830.57 Interest From 5/21/03 25,238.85 to Date of Sale 6/11/08 Ongoing Per Diem of 13.65 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFF P.C. CE , An a BYAffln1,A Att 3rriey6 for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 70 tit fk? W w U4 .,s 44 f { Few © UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA In re: Nathaniel Q. Wilkinson and Chapter 13 Tammy L. Wilkinson, a/k/a Tammy L. Apgar Bankruptcy No. 1:03-bk-05123-MDF Debtors Option One Mortgage Corporation, a California Corporation, or its Successor or Assignee Movant VS. Nathaniel Q. Wilkinson Tammy L. Wilkinson, a/k/a Tammy L. Apgar Respondent ORDER AND NOW, in accordance with the Settlement Stipulation, after Notice of Default and upon the filing of Certification of Default, it is hereby ORDERED that the automatic stay of Bankruptcy Code §362(a) be, and the same hereby is, MODIFIED to permit Option One Mortgage Corporation, a California Corporation, or its Successor or Assignee to foreclose its mortgage, and, without limitation, to exercise any other rights it has under the mortgage or with respect to the property located at: 135 E Penn Street, Carlisle, PA. By the Comm, 70411 A Cft*rur' ` Jgdve (]DK) This document is electronically signed and filed on the same date. Dated: December 3, 2007 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson ::NO. 03-1253 Tammy Wilkinson Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, 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. -/ BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE } M `91 R UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson :NO. 03-1253 Tammy Wilkinson Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, 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: 135 East Penn Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 135 East Penn Street 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 • 4. Name and address of the last recorded holder of every mortgage of record: Name Address Option One Mortgage Corp. P.O. Box 57038 Irvine, CA 92619-7038 Richard B. Steffy & Dana H. Address to Follow Steffy, Husband and Wife 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 Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 135 East Penn Street 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. DATED: January 2, 2008 UDREN LAW OFFICES, P.C. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -01 w UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage -:COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson -,NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) r 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 `l :-1 I, CD %_1 It UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation =CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson €:NO. 03-1253 Tammy Wilkinson De f endant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, 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.) r ?V4 4 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 A'? C. - l ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON, ERECTED SITUATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY AN 18-FOOT WIDE ALLEY; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KELLER'S HEIRS; ON THE SOUTH BY EAST PENN STREET; AND ON THE WEST BY PROPERTY NOW OF FORMERLY OF JAMES C. HOLMES, HAVING FRONTAGE OF 20 FEET ON EAST PENN STREET, AND EXTENDING IN DEPTH AT AN EVEN WIDTH OF 120 FEET TO THE ALLEY AFORESAID. BEING KNOWN AND DESIGNATED AT TAX PARCEL NO. 02-20-1800-203 IN THE DEED REGISTRY OFFICE OF FULT.ON COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 135 E. PENN STREET. UNDER AND SUBJECT TO COAL AND MINING RIGHTS, EASEMENTS, RIGHT OF WAYS, OIL AND GAS LEASES, COVENANTS, CONDITIONS, RESTRICTIONS, ETC., AS THE SAME MAY APPEAR IN PRIOR INSTRUMENTS OF RECORD AND ON THE AFORESAID RECORDED PLAN. BEING KNOWN AS: 135 EAST PENN STREET, CARLISLE, PA 17013 PROPERTY ID NO.: 02-20-1800-203 TITLE TO SAID PREMISES IS VESTED IN NATHANIEL Q. WILKINSON AND TAMMY WILKINSON, HUSBAND AND WIFE BY DEED FROM DANA H. STEFFY AND RICHARD B. STEFFY, HUSBAND AND WIFE DATED 1/18/02 RECORDED 2/5/02 IN DEED BOOK 250 PAGE 1333. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1253 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION, Plaintiff (s) From NATHANIEL Q. WILKINSON AND TAMMY WILKINSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $60,830.57 L.L. Interest FROM 5121/03 TO DATE OF SALE 6111108 - ONGOING PER DIEM OF $13.65 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $25,238.85 Atty's Comm % Atty Paid $750.24 Plaintiff Paid Date: JANUARY 9, 2008 Due Prothy $2.00 Other Costs Curti. Long, Proth ry (Seal) By: Deputy REQUESTING PARTY: Name CHANDRA M. ARKEMA, EQUIRE Address: UDREN LAW OFFICES, PC. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 I 7 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION :Cumberland County Plaintiff V. :NO. 03-1253 Nathaniel Q. Wilkinson Tammy Wilkinson Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: February 14, 2008 9- f-4,b-v&r j i 3! 