The URL can be used to link to this page

Home My WebLink About03-1492MARK 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 Deutsche Bank Trust Company Americas formerly known as Banker's Trust Company, as Trustee and Custodian by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services, Inc. as its attorney-in-fact 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Wilbert Pless, Jr. Juanita I. Pless, Mortgagor 36 Hope Terrace Carlisle, PA 17013 United States of America 228 Walnut Street PO Box 11754 Harrisburg, PA 17108 Defendant (s) 03- Iqgl. 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 Dersonall or by attorney and filing in writing with the Court your defense~ or objeCtions to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UNABOGADO 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 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage as of o 03/28/03: Principal of debt due ynpaid Interest at 12.75% rom 10/16/02 to 03/28/03 the per diem ~nterest accruing on this debt is $22.95 and that sum shQul~ be added each day after 03/28/03) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balanc~) ~The monthly escrow on this account is $146.33 and that sum should be added on the first of each month after 03/28/03) Late Charqes (monthly Iate charge of $35.75 should be added on the fifteenth of each month after 03/28/03) Breach Letter BPO's/Property Inspections Pir Inspections Attornevs Fees (anticipated and actual to 5% o~ principal) TOTAL $65,691.71 3,774.74 250.00 280.00 (1,024.35) .143.00 100.00 64.00 31.80 3,284.59 $72,595.49 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: Homeowners Loan Corp. Assignments of Record to: Deutsche Bank Trust Company Americas formerly known as Banker's Trust Company, as Trustee and Custodian by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services, Inc. as its attorney-in-fact Recording Date: LODGED FOR RECORDING 2. Defendant(s), Wilbert Pless, Jr. and Juanita I. Pless, Mortgagor are the individual(s) designated as such on the caption, whose last known address is as set forth in the caption, and unless designated otherwise, are the real owner(s) and mortgagor(s) of the premises being foreclosed. Defendant, The United States of America is a Defendant by virtue of a judgment, lien, or other interest in the mortgaged property. Evidence of the USA's interest is attached hereto. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 34 North East Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 04/15/02 DATE RECORDED: 04/24/02 BOOK: 1756 PAGE: 2162 The legal description of the mortgaged premises is attached hereto and made part hereof. 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 ~ailed 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 $72,595.49, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 J 04:$bm From-PREt41ER ABSTRACT +243 33g0 49.,~ T-228 P.002/002 F-083 Department of ~he Treasu~ - internal Revenue Service .~/o~ 668 (Y)(c) ~ .. · g to ~ t~ a ~ W and dgh, to addmona] penaidff. Int.,a,. ~ Yet_ f~ the ~ounr of thee . ........ t, ~d cos, ~at may ac~e. ~--, and ~ ~ ~. Name of Tnxpayer ~ ~ .~ Residence 36 ~O~E TER ~.'~' ~ :; ..('~ unmss notice of the lien is refllBd b ........ ~ ass~sment Jist~ ~ >' ~'~ ' ~::~ ::) 5~ on The day followi~ such ---- v me gem gwen in column ~e) ~r .... ,_ [o~, ~ r~ iff IRC 6325fa) ........ -ku uf release a. defined T~ Ped~ Date of ~c Day for Un~d ~ce ~d of Tax En~g ldenfi~g Numar ~s~ment Refi~g 1 o 4 o of ~S~enc 1040 /199~ 169-32-1936 08/2~/1999 09/22/2009 29. ~5 10~0 1~/31/199~ 169-32-193~ 03/25/2002 04/2~/2012 18329.14 Place of Filing PrOthonotary Cumberland County Carlisle, PA 17013 Total 19950.12 This notice was prepared and signed at ___ PITT$2URGH, PA , , on this, the~ 03~d day of October 2002 for L L~~ '~~/~~___~.