HomeMy WebLinkAbout00-08015
MARX J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. XINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
: NO. 00 - rPOI$
C,-c>d T~
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 ~he 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 Plai*tiff. 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 17013-3387
717-249-3166 or 800-990-9108
y.mor _.
I' . ~ ,
" -'ft".-
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 0 en
persona 0 con un abogado y entregar a la corte en forma escrita sus
defensas 0 sus objeciones alas demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero 0 sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAHE 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, P A 17013-3387
717-249-3166 or 800-990-9108
'A~lWf'!'r_ .;~
- ~'--I-^^
;-
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
Isl Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry HilI, 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: GMAC Mortgage Corporation of PA
Assignee: Norwest Mortgage Inc., a California Corporation
Recording Date: TO FOLLOW Book: TO FOLLOW Page: TO FOLLOW
Assignor: Norwest Mortgage Inc., a
Assignee: Bank United, a Federally
Recording Date: 9/3/98 Book: 587
California Corporation
Chartered Savings Bank
Page: 622
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: 47 Westwood Court
MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township
COUNTY: Cumberland
DATE EXECUTED: 9/30/94
DATE RECORDED: 10/5/94 BOOK: 1235 PAGE: 979
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
'-">ll<l1l/ll!l'
,
~ ~
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.
6. The following amounts are due on the said Mortgage as of
11/6/00:
principal of debt due and unpaid
Interest at 8.125%* from 4/1/00
to 11/6/00
(the per diem interest accruing on
this debt is $21.48 and that sum
should be added each day after
11/6/00)
$95,180.03
5,177.08
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
250.00
280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $166.62 and that sum should
be added on the first of each
month after 11/6/00)
984.66
Late Charges
(monthly late charge of $36.55
should be added on the fifteenth of
each month after 11/6/00)
219.40
Inspections
Other Fees
90.00
125.00
Attorneys Fees (anticipated and actual
to 5% of principal)
4 759.00
TOTAL
$107,065.17
1-"
, ". ~~ ~
"'""'."'1
..",
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. Notice of Intention to Foreclose under Act 6 of 1974 of
the Commonwealth of Pennsylvania is not requi!ed as the original
principal amount exceeds the sum of $50,000.00.
The notice
specified by the Pennsylvania Homeowner's Emergency Mortgage
Assistance Program, Act 91 of 1983, has not been sent because the
Mortgage is insured by the Federal Housing Administration ("FHA")
and the notice is therefore not required.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $107,065.17 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
M---
Mark J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
.,.'~,
'-,-",.
''''-''j~~,~~
-~ -I
.".._"~"""""~
->rALL THAT CERTArN tra~t cf ;cr:d sit;,:(\:c:d~ lylt:g and bcdilg in IZnst PCflllsburo T<:,wl!shlpl
Cumbe,']a;:d C:;ti:ity. ~c:1l1sylva;~ia. hC:ll~de(! unc dc.<;crjbed i.~S rolJow~1 to wit:
BJ~GIj\'~I:\G :.t.1 roinl on ~:;~ I~rJrthwcslem line of \Vc~twocd Court at the dividjl~g line be!'^'cen
LolS Nos, 23 il::d 24 ns ShOW:1 011 the here:l),lftcr mentioned Plan or Lots; ~hence along silid I;ne
1\0rl/, 63 degrees 49 mim,!cs SO seconds WCSl 166.76 reet to a point at lands now or formerly
u; :'v~CH.lnlair. V:e'),' .ESlalC::i; thence n!cmg snid :r.nds !'\orth 09 degrees 09 mir,lltes 21) seconds WC3:
21 8'J r~ct [0 n j}:;i:it <It [he ~!i'Ji(~il'lg iinc br:{Wce;1 ~~Ol." ~cs, 24 (.no 25; ('~cncc fJ10;\g .:m:d ii.~c
Sr::.:th \)8 c;(:G.r~c~, 49 ,:11:1'..:~e:l 50 ~eCO;lGS E..:s~ I S2.45 feet to a pC:;:L 0:' tl:c nor[l:\'JeS"teri~ ii:!c of"
\\....:; w-:.nd eel rl, ~ilcr,:e nio'l&; ~;~(: imrlhwe~:crn 1'::10 of \,veslwooc! Court by ~ .:~:rv~ ha....;ng a
;:~{"-;l<; ."1 175.00 !:~;~::11 rtrc 11.:.11;111 ofZ4.0S :.:':~ tn a i10iJ1l, tbc rL1ce ofPEG!:-::--dl':O.