0z6o gr TO: USA, US Attorney US Department of Justice 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 UDREN LAW OFFICES, P.C. DATE: February 20, 2008 BY: Attorneys for Plainti f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE R H O Pi xbNw m T?cnc cr. K 110 d MwW 'dC v O ¢t O. tAt?rtGIt n N O ? Ln " F91 rt j- m 0 O rn. 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Z Q co c 4 m A m ° mm r E o o o N o _ a, 00 C h Q Z Y 04 M M 3 C d 1 +? ) f6 m O O U 2 O E >. Ce 'D p E ZQ V a- r im I ? LO N ? J r N Ch to CO 1- CO 0) r r r ^ J 1 c m a c ° m L 0 Y r: w mp, F? m m a Q 3 o` U. CA ca Li ti m' M LL a r?-t rc ? °. ?lw co Option One Mortgage Corporation In The Court of Common Pleas of VS Cumberland County, Pennsylvania Nathaniel Q. Wilkinson and Tammy Wilkinson Writ No. 2003-1253 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark J. Udren. Sheriff's Costs: Docketing 30.00 Poundage 1.94 Advertising 15.00 Prothonotary 2.00 Mileage 4.80 Levy 15.00 Surcharge 30.00 $ 98.74 So Answers* R. Thomas Kline, Sheriff BYE/ ") Real Estate ergeant dtrV "Z_ ?,q3,)-, /ce-,, .26&. 4'/ 'A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson :NO. 03-1253 Tammy Wilkinson Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, 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: 135 East Penn Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street 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 4. Name and address of the last recorded holder of every mortgage of record: Name Address Option One Mortgage Corp. P.O. Box 57038 Irvine, CA 92619-7038 Richard B. Steffy & Dana H. Address to Follow Steffy, Husband and Wife 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 Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 135 East Penn Street 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. DATED: January 2, 2008 UDREN LAW OFFICES, P.C. BY : (JVd/JI / // 11-i - Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE .f UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation ;CIVIL DIVISION Plaintiff 'Cumberland County V. ;MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Nathaniel Q. Wilkinson 135.East Penn Street Carlisle, PA 17013 Your house (real estate) at.135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale.will go through only if the buyer pays the Sheriff the full.amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong)'are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE.- ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA,.ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson ::NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 170131s scheduled to be sold at the.Sheriff's Sale on June 11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON, ERECTED SITUATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY AN 18-FOOT WIDE ALLEY; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KELLER'S HEIRS; ON THE SOUTH BY EAST PENN STREET; AND ON THE WEST BY PROPERTY NOW OF FORMERLY OF JAMES C. HOLMES, HAVING FRONTAGE OF 20 FEET ON EAST PENN STREET, AND EXTENDING IN DEPTH AT AN EVEN WIDTH OF 120 FEET TO THE ALLEY AFORESAID. BEING KNOWN AND DESIGNATED AT TAX PARCEL NO. 02-20-1800-203 IN THE DEED REGISTRY OFFICE OF FULTON COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 135 E. PENN STREET. UNDER AND SUBJECT TO COAL AND MINING RIGHTS, EASEMENTS, RIGHT OF WAYS, OIL AND GAS LEASES, COVENANTS, CONDITIONS, RESTRICTIONS-, ETC., AS THE SAME MAY APPEAR IN PRIOR INSTRUMENTS OF RECORD AND ON THE AFORESAID RECORDED PLAN. BEING KNOWN AS: 135 EAST PENN STREET, CARLISLE, PA 17013 PROPERTY ID NO.: 02-20-1800-203 TITLE TO SAID PREMISES IS VESTED IN NATHANIEL Q. WILKINSON AND TAMMY WILKINSON, HUSBAND AND WIFE BY DEED FROM DANA H. STEFFY AND RICHARD B. STEFFY, HUSBAND AND WIFE DATED 1/18/02 RECORDED 2/5/02 IN DEED BOOK 250 PAGE 1333. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1253 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION, Plaintiff (s) From NATHANIEL Q. WILKINSON AND TAMMY WILKINSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $60,830.57 L.L. Interest FROM 5/21/03 TO DATE OF SALE 6/11/08 - ONGOING PER DIEM OF $13.65 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $25,238.85 Atty's Comm % Atty Paid $750.24 Due Prothy $2.00 Other Costs Plaintiff Paid Date: JANUARY 9, 2008 (Seal) Curtis R ong, Prothon By: Deputy REQUESTING PARTY: Name CHANDRA M. ARKEMA, EQUIRE Address: UDREN LAW OFFICES, PC. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 Real Estate Sale # 33 On February 21, 2008 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of Carlisle, Cumberland County, PA Known and numbered as 135 East Penn Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 21, 2008 By. Real Estat Sergeant I Z :01 V I I Ndf 8002 Vd 'A1Hit0J u v t AWNS 3N1 10 3JI??t) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage =COURT OF COMMON PLEAS Corporation :CIVIL DIVISION P.O. Box 57038 :Cumberland County Irvine, CA 92619-7038 Plaintiff V. Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Defendant (s) NO. 03-1253 SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendants, Nathaniel Q. Wilkinson and Tammy Wilkinson have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on march 7, 2008, Bankruptcy Case No. 08-00799. UDREN P.C. BY: . Atto ys f i tiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 'LOUIS A. SIMONI, ESQUIRE G3U?0`??? c'-? -- ? c?? ?, -n w ?: , ?' ? e F't ? R? __.{ G? ?? d- fV ;per. _` ?-.3 ": WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N003-1253 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION Plaintiff (s) From NATHANIEL Q. WILKINSON AND TAMMY WILKINSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $60,830.57 L.L.: Interest from 5/21/03 to Date of Sale March 7, 2012 ongoing per diem of $13.65 to actual date of sale including if sale is held at a later date - $43,871.10 Atty's Comm: % Atty Paid: $1,6,@7.23 Plaintiff Paid: Date: 10/10/11 (Seal) REQUESTING PARTY: Due Prothy: $2.00 Other Costs: David D. Buell, P othonotary By: Deputy Name: DANIEL S. SIEDMAN, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 306534 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County - V. :MORTGAGE FORECLOSURE M. 1 Nathaniel Q. Wilkinson NO. 03-1253 ` ? r L Tammy Wilkinson O ; Defendant (s) PRAECIPE TO ISSUE WRIT OF EXECUTION cam: TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $60,830.57 Interest From 5/21/03 43,871.10 to Date of Sale March 7, 2012 Ongoing Per Diem of 13.65 to actual date of sale including if sale is held at a later date (Costs to be added) UDREN LAW OFFICES, P.C. W4 %ay.oa d CL 31.45 19, y5 u„ 604.74 Ins. 9 Ss. Sd 9.oo t S. ao BY:? Attorneys for Plaintiff S. a e:?'n;=n Esgt;; ,, PA ND 306534 '% a .ao-?)L'%k 6. Cry ?b aoo ew a?5-713 w1(1+ ok Q? ?u?l UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation 'CIVIL DIVISION CZ: Plaintiff Cumberland County rri ces MORTGAGE FORECLOSURE `- { Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant(s) ?- off= CERTIFICATE TO THE SHERIFF -- ' I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X 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. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. 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: UDREN LAW OFFICES, P.C. Attorneys for Plaintiff P.a 1D 306534 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage : COURT OF COMMON PLEA S Corporation : CIVIL DIVISION err= c=: Plaintiff € Cumberland County MORTGAGE FORECLOSURE <? G CD -: Nathaniel Q. Wilkinson - NO. 03-1253 Q C Tammy Wilkinson ,. Defendant(s) C E R T I F I C A T E I hereby state that as 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 statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff Esqu;r ? A 1D 306534 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage ':COURT OF COMMON PLEAS -0 t= Corporation CIVIL DIVISION Plaintiff € Cumberland County V. --- -..::_ MORTGAGE FORECLOSURE C)_ ; Nathaniel Q. Wilkinson ':NO. 03-1253 Tammy Wilkinson Defendant(s) c AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Option One Mortgage Corporation, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 135 East Penn Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 135 East Penn Street 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 Hudson United Bank 1000 Macarthur Boulevard Mahwah, NJ 07430 4. Name and address of the last recorded holder of every mortgage of record: Name Address Option One Mortgage P.O. Box 57038 Corporation Irvine, CA 92619-7038 Richard B. Steffy and Dana 346 Veterans Way H. Steffy Elliottsburg, PA 17024 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 Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue Internal Revenue Service Atty General of U.S. U.S.A. 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Technical Support Group, William Green Federal Bldg., 600 Arch St. Room 3259, Philadelphia, PA 19106 US Dept. of Justice, Room 5111, Main Justice Bldg., 10th & Constitution Ave. N.W. Washington, DC 20531 US Dept. of Justice U.S. Attorney 615 Chestnut St., Suite 1250 Philadelphia, PA 19106-4476 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 135 East Penn Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: October 4, 2011 UDREN LAW OF S, P. C. BY: Attorneys for Plaintiff L'Iaf?iel S. Sk-?d r;,ar2, Est?;,f!sF? R,'ID 306534 UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com 0 ti O FOR PLAINTIFF p on ne Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson :NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 ? cc ? a '•,^f CD Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, 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.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 7. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249 -3166 800-990 -9108 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2911 WV 18 it 10-- 02 CUMBERLAND COUNTY PENNSYLVANIA Option One Mortgage Corporation Case Number vs. Nathaniel Q Wilkinson (et al.) 2003-1253 SHERIFF'S RETURN OF SERVICE 11/15/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $93.84 SO ANSWERS, November 17, 2011 RON R ANDERSON, SHERIFF L ?!g: y3 ?/ q Cc n t,,,Suite Sherift, Te eosoft, In; MARS J. VDAEN, BSQUM NJMANAG 7VGATTORNEP TINA MARM RICA' OP,P" ADAQNLYMYOR IVA. UD"N LAW OFFICES, AC. WOODCREST CORPORATE CEATER 111 WOODCREST ,ROAD SUITE 200 CA,R RYHEL, ArEW JERSEY 08003-3620 856. 