~. ~ I~ ' (NO?E~~__ ~ 829-3903 23'00-0008 [aorizea o law Rev · 971 . 2 C.a. ~~edgmont~ .... ---_. · Rul. 71~88 1 Y to take Pan I . Kept By ~cordln~ O~ce Form 66'8(Y)(c) (Rcv. I0-00; CAT. NO 800~X · ~ n~, ~ nor~hwee~ 'co,er of North Mulbe~ Av~, =h~Ce in a ~es=erlv I/ne of '~lbe~ Av~ue et-hr -' - ~in= ~ tae ~reS~= f .... ~.Y-~ave (86). feec . . in '~ e,ascerl~ ~: ..... ncy-Cnree [23) ~ , lon~ =hence wesce~ lime of NotCh ~as~ Street, twohy. Cwo (22) feec co a PO~t or ~VI~ ~~ ~C~D a ;~le =wo ~d one-half sto~ brick .dWellin; ~o~ as No. 34 North ~as~ ~arcel ID No. ()2-21-D318-275 January 24, 2003 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME'FROM FORECLOSURE This is an official notice that the mortEa_oe on your home is in defanlt, and the lende, intends to foreclose. Specific information about the nature of the default is nrovided in th,~ The HOMI~OWN-F,R'S MORTGAGE ASSI,~TANCE PRO~RAM IH EMAP) maybe able; To nee ifHEMAP can help: yon mast MEET WITH A CONSUMER CREDI"I' COUNSEIJNG AGENCY WITH IN .30 DAYS OF TH E DATE OF TH IS NOTICE. Taki~ The name: addre.~n and phone number of Consumer Credit ConnselinE A~encies aervin,, your County. are listed at the end of thin Notice. If vou have anv unestions, you mav call Pennavivania Honnino ginance A oencv toll free at'l-gOO-342.~N9}. ~ern~da ~th ~mnaired This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE.EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCIOIN INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMAD0 UItOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALyAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SI~ HIPOTECA. Page 1 of 6 EXHIBITA HOMEOWNER,S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Wilbert Pless Jr. Juanita I. Pless 34 N. East St. Carlisle PA 17013 11471009 Hom_e_o~wners Loa_._n. Corp. Saxon Mo~ga_g.e. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE FJJGIBI,E FOR FINANCIAl, A,q,ql,qTANCE H'FJ,P YOU MAKE FUTURE MORTGAGF, PAVMFNT,q IF YOU COMPLY WITH THE PROVISIONS OF ~ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE 'ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, , IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARV ,qTAV OF FORECI,O,qliRE _ Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THI,~ MF, ETING MlkqT OCCUR WITHIN THE NEXT (~0) DAY,q. IF ¥CJll DO NOT APPI,Y FOR ~M~RC,~NC,¥ MORTGAC~ A,q,qLqTANCE. ¥OT I MT kqT RRING 'VOl IR MORTCrAG~ IIP TO DATR TI-IF~ PART OF THLq CON,qIIM-F.R CREDIT COIIN,qEI,1NG AGENCj E,';: -- 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 th6'date of this meeting. ~ · ' . It is only necessary to schedule one face-to-face meeting. Advise your lender immadiat~ of your intentions. APPI,ICATION FOR MORTGAGE A~q,ql,qTAN¢:~; _ 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 fi:om 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 Page 2 of 6 face- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLy. IF YOU FAlL TO DO SO OR IF YOU DO NOT FOLLOW ~ 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 AC. TION -- Available funds for emergency inortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, nO foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fried bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO C, IIRE ¥OlrR MORTGAGE DEFAIJIJT (Brine it n? to date'~ NATIIRF, OF THE DEiVAIII,T _ The MORTGAGE debt held by the above lender on your property located at: 34 N.'East St. Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following mounts are now past due: ...... Monthly a ~ ~~l~[~O/~h~!~8 for November 16 2002 through January 16. 2003 = $2584.14 M°nthl3~ Late~s of $35.75 fo~ November 16, 2002 through December 16, 2002 = $71.50 Other charges (explain/itemiTe): ~100.00 ...... TOTAL AMOUNT PAST_.DUE.. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do nnt uqe if not applleahle): N/A [IOW TO C. IIRE ~ I~FICAIII.T _ You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO TFIF. LENDER, WHICH IS ~ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa?nent~ mu~t he made. either hv ca~h_ ca~hier'.q check certified check or money order made navahh: Mark J. lldren & A.qsnclateo 1040 N. Kin_oa Hi_ohway.. Ch~r~. Hill: NJ You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not n.~e ifnnt applicable ): N/A IF ¥O11 BO NOT C. IIR1,. TgYF~ IM*,I*AIII,T ._ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, · · · . This Page 3 of 6 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 mount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.. IF THE MORTGAGE IS FORECI,OSED uPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.'00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. · · . . required to pay attorney'n fee,~ OTHER I,ENDER REMEDIE~ .. The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CURE THE DEFAIII,T PRIOR TO SHERIFF'S NAi,E - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you .qtill have the rioht to cure the defanlt and nrevent the .qale at any time un tn one hour before the Sheriff'.q Sale_ You may dn~o hv navino the total amount then na~t due_ nllm any late or other char~e.q then ~llt~ rea.qnnahle attnrnev',q fee,q anti cn.qt,q connected with the fnrecln.qure ~qale and any other co.qts connected witl~ the Sheriff',q Sate a.q ~pecifie~l in writing by the lemter and hy perforii~ing any other rea2firemenm under the mortgag~' Curing your default in the manner set forth in this notice ~ restore your mortgage to the same position as if you had never defaulted. EARIJEST PO~,'qlRI,E SHERIFF,S SAI,E DATI?~ -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE I,ENT}ER , Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person: Saxo~c_e__s.., Inc. P.O. Box 161489 _Fort Worth TX 76161-1489 ~ 874-9516 N/A Cu_s..gomer Service EFFECT OF ~I-IFRIFI*,S SAI~E _ You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and' other belongings could be started by the lender at any time. AS~qlIMPTION OF MORTGAGE .. You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 6 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 Page 5 of 6 YOU MAY Al,SO HAVE THF. RIC~HT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMEs IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRLTPTCY LAW. CON~qITNIER CRF, F}IT COIIN~qEI,IN~ AC~ENC. IE~ ,~ERVIN~ YOUR COUNTY CCCS of Westem Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Corem of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CIIM'~ERI,ANI) Cf}lINTY Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 OFFICIAL .rtl i'u TotaI.Po~tage & Feee USE ~eld 'selqenl~ ~1t/1:11'18NI ON · r"l r"t Cedifled Fee 3 Return Re~lept Fee r'~ C3 0~ndomementRequlred) 1 '''~' ~ Here ,~ (Endomement Required) ;.4i~,'~(a,-rc&~ ................................................ * ......... ~-~ ~.~.~.~_.5_~....~..~....~_~.L..5.!.:_ ........................... rmrt dV ol~pesseJppg . Sso0Oa.leUJOl&tl ,eS :.LNVJ.II0dNI lu ~ el IdlOOeJ ppg ug ,to..j · · ~reld ~eotqenreA NYurIGNI ON · Return Reclept Fee (Endomement Required) -i dV oi.uesse2ppe i ss.ooze ieu2OiUl &gS :INVLH0dNI leu :lou' el 1.dleOe. I /~eod e~ lUO ~,mwieo~ g :Il · l~: luowoe, tOl:)Ue i~Ofllppte u:e Jo,.j · · rtb~ 'rml~ el~allPe~p · ~ ee. mpu:q 'ee~. uo.::l Sd) lelqo Ol ',n.mnllep eUOlilppe ua .m..