CO\T.\fj';INt; \ i 8J 9'1 SS"i1I'C reel. *'
.
~"
~.,..,.,.
-
~, .."
,'0<
V E R I F I CAT ION
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
MARK J. UDREN & ASSOCIATES
"~>il, _..,"C__
_'C'
-I"
,"
.. ,
-~
'.
~~.
~ ~"",!."l
.~.
-'="-"x.' ,,,,,.
V~'"
-~" . '. - ~-~"."~' .,.b""'~'~_"-=iIi[- ^
~",,.<"' T
o
c
u~~
rn :,'~ I
Z:J'
t?;:
~t'}
~()
~nCJ
>,:=
:z
=:;!
(::;:J
c,)
o
'T1
'-1
;~~ ;::]
8
r
'lI,Tlt'IJlIl~Wl.I":->f~~~~-"'~~.3'~h~~W~''''''~lli1J~'iHll''1I'1f'''''~!Ii'''~~~W"-~;'W""FW'''''''''';':;'':n,~>:,"",p~"Y,l''''iW'''!'fl'''''''~'''''lt'~~-R1~"!fi",r,h';'\W!.",;,,",~4"l"~~~."C'~ '.."".,.,;-
'W.
t~ ~~i3
~ 0CY0
R I
cY ~ ~
~~
........
(J\
w
~
-.fP
c:S
.....:,:
~;
",fr;
:-;~j ;:-;'1
~Ji~)
-~-~ ,..t ;
~:~1 F~
(:SIll
~
::n
-<
-0
3~
:.v
t:-
.1::-'"
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-08015 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK UNITED
VS
LAUFFER LINDA L
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
LAUFFER LINDA L
the
DEFENDANT
, at 0018:00 HOURS, on the 27th day of November, 2000
at 47 WESTWOOD COURT
ENOLA, PA 17025
by handing to
LINDA LAUFFER
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
10.00
.00
37.30
So Answers:
~ ~
r'~"- e'/< l' -'~..:-~
R. Thomas Kline
11/28/2000
MARK J. UDREN
Sworn and Subscribed to before By:
me this /.A-I-
day of
M2e.u~ ~J.lrW A.D.
C)'h" ,IJ 7/j'ViJ~,. ; ~
rothonotary ,
,-,>;mOl _
"
~ " .
W . I
"
~._~.h
,-. "
..
..
MARK J., UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGWWAY, SUITE 500
CHERRY HILL, NJ Oa034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 SoW. Freeway, Suite 14
Houston, TX 77027
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
, : Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda Lo Lauffer
47 Westwood Court
Enola, PA 17025
: NO. 00-8015 CIVIL TERM
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant (s) for failure to file an Answer to Plaintiff's Complaint
within 20 days from service thereof and for foreclosure and sale of the
mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
Interest per Complaint
From 11/7/00 to 3/5/01
Late charges per Complaint
From 11/15/00 to 3/5/01
Escrow payment per Complaint
From 12/1/00 to 3/5/01
$107,065.17
2,713.20
146020
666 48
TOTAL
$110.591 05
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 which is attached hereto.
MARK
Mark
Attor
DAMAGES ARE HEREBY ASSESSED
DATE: fYZ';:JArJ:.
fly -::. rY)f
(
AS INnI TED ~
(3M~C> ~ ~
PRO PROTHY
"1 ~ , ~-, ~~"'- :, '_~ - ,
'-'1
~ - -
--"-
<<
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
Bank United
3200 S.W. Freeway, suite 14
Houston, TX 77027
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Linda L. Lauffer
47 westwood Court
Enola, PA 17025
Defendant(s)
NO. 00-8015 Civil Term
DATED:
TO:
December 20, 2000
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
IMEQRTANT 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 17013-3387
717-249-3166 or 800-990-9108
NOTIZI~ACION IMPORTANTE
US TED 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, 1MPORTANTES . DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE S1 USTED NO TIENE ABOGADO,
o S1 NO TIENE D1NERO SUFIC1ENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OF1CINA, CUYA DIRECC10N SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENC1A LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 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 TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
L'-~_"",,, "_", ,
I" ,
0_';>"
.
_ e~
.~ .
..