669. 5400 dJ0. 005P. OJYY FFRE LE MAC PENNSYLVANIA .DESIGNATED COUNSEL November 14, 2011 Sent via telefax #1-717-240-6397 Cumberland County Sheriff's Office One Courthouse Square Carlisle, PA 17013-3387 ATTN: Claudia Re: Option One Mortgage Corporation vs. Nathaniel Q. Wilkinson & Tammy Wilkinson Cumberland County C.C.P. No. 03-1253 Premises: .135 East Penn Street, Carlisle, SS Date: March 7, 2012 Dear Claudia: my !Rb LU!; U4.oLNin ruui/UUI PA 17013 Please Stay the Sheriff's Sale scheduled for March 7, 2012. Sale is stayed for the following reason: Defendant(s) filed Chapter 13 Bankruptcy filed March 7, 2008 in the Middle District (Harrisburg, PA). Case number #08-00799. 20iiA granted August 8, 2011. Bankruptcy reinstated October 11, you for your attention to this matter. y/ yours , Stear Manager /hac 1 4 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation =CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Option One Mortgage Corporation, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 135 East Penn Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 135 East Penn Street 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 Hudson United Bank 4. Name and address of of record: Name Option One Mortgage Corporation 1000 Macarthur Boulevard Mahwah, NJ 07430 the last recorded holder of every mortgage Address P.O. Box 57038 Irvine, CA 92619-7036 4 Richdrd B. Steffy and Dana 346 Veterans Way H. Steffy . Elliottsburg, PA 17024 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 Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department. of Revenue Internal Revenue Service Atty General of U.S. U.S.A. 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Technical Support Group, William Green Federal Bldg., 600 Arch St. Room 3259, Philadelphia, PA 19106 US Dept. of Justice, Room 5111, Main Justice Bldg., 10th & Constitution Ave. N.W. Washington, DC 20531 US Dept. of Justice U.S. Attorney 615 Chestnut St., Suite 1250 Philadelphia, PA 19106-4476 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 135 East Penn Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED : October2011 "? UDREN LAW 05 S, P.C. _?--j BY: Attornevs for Piaint'-_ r Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com v. MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson Tammy Wilkinson Defendant(s) NO. 03-1253 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, 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. 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.) f YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com Option One Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson Tammy Wilkinson Defendant(s) NO. 03-1253 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) Y YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage €COURT OF COMMON PLEAS Corporation :CIVIL DIVISION Plaintiff :Cumberland County V. 'MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $60,830.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N003-1253 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION Plaintiff (s) From NATHANIEL Q. WILKINSON AND TAMMY WILKINSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $60,830.57 L.L.: Interest from 5/21/03 to Date of Sale March 7, 2012 ongoing per diem of $13.65 to actual date of sale including if sale is held at a later date - $43,871.10 Atty's Comm: % Atty Paid: $1,6al.23 Plaintiff Paid: Date: 10/10/11 Due Prothy: $2.00 Other Costs: David D. Buell, P othonotary (Seal) REQUESTING PARTY: Name: DANIEL S. SIEDMAN, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 306534 By: Deputy TRUE COPY FROM RECORD In Testimony whereof, I hero unto set my hand and the "W of said at Cadiste, Pa. This. IQ da?arJ? 2o- L- nt r tow- ?le:Yti?at(Nt1?35"? 130 ilo, UDREN LAW OFFICES, P.C. ATTORNEY FOR PL~N'~Fh'~ WOODCREST CORPORATE CENTER ~ ~+- ~`'"~ 111 WOODCREST ROAD, SUITE 200 -r'~'" "`' CHERRY HILL, NJ 08003-3620 ~''~ r~ '' 856-669-5400 pleadings@udren. com ..~ ;,. Option One Mortgage € COURT OF COMMON PLEAS ~ ~"Q a ~ ,_, ~ ~ ~-~'~~ Corporation €CIVIL DIVISION ~~ ~, Plaintiff :Cumberland County ~ ~ ~" v . . ~ ,~- :MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson 'NO. 03-1253 Tammy Wilkinson Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 5 21 03 48,839.70 to Date of Sale March 6, 2013 Ongoing Per Diem of 13.65 to actual date of sale including if sale is held at a later date (Costs to be added) $60,830.57 UDREN LAW OFFICES, P. C. „F r BY:_ a ~y ~ Atto tq .y „ -, SS'So ,~r, ~~.o1s °~. ~,~, \~~ ©~~ ~~ ~1~ c{OlS9 ~, emu. o~s,,,~~'' ~~g7~~7~0? `~~ \'1 ., . _ .. ~ ~. a M. BELLING, r-:::.,~a pq ID 309091 ~1 ~t ~k ~ t~ ~s~e~, UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA In Re: NATHANIEL Q. WILKINSON xxx-xx-8697 TAMMY L. WILKINSON XXX-XX-4228 Debtor(s) Chapter 13 Case No. 1:08-bk-00799-MDF 11 U.S.C. §362(d) WELLS FARGO BANK, N.A., as Trustee for Option One Mortgage Loan Trust 2002-A, Asset-Backed Certificates, Series 2002-A Movant v. NATHANIEL