-I ,eaeld 'eelClgnp~: :)NV'cln~NI ON si IlU~ Pell~2eO · Iw trow I~ · ~UlWeld JUlrl, mduq ~op lo l:uooo2 ¥ · ll~luopj enblunv · dlOOe. I Ou~e,,, ¥ .m I finn POIJlpOO ~,- ru Total PostaOe & Fees Postmark Here · Lm Jo:! I · · Ilei~l pq~je0 · VERIFICATION 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 SHERIFF'S RETURN - REGULAR CASE NO: 2003-01492 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS PLESS WILBERT JR ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PLESS WILBERT JR the DEFENDANT , at 2000:00 HOURS, on the 3rd day of April , 2003 at 36 HOPE TERRACE CARLISLE, PA 17013 by handing to WILBERT PLESS JR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 3 45 00 10 00 00 31 45 Sworn and Subscribed to before me this 2i~ day of ~ ~h33 A.D. So Answers: R. Thomas Kline 04/14/2003 NARK UDREN By: SHERIFF'S RETURN - REGULAR CASE NO: 2003-01492 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS PLESS WILBERT JR ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PLESS JUANITA I the DEFENDANT , at 2000:00 HOURS, on the 3rd day of April , 2003 at 36 HOPE TERRACE CARLISLE, PA 17013 WILBERT PLESS JR, HUSBAND a true and attested copy of COMPLAINT by handing to MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~l~- day of V P~othonotary So Answers: R. Thomas Kline 04/14/2003 MARK UDREN By: SHERIFF'S RETURN CASE NO: 2003-01492 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS PLESS WILBERT JR ET AL REGULAR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PLESS JUANITA Ithe DEFENDANT , at 2000:00 HOURS, on the at 36 HOPE TERP~ACE 3rd day of April , 2003 CARLISLE, PA 17013 WILBERT PLESS JR, HUSBAND by handing to 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 DEFENDANTS DO NOT LIVE AT EITHER 31 OR 34 NORTH EAST ST CARLISLE. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~/~- day of lorn3 A.D. So Answers: R. Thomas Kline 04/14/2003 MARK UDREN By: ~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-01492 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS PLESS WILBERT JR ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PLESS JR WILBERT the DEFENDANT , at 20])0:00 HOURS, on the 3rd day of April at 36 HOPE TERRACE CARLISLE, PA 17013 by handing to WILBERT PLESS JR a true and attested copy of COMPLAINT - MORT FORE together with , 2003 and at the same time directing His a~tention to the contents thereof. Additional Comments THE'DEFENDANTS DO NOT LIVE AT EITHER 31 OR 34 NORTH EAST STREET CARLISLE. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this . ~1~3~ day of 0~ ~ A.D. I ~rot~notary So Answers: R. Thomas Kline 04/14/2003 MARK UDREN By: ~uty~ Sh~rI~t SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-01492 P COMMONWEALTH OF PENNSYLVA/qIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS PLESS WILBERT JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: UNITED STATE OF AMERICA but was unable to locate Them deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On April 14th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 6.00 9.00 10.00 25.50 .00 50.50 04/14/2003 MARK UDREN So ans~~~~-~'~ Sheriff of Cumberland County Sworn and subscribed to before me this ~l~ day of ~ A.D. Prothonotary In The Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank Trust Company Americas VS. Wilbert Pless Jr. et al SERVE: United States of America No. 03-1492 civil NOW, April 2, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.~ Sheriff of Cumberland County, PA Affidavit of Service Now, ,20 ...., at o'clock ~ M. served the within upon by handing to a and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this ~ day of ,20 Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA NIH ~:Jll ".,' C Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : DEUTSCHE BANK TRUST COMPANy AMERICAS us : UNITED STATES OF AMERICA Sheriff's Return No. 0787-T - - -2003 OTHER COUNTY NO. 03 1492 AND NOW:April 4, 2003 at COMPLAINT IN MORTGAGE FORECLOSURE UNITED STATES OF AMERICA to DENNIS PHANNENFSCHMIDT (CIVIL CHEIF) 8:10AMserved the within upon by personally handing 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 228 WALNUT STREET HARRISBURG, PA 17108-0000 Sworn and subscribed to before me this 4TH d?~ of APRIL, PROTHONOTARY 2003 So Answers, Sheriff of Dauphin County, Pa. Deput ~hA--iff Sheriff's Costs: $25.50 PD 04/04/2003 RCPT NO 177330 DB