MAgK 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
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
ATTORNEY FOR PLAINTIFF
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
. MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
. NO. 00-8015 CIVIL TERM
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF
COUNTY OF
THE UNDERSIGNED being duly sworn, de~oses and says that the
averments herein are based upon invest1gations 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:
SS
Defendant:
Age:
Residence:
Employment:
Defendant:
Age:
Residence:
Employment:
LINDA L. LAUFFER
Over 18
As captioned above
Unknown
Sworn to and subscribed
before me this 5TH day
O~OOLMJ~
l'Jo ary u .jf2
ame:
Title: AT
Company:
UDREN & ASOCIATES
Over 18
As captioned above
Unknown
DARLENE WlLENSERGER
HOrm PUi1/C Of NEW JERSEY
ColllllllNlon ExpIlt$12f1/2l105
-'"""';;"'l'Il1
q < .~- '"
I" ,.
~c
~
I-~ -
',"
>""', " """"~""'li'it"r""lnri'lr" il"iI HTI' "l"
..
,-.
'6q.
[ ~ (::) --.()
~ ,
Q 0 0
C> ~ ()
r ,--,
........ -00-' :x ~:}
k.J r EP [T) >
() "" i~:i:D
Zfl,f r"'"
~~ ...0 (j) ~". .;:- _::g~j
-~."
-t: r:-<:L. ,-', j
_Cl .'-~~C)
- , jU ~E ~ :l>>
z() :Jt: ~~:n
~"vv ~o - ~o
Pc: - Om
2:
r-, ~ :< .,.. b!
-- 55
-<
,{.~;;!~,:'~~,L,._ \~'i:',', ~viL:'O.-'-...l
'11,'~'j~ VJi~', ~~l ~';JfiU~
:J.rOl'l._': ,'hI ,,'\<i ,."' _...;._;~ ."..1'>
'fWU:" d ',J.~ ,.;iII,",,'lit.;;. r;~;..:,~..!:{ttth; ~f
:~r-
. _, _ '!iII!W1'W'>'"'I'~~mF_'!<""'~!;1!.l!j\\'~ffl'if"'!ff~""W;~"'-~I'IJ!'~~~~'~'I\'f"l"f"l""f;;:!;'p"l'ii,,,",j!!,,,,,W"'''''',--",-
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, suite 14
Houston, TX 77027
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Plaintiff
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
:NO. 00-8015 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
47 WESTWOOD COURT,
ENOLA, PA 17025
Amount due $110,591.05
Interest From March 6. 2001 2.120.40
to Date of Sale June 6. 2001
Per diem @$22.80
(Costs to be added) $
Mark
ATTO
./ Udren, ESQUIRE
!j:Y FOR PLAINTIFF
:;$)
^, ~
--,
.
"
rrMMIIII~_~
~
.....
~
t
(J
[
l>..,
-{)
"
Iv
-J
~~
~ D
o C>
0&
r
" ,
. ~ .' ,~-- , ~ .- --'~,-
~
o
-{l
C>v
()
/Q.
o ~,,~ w "-
"I.J"'U~;--)VJ.
~ R ~ tv 0
\; \, (\ () ()
I I j
-V
~~~'~~
~~~~f
f-I-1:
"
....
~
,
~~, ~'-'l;_~~JI!II:w!ii!~~~"In~"'_'''S,r:JSl1!',~~'l!?t~~~~~_"E5"''lllrO'"''''-~'hn",,_,-':r_' "_,,,_"~'~""';
, -~ '.,~,-- - ~'~',->~.,..,.
{'")
C
?
-Om
rn fT~
2::1'3
zr'
(/)J>
-<7
~o
::r:>...-,
z;.<
5>~
~
"""T
o
::&:
no
~o
o
-11
::;:j
Ti:;:D
"
-nrrl
;~yl
_:::::jO
;~~ 1:!~
CSfn
j;!
::JJ
-<
.r-
=
:1i:
c-
"_.-".~.=-,~
MARK J. UOREN & ASSOCIATES
BY: Mark J. Udren, Esquire
AT~Y I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
: NO. 00-8015 CIVIL TERM
Defendant(s)
CERTIFICATE TO THE SHERIFF
I HEREBY CERTIFY THAT:
I. The judgment entered in the above matter is based on an Action:
____A. In Assumpsit (Contract)
____B. In Trespass (Accident)
----.lLC. 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:
-LA.
____B.
____C.
____D.
____E.
____F.
An individual
Tenants by Entireties
Joint Tenants with right of survivorship
A partnership
Tenants in Common
A corporation
III. The Defendant(s) is (are):
-'LA.