Q. WILKINSON TAMMY L. WILKINSON Debtor(s) And CHARLES J. DEHART, III, ESQUIRE Trustee Respondents ORDER MODIFYING §362 AUTOMATIC STAY Upon the Motion of PARKER, McCAY, P.A. Attorneys for Wells Fargo Bank, N.A., as Tnistee for Option One Mortgage Loan Trust 2002-A, Asset-Backed Certificates, Series 2002-A, its successors and/or assigns (hereinafter "Movant"), under Bankruptcy Code section 362(d) for relief from. the automatic stay as to certain real property as hereinafter set forth, and for cause shown; 1. The automatic stay of Bankruptcy Code section 362(a) is vacated to permit the Movant to institute or resume and prosecute to conclusion one or more actions in the court(s) of appropriate jurisdiction to pursue the Movant's rights in the following property described below to the extent and in the manner provided by any applicable contract documents and non-bankruptcy law. Case 1:08-bk-00799-MDF Doc 93 Filed 10/17/12 Entered 10/17/12 15:32:36 Desc Main Document Page 1 of 2 _ .. .. ._ ., , _. . I35 E. Penn Street, Carlisle, Pennsylvania 170.13 2. ORDERED that Rule 4001(a)(3) is not applicable and Movant may immediately enforce and implement this Order granting relief from the automatic stay. 3. The Movant may join the Debtor and any Trustee appointed in this case as defendants in its action(s) irrespective of any conversion to any other chapter of the Bankruptcy Code. By the Court, Chief B~P~Y ~ (JK3 Dated: October 17, 2012 Case 1:08-bk-00799-MDF Doc 93 Filed 10/17/12 Entered 10/17/12 15:32:36 Desc Main Document Paae 2 of 2 ;. ., ,. .. . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren. com ~~ ~ , Option One Mortgage € COURT OF COMMON PLEAS "'~;~ ''' =-~' , Corporation ~ CIVIL DIVISION ~'7~ ~ O i ~y:', :t _ . Plaintiff :Cumberland County ~ ~~_ c s ~ ~ :~tW MORTGAGE FORECLOSURE ~~ a ~~? ~ Nathaniel Q. Wilkinson NO. 03-1253 ;~ ~? ~~- Tammy Wilkinson ~ Defendant(s) C E R T I F I C A T E I hereby state that as 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 statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities UDREN OFj~~FICESn/~P. C~ Attorn vs f'or Plait~it.i~~ C. PAIGE M. BELLING, ES~u.f~~ PA ID 309091 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Option One Mortgage =COURT OF COMMON PLEAS -~ Corporation CIVIL DIVISION ~ ,:, --+ Plaintiff € Cumberland County Q ~;~~ v . ~ r-~ ~e~ :-~ MORTGAGE FORECLOSURE ~,~ ~ Nathaniel Q. Wilkinson € NO. 03-1253 '~° ~"' ~,,. -,~; ~~`~~~ ` ~ Tammy Wilkinson ~~.. . - ~ ~, ~~': Defendant (s ) ~ _~ _ ~~,~ . ~ AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Option One Mortgage Corporation, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 135 East Penn Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street 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 Hudson United Bank 1000 Macarthur Boulevard Mahwah, NJ 07430 4. Name and address of the last recorded holder of every mortgage of record: Name Address Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Richard B. Steffy and 346 Veterans Way Dana H. Steffy Elliottsburg, PA 17024 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose .interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 135 East Penn Street Carlisle, PA 17013 Internal Revenue Service Atty General of US Technical Support Group, William Green Federal Bldg., 600 Arch Street, Room 3259 Philadelphia, PA 19106 US Dept of Justice, Room 5111 Main Justice Bldg., 10th and Constitution Avenue N.W. Washington, DC 20531 U.S.A. US Dept of Justice US Attorney 615 Chestnut Street, Suite 1250 Philadelphia, PA 19106-4476 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements he are made subject to the penalties of 18 Pa.C.S. sec. 4904 rel ing to unsworn f~,,lsification to authorities . '~~ n~~~ DATED : November 2 01 , _ _.~ ( ,~ ; ~~ UDREl~ LA /OFFI ~ , P . C . ~ry BY : l./V ~ AI~A~~~~LL~ PAID3 ~.. UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Option One Mortgage :COURT OF COMMON PLEAS Corporation 'CIVIL DIVISION Plaintiff :Cumberland County v. =MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson €NO. 03-1253 Tammy Wilkinson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 -~ ~_- ~, ,~"' -~:~ --~~, ~ ~ _..t cn ~"" u"' r ~ ,~ -,: ~ ~• ~ ~ ~ ~ ~~ ~ ~:s Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 6, 2013, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $60,830.57, 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 OWNPlR'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: {856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~., -;- ~, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'°S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this, schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE., GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 03-1253 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION Plaintiff (s) From NATHANIEL Q. WILKINSON, TAMMY WILKINSON (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $60,830.57 L.L.: Interest FROM 5/21/03 TO DATE OF SALE MARCH 6, 2013 -Ongoing Per Diem of $13.65 to actual date of sate including if sale is held at a later date - f48~ 8~• 7d Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,749.57 Other Costs: Plaintiff Paid: mate: 12/3/1'L (Seal) REQUESTING PARTY: Name: PAIGE M. BELLING, ESQUIRE Address: UDREN LAW OFFICES, P.C. ~~~G~I.Q David D. Buell, Prothonotary Deputy ll l WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 309091 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 113 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com ma) C - Option One Mortgage QCOURT OF COMMON PLEAS MM C= Corporation CIVIL DIVISION Plaintiff € Cumberland County > V. �-- -, Nathaniel Q. Wilkinson C-) _ Tammy Wilkinson NO. 03-1253 y c C' Defendant (s) CD PETITIO14 FgX 2261RONEKWT OF H FF' E Plaintiff, by its counsel, petitions the Court for a 3 (three) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 135 East Penn Street, Carlisle, PA 17013 was originally scheduled for March 6, 2013, then postponed to May 1., 2013, then postponed to July 9, 2013 due to a Chapter 13 Bankruptcy filing. 2 . The aforementioned Bankruptcy. Case was Dismissed by Order of the Bankruptcy Court dated May 28, 2013 . See Exhibit "A" attached 'hereto. 3 . A 3 (three) month postponement of the Sheriff's sale is necessary to allow Plaintiff to resolve the pending assignment issue. 4, . Pursuant to local rule the defendant is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 5. No Judge has been assigned to this matters: . WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the October 2, 2013 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: ar, Nath . Wolf, Esquire A t r4gy Sort aintiff Local Counsel HARRY . PA I '10,501 Order Dismissing(Form ordsmiss)(01113) UNITED STATES BANKRUPTCY COURT :MIDDLE DISTRICT OF PENNSYLVANIA In re:Debtor(s)(name(a)used by the debtors)in the last 8 years,including married,maiden,and trade)-- Nathaniel Q.Wilkinson Chapter 13 Tammy L.Wilkinson Case No, 1:13--bk-01123--RNO Debtor(s) arde Upon consideration of the Motion to dismiss case and it having been determined alter notice and opportunity for hearing,that the case should be dismissed,it is ORDERED that the above—named can of the debtor(s)be and is hereby dismissed. Dated: May 28,2013 By the Court, 6�A �. Honorable Robert N.Opel United States Bankruptcy Judge Case 1:13-bk-01123-RNO Doc 19 Filed 05/28/13 Entered 05/2811311:54:41 Desc Order Dismissing Page 1 of 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III 'WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings @udren.com Option One Mortgage ° COURT OF COMMON PLEAS Corporation CIVIL DIVISION Plaintiff @Cumberland County V. Nathaniel Q. Wilkinson Tammy Wilkinson ' No. 03-1253 Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.F. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed due to a Chapter 13 Bankruptcy filing. Plaintiff now seeks an additional postponement to allow time to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3 (a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 135 East Penn Street, Carlisle, PA 17023, to the October 2, 2013 Sheriffs sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: athan olf, Esquire At ore far l intiff Local sel HARRY§.,RE E, ESQUIRE �A t� 310501 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, Na 08003-3620 856-669-5400, pleadiugs®u.dren.com Option One Mortgage xCOURT OF COMMON PLEAS Corporation - CIVIL DIVISION Plaintiff € Cumberland County V. Nathaniel Q. Wilkinson Tammy Wilkinson NO. 03-1253 Defendant.(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was sewed upon the following persons) named herein at their last known address or their attorney of record by; . xxxx Regular First Class Mail Certified Mail Other Date Served: July 8, 2013 TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 UDREN LAW OFFICES, P.C. BY, Wolf, Esquire A € r y N& P faintiff j/,16ca1626unsel HARRY 5,R49 EH':r ESQUIRE PAID 3110501 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION � C) ry r-i i C � Option one Mortgage r r, r Corporation Plaintiff V. NO. 03-1253 -<> o'er Nathaniel Q. Wilkinson Tammy Wilkinson 3} C-) Defendant(s) ro c ORDER -� AM NOW, this 0% day of July, 2013, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 135 East Penn Street, Carlisle, PA 17013, it is hereby ORDERED that the said Sale currently scheduled for July 9, 2013, is extended 3 (three) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for October 2, 2013. No further advertising or additional notice to lienholders or Defendant(a) is required provided the postponement is announced at the July 9, 2013 Sheriff's Sale. BY THE COURT: TOL.., athaniel Q. Wilkinson 135 East Penn Street Carlisle,. PA 17013 L,,Ta'm-my Wilkinson 135 East Penn Street Carlisle, PA 17013 I- r Sheriff of Cumberland County One Courthouse Square ' Carlisle, PA 17013-3387 wren Law Offices, P.C. 111 woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department C "es /'(. it LL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Option One Mortgage Corporation Plaintiff V. : NO. 03-1253 Nathaniel Q. Wilkinson Tammy Wilkinson Defendants) &1*AAed,-O R D E R AND NOW, this jot� day, of July, 2013, after