____B.
____C.
Resident in the Commonwealth of Pennsylvania
Not resident in the Commonwealth of Pennsylvania
If more than one Defendant and either A or B above
state which Defendant is . dent of the
Pennsylvania.
Resident:
is not applicable,
Commonweal th of
(
I
n,
.D.
Mark
Addreis
\J
Ud
&
'"";-~1WT- -,.q; ""__'__"'"""_~'" "
c r
~~~_?
~1\Ii
1.
,,-- ~,,~~-, ,~"
,>~., <.~
",.
~' '-,,' ~'-- 1'-"
, . "',~"
'" ,",' ,'---,;..;;; _'~,<;;C' '",__;)~N, ','-'> ,- - -~'?""'iii'ifi~j{I''-nJIi(r:'iJIttMt~~~.nllin'f'&l' ''';.'Jc'J''mft~'''rr
o
c:.
"..
"'t1ED
111m
2::r:
2C~-
Co...!."
-<">
r-: ~:::::.;
<C>
p..
Ld
;;0
c:.
2:
::<
o
:x
:0..
:::0
o
-'-'
,-~~!
:~-kfQ
~r"'rf?
ejcj
S)(],)
-< ..
~;~ ~!i
ar'n
't;'
::0
....;;
oJ::-
:c>>
.:1;;
.!:,"
.
,)J'r,J""l~~~~i!1~'I1~~"""",!~~~~>MiW'll"~"''''BI',,,,t''',*,,,'''''rm",,,,~--;<;,,,,p~'Re.,-,;i"';""~"'~"'-WJ!'f",)"0~,iRi')-,'"''N'-e'''-'-m:r~il''''m-,",I';~._'!'''''_f.il;m'~I~~r-~~ n ..
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
: NO. 00-8015 CIVIL TERM
Defendant(s}
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
X An FHA insured mortgage
Non-owner occupied
Vacant
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
Mark J
ATTORN !
0'~_.~_.
.
'r'l --"
,.
- w
~ "
~
~-,
-~'''''"'-=
~~, ,,_"',"'~>_>_~'~._< ~" ,"'~O__. _.,_~=.
IlrU.'O~ i111Uilil?
(") 0 0
'U~ -n
::l!: :;j
CO :;:..
mm ::0 i::::IT.tJJ
Z::c
Z- ~jj!E
c?)):, +:-
----;?- ,."""
~o ". ~i~~
)>
zO :J: ~;?r)
:>0
c (srn
z c:- "C!
~ ;;0
-<
=ljt~mr~~~\W!!'\lIIF.;~'!@~~~il!tJi!lfl'll"..",~v,,-"'yc.,-_,=r;'F,",~' "--_"~"'''';--''Ni'"q"",''.ph';-~m0f'1l'i."""'"",,r~f,I;ll''''l,,eq',!~~j-'-;'--"1:P''''-Ei,.,<,,1'''f''-f'!-~'!Iir~"''We ~_" .;
MARx J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
: NO. 00-8015 CIVIL TERM
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Bank United, Plaintiff in the above action, by its attorney, Mark J.
Udren, ESQ., sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real
property located at: 47 Westwood Court, Enola, PA 17025
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
LINDA L. LAUFFER
47 WESTWOOD COURT, ENOLA, PA 17025
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
Plaintiff herein.
See Caption above.
COMMERCIAL CREDIT CORP.
3300 HARTZDALE DRIVE, SUITE 111, CAMP HILL,
PA 17011
5. Name and address of every other person who has any record lien on the
property:
Name Address
NONE
_O',Affl ~ r
,
,
~---
~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
13 N. HANOVER STREET, CARLISLE, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
47 Westwood Court, Enola, PA 17025
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 f ification to au horities.
Ud en, ESQ.
for Plaintiff
MARK
DATED: March 5, 2001
\
~,,~~'"'
~ -I '
<-,
I ~ ~ '1 '
,
'1_"
liI
~- ~,
;-"^
~. -
-,-",-""',-
- ~ ~" _.."~-~--~~
"" IDllrr'pj"
,
ii'
() 0 0
C Tl
s: :r: ::;::!
-OeD ".
nlrn- ;:0 ,7';"jIJ
Z~D ' r-
ZC -a IT!
c7l."~ ."- ::J\?
-<...,::. ':.':)C)
r:::-O "-I ~
j?;O """ ", -r,
::r: ';2(::)
-<'-0
5>c 4-rn
0
~ -....
.,.- 5:;
-<
l' ~" __.~~_~,~~~,-_,~~_"'''''''''!"'''~>ffl;('l!~~if4:l!'';I;l;~~I'INHilH!T-mf'~YF'",'I~"';i_P,~"'_.'i'-;:""-":"'''fW~~"~''''1:;;'t~-m:'!''~'''",$~%t'*'''''~Jil"l~$'l'i!'_>!,!Jj~__''''?-W__'/J_ _,,'
~. .
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Plaintiff
. COURT OF COMMON PLEAS
. CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
: NO. 00-8015 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: LINDA L. LAUFFER
47 Westwood Court
Enola, PA 17025
Your house (real estate) at 47 Westwood Court, Enola, PA 17025 is
scheduled to be sold at the Sheriff's Sale on June 6, 2001 at 10:00 AM,in
the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to
enforce the court judgment of $110,591.05 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
yon MAYBE ABI ,E TO PREVENT THI S SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immedia~e ac~ion:
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.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
'~,
I' ~-'. '". ,
--I
-,
,~
YOU MAY STILt. 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 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The ,sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
-CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
T;"\-'ffiJi~IU"c!-!_ 1_,
~- < - IT' _"?-, -
,~
-
r1
ill
. '^ ~ ~ '",-''-''M w'"''''.","''*,J"",-~, "0'--
.-~,,,,,,
1'"
j'U:11n
(") Cl 0
C -1'1
s.: :Jt
'UCD ;po -~.:: -n
CPQ; ;;0
Z-:o~ "F
--.-n";
6)~> ~ -;r--i
~---.- ::--) ..~....
kG' ~:",c)
> ,~~~
)>c ::I:
ZCl
;p- c5rn
c
Z '-1
=<! r:- ~
~~
~n~~"'i\ijI'l!Fl~"'1'_"-"T-c<~m~BWY.$!;;;;!I[""~'f'l~"II,'li!"T""'l"";c;""'''':~'T'''''f'-''''''''F..:~ i"'.'~ ';"~_'_'<>'f"{"'F;"""";~n"f,C"~F,"""""'"'"'<if<."''C~''''-'-""""~'''~',"'I''':'''-~I_~~W-~~Jl'i!iIIi!'_ _, .,,~__'
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CaERRY aILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, suite 14
Houston, TX 77027
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
v.
Linda L. Lauffer
47 Westwood Court
8nola, PA 17025
Defendant(s)
: NO. 00-8015 Civil Term
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which
is attached hereto as Exhibit "A", was sent to every recorded lienholder and
every other interested party known as of the date of the filing of the
Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which
was signed for by Defendant (s) on the date specified on the said Return
Receipt. Copies of the said Notice and Return Receipt are attached hereto as
Exhibit "13".
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 "13".
4. If service was by Order of Court, then proof of compliance with said
Order is attached hereto as Exhibit "13".
All Notices were served within the time limits set forth by Pa Rule C.P.
3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: May 8, 2001
MARK
BY:
Mark J. dren, Esquire
Attorney for Plaintiff
'!fY"_~'fl
, -~-
..11
~..
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
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
NO. 00-8015 CIVIL TERM
DATE: May 3, 2001
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): LINDA L. LAUFFER
PROPERTY: 47 Westwood Court, Eno1a, PA 17025
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on 10:00 AM, at June 06, 2001, in
the COMMISSIONERS HEARING ROOM, 2ND FLOOR, CUMBERLAND COUNTY
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.
t, EXt-IIBIT A
Ii,,-cc,,,j;
,~r~ ',,,,=:,,__~ ~
'~1
"
, '.
.
. ,n --'.