consideration of Plaintiff' s Petition for Postponement of Sheriff' s Sale of the mortgaged property located at 135 East Penn Street, Carlisle, PA 17013, it is hereby ORDERED that the said Sale currently scheduled for July 10, 2013, is extended 3 (three) month(s) to the regularly scheduled Cumberland County Sheriff' s Sale scheduled for October 2, 2013 . No further advertising or additional notice to lienholders or Defendant (s) is required provided the postponement is announced at the July 10, 2013 Sheriff' s Sale . BY THE COURT: TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 -,✓�Tammy Wilkinson 135 East Penn Street Carlisle, PA 17013 mco Sheriff of Cumberland County > One Courthouse Square Carlisle, PA 17013-3387 ,.1✓"Udren Law Offices, P .C. Try W 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Dept ar�t�ment --j `'"l The Patriot-News Co. 2020 Technology Pkwy Q patriotNews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. This ad ran on the date(s)shown below: 2011-7714 Clvii 04/16/13 N HWEST SAVINGS B K vs. 04/23/13 HENRY LINE Constance B.Line 04/30/13 Atty: Megan C.Huff ALL THAT CERTAIN lot,tract or parcel of land situate in Middlesex r Cumberland County, Pennsylvania, more' particularly bounded and described as follows,to wit: Sworn to and subscribed before me this 13 day of May, 2013 A.D. BEGINNING at a post corner of land now or formerly of Albert Bucher;thence South Five and forty-nine and one-fourth degrees East,a distance of one-hundred forty-four (4). and two tenths feet to a point;thence along (1(1 ary Public a public road,South seventy degrees West a distance of two hundred twenty and two- tenths feet to a point;thence by lands now or formerly of Edward L. Sunday,North twenty-two and one-half degrees West, a five- tenths of one a point;thence bynan s nor COMMONWEALTH OF PENNSYLVANIA tenths feet to a point;thence by lands nor or formerly of Albert Bucher,North eighty Notarial Seal and one-half degrees East, a distance of Holly Lynn Warfel,Notary Public one hundred sixty and one-tenth feet to the Washington Twp.,Dauphin County point or place of BEGINNING.Containing My Commission Expires Dec.12,2016 26,190 square feet.. MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _ ow of IIitabeef,.fD J i f Jody S Smith Chief De put �s P Y ,,, c L Cu pit i 2: t. Richard W Stewart Solicitor oFFcEoFrkE$HERIFF UoiB R LA [J CUL i PENNSYLVANIA Option One Mortgage Corporation Case Number vs. Tammy Wilkinson (et al.) 2003-1253 SHERIFF'S RETURN OF SERVICE 01/03/2013 10:25 AM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 135 East Penn Street, Carlisle, PA 17013, Cumberland County. 01/08/2013 1724 hrs, Noah Cline, Deputy, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Tammy Wilkinson at 135 East Penn Street, Carlisle, PA Cumberland County. 01/08/2013 05:24 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be TAMMY WILKINSON (WIFE), who accepted as"Adult Person in Charge"for Nathaniel Q Wilkinson at 135 East Penn Street, Carlisle, PA 17013, Cumberland County. 03/06/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/1/2013 03/07/2013 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Mark Udren, on behalf of xxxxx. xxxxx, being the buyer in this execution, paid to the Sheriff the sum of$ 04/30/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/10/2013 07/09/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/2/2013 10/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,092.74 SO ANSWERS, October 02, 2013 RONR ANDERSON, SHERIFF )9i/3911/ i,c)Cour4Suite Sheriff:Teleosoft,Ire. UDREN LaW 'OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com Option One Mortgage COURT OF COMMON PLEAS Corporation CIVIL DIVISION Plaintiff Cumberland County v. MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129 . 1 AND RULE 76 Option One Mortgage Corporation, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P. C. , sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 135 East Penn Street, Carlisle, PA 17013 1. Name and address of Owner (s) or reputed Owner (s) : Name Address Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Tammy Wilkinson 135 East Penn Street 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 Hudson United Bank 1000 Macarthur Boulevard Mahwah, NJ 07430 4 . Name and address of the last recorded holder of every mortgage of record: e.. - Option One Mortgage Corporation P .O. Box 57038 ,- .. rk.9261y pig 1 Richard,B., Steffy and 346 Veterans Way Darla H. Steffy Elliottsburg, PA 17024 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 Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7 . Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address ' Tenants/Occupants 135 East Penn Street • Carlisle, PA 17013 Internal Revenue Service Technical Support Group, William Green Federal Bldg. , 600 Arch Street, Room 3259 Philadelphia, PA 19106 Atty General of US US Dept of Justice, Room 5111 Main Justice Bldg. , 10th and Constitution Avenue N.W. Washington, DC 20531 U.S.A. US Dept of Justice US Attorney 615 Chestnut Street, Suite 1250 Philadelphia, PA 19106-4476 I verify that the statements made in this affidavit are true and correct to the best of my information and belief . I understand that false statements he ,are made subject to the penalties of 18 Pa. C. S . sec. 4904 relating to unsworn falsification to thortes p. fti DATED: November 201' 1,_, UDREI�. LAW OFFICE , P. C., //Z./CO BY: l/l.. r A g sL�f� ? , L ,laintif f�/ PA. ID 3090c`: UDREN LAW.O, 'FICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com Option One Mortgage COURT OF COMMON PLEAS Corporation CIVIL DIVISION Plaintiff Cumberland County v. MORTGAGE FORECLOSURE Nathaniel Q. Wilkinson NO. 03-1253 Tammy Wilkinson Defendant (s) NOTICE OF SHERIFF' S SALE OF REAL PROPERTY TO: Nathaniel Q. Wilkinson 135 East Penn Street Carlisle, PA 17013 Your house (real estate) at 135 East Penn Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff ' s Sale on March 6 , 2013 , at 10 : 00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $60, 830 . 57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff' s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) • YOU MAY' STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue. Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 � ti� y:t lw tJece.. _wer•-:i"sl.-.. _+4... a. ylUX'i.:' ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON, ERECTED SITUATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY AN 18-FOOT WIDE ALLEY; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KELLER' S HEIRS; ON THE SOUTH BY EAST PENN STREET; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF JAMES C. • HOLMES, HAVING FRONTAGE OF 20 FEET ON EAST PENN STREET, AND EXTENDING IN DEPTH AT AN EVEN WIDTH OF 120 FEET TO THE ALLEY AFORESAID. BEING KNOWN AND DESIGNATED AT TAX PARCEL NO. : 02-20-1800-203 IN THE DEED REGISTRY OFFICE OF FULTON COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 135 E. PENN STREET. UNDER AND SUBJECT TO COAL AND MINING RIGHTS, EASEMENTS, RIGHTS OF WAY, OIL AND GAS LEASES, COVENANTS, CONDITIONS, RESTRICTIONS, ETC. , AS THE SAME MAY APPEAR IN PRIOR INSTRUCTIONS OF RECORD AND ON THE AFORESAID RECORDED PLAN. BEING KNOWN AS: 135 East Penn Street Carlisle, PA 17013 • PROPERTY ID NO. : 02-20-1800-203 • TITLE TO SAID PREMISES IS VESTED IN NATHANIEL Q. WILKINSON AND TAMMY WILKINSON, HUSBAND AND WIFE BY DEED FROM DANA H. STEFFY AND RICHARD B. STEFFY, HUSBAND AND WIFE DATED 1/18/02 RECORDED 2/5/02 IN DEED BOOK 250 PAGE 1333 . WRIT OF EXECUTION and/or ATTACHMENT CO IONWEALTH OF PENNSYLVANIA) NO. 03-1253 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION Plaintiff(s) From NATHANIEL Q. WILKINSON,TAMMY WILKINSON (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $60,830.57 L.L.: Interest FROM 5/21/03 TO DATE OF SALE MARCH 6,2013-Ongoing Per Diem of$13.65 to actual date of sale including if sale is held at a later date — 'f'/2 839.1'6 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,749.57 Other Costs: Plaintiff Paid: Date: 12/3/12 David D. Buell, Prothonota. (Seal) ` - Deputy REQUESTING PARTY: Name: PAIGE M.BELLINO,ESQUIRE Address: UDREN LAW OFFICES,P.C. TRUE COPY FROM RECORD In Testimony whereof,l here unto set my hand and the ai of said Cos rt at Carlisle,Pa. 111 WOODCREST ROAD,SUITE 200 This day of -L' ,20 /Q CHERRY HILL,NJ 08003-3620 Prothor.;:atary k-^g)14)Lt `1,>40.4t4-) Attorney for: PLAINTIFF 1 Telephone: 856-669-5400 Supreme Court ID No.309091 CUMBERLAND LAW JOURNAL Writ No. 2003-1253 Civil Option One Mortgage Corporation vs. Tammy Wilkinson, Nathaniel Q.Wilkinson Atty.: Mark J. Udren ALL THAT CERTAIN tract of land, together with the improvements thereon,erected situated in the Bor- ough of Carlisle,Cumberland Coun- ty, Pennsylvania, more particularly bounded and described as follows: ON the North by an 18-foot wide alley,on the East by property now or formerly of John Keller's heirs;on the South by East Penn Street, and on the West by property now or formerly of James C.Holmes,having frontage of 20 feet on East Penn Street, and extending in depth at an even width of 120 feet to the alley aforesaid. BEING known and designated at Tax Parcel No.: 02-20-1800-203 in the Deed Registry Office of Fulton County,Pennsylvania. HAVING ERECTED THEREON a dwelling known as 135 E. Penn. Street. UNDER AND SUBJECT to coal and mining rights,easements,rights of way,oil and gas leases,covenants, conditions, restrictions, etc., as the same may appear in prior instruc- tions of record and on the aforesaid recorded plan. BEING KNOWN AS: 135 East Penn Street,Carlisle, PA 17013. PROPERTY ID NO. :02-20-1800- 203. TITLE TO SAID PREMISES is vested in Nathaniel Q. Wilkinson and Tammy Wilkinson,husband and wife by Deed from Dana H.Steffy and Richard B. Steffy,husband and wife dated 1/18/02 recorded 2/5/02 in Deed Book 250 Page 1333. 109 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz_: January 25, February 1, and February 8, 2013 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. / ?w` 11^ Li,a Marie Coyne, EIitor SWORN TO AND SUBSCRIBED before me this 8 da of February, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY tray Commission Expires Apr 29,2014