.eBIP"iio
~ ~F E ~
!tUig~~
III D.Lrl=_
~8~~~
'Eqa;o~.!:1
~~~~~ e
].!!!:ii ~ ~ ~
E3fo~:1
~1::1P1P""'.!!l
.~ ~~~'ii~
Illlllai ';:!;'S
e.E::z;8"iii_
lD6I1li:5'C
~._ III '-_ C
~'Ge::J1ii1'll
=.5 ~~ E'E:
ElIlw~B:C
'C 8 6 ~E B
EelDD.g:~
~'E:g"iii~6
a III >.:5= >.
e5~'6.E8:
~ 8~;co:
o'C c.... QI
'ii'i'ii ~~u 21
~::Z;'C'E~~
'E gj.E 5l~ ~
'-e5=ec
]~~E~-;g
,g Qi fE8~
:l~lIl~lD:m
~;F'6l::~
'C- .1Il....~
~~8:::~ .
cE~.e8'iij
o 8 ~ go E
ijl'Cts~~~
.~~ ~~gg
W ~ ~.!l ~ E
.!l ~gS~B
~~~t.e.E
~ 0 0 ~.... 6
P-5~>'~ ~
c: o'E~e
,gljHe~
i~,:]~o
~11.9Ea;
'Can::J(/)
ae!~~g
QllIl ::J ~O>o:
FE-IIll::
~
~ w
";,,,
Q) E
o ~
~a:
0::
cmIl
~
, Ui!E~H~
III "
tll...=
"o.c
~- w
iio;S
!!J. 01_
_co
'e~ m
CD e'Q.
""_ 0
0.00
EB'ii
SlJ5
:=:2
='t:"
<C~~
- c-m
.9<uju..
~
'" .
'().~m
~ et::u..
<'!
i ~
."0
~ ao
g ~~
" ~-
o!;o
e~
~ i;l'i
mC..E>
o e
c ~
e!IIlCD_
~..E ::::l cti
.!! 1Il_1ii"5:l
tll~..Etll>m
'C '(i- fij .0:;:
Q.~ tll 0 t;_
e iii Q, <(:::;:..
8:-g~~
co~.s::.c:
...__..... Ol
- 1Il'-ii;: c: CD
~"5:l~:> == ~
c3~DD~5
:I:
~
.Q
.><
o
o
:0
C
Gl
Q.
-
c
'0
Q.
iii
III
~
o
.><
.E
.->--.--"-"""_.,,-...
/: ~.:~ ,'.:.i,}:>:..
1,:'-.>'- "~'" ~","
'/ ' , . >,
"',::' , ')"h
..~!, "(',\
::h ~':.' ,,'" : >
\\r:,:"',
,-f:,r-.-. ./,'
~/
.:
Gl
-
.;:
3:
..
Q.
~
,.,
.t:J
"0
..
-
Gl
1i.
E
o
()
..
.t:J
-
UI
il
-"";;1' LL
-
~R'4:~~~~.r~POSTAGE' 'I~,l'
3 MAV','OI:::-!f:if ;'Iii::: I ? 5 :::
\. r~m-.c.._iIl
N'J P.IU.!I:.1ER I t':
_ 670i~' "''!
~
.E ~ CD
:e. -c :
CI) lll=
~CI)~~-
.!!! U III CD I,
I:: -c lP III C)
:; ~o::: l!:! tll
a;:.c~ Q, iii
o:::e:E~ ~
D:1iDD
!/
, /
/
/ '
/
~
~
Q
~
ILl
'"
.S
.>
~
~
0::
~
o
"
S
~
"
0.
oj w S
> oj 0", 0
w ii: z. z
w 0:: <0> w
e 0 < '" -0
" w W -I' Ii
11 :::J > 0."
-I a 0 ::;;::!
< :::J
B 0 m z 0.... 0
is m w < o~ 0
?- m :I: ...<
0:: :::J :Z 0":. 0
;; < 0 0
0 :I: :I: '" :::JCl ~
0. I- ~ <0:: /
o~
" o~ 0:: Z w:::>
c ",0 :::J 0:: !XI
= "'.... 0 0 :::Jm m
~ i='" w
;; 0. 0 o~ !Xlii: 3:
e 0::< ~ w~ -0:: 1/
0; 00. >< ....
o - I- m~ ~:I: .
,; -I 0. m< m
~ 1--1 W Zo. ..... I-
w i3~ 0'" Qw O. z
w ~
e Wo. ~~ 0> <
0::::;; 1--1 1-0 0.
" <m 0." /
" 0< I-~ -1- wN :::J
-< -10 w< w-l 01- 0
'0 < - !;(D.... 0::0:: _Z 0
~ u~ < <w Q
I-W 00 0.::;;
E 0:::: i= - m"
= m-l ...1- I-N
w.. wm ml-
z ::;;w -I::; WW 00:: ZO /
::;;W ::;;~ <~
::;;1- <0:: ffi<
05 w< O~ Ow
om 0::0 om 00 1-11.
"
~-c -c
-m m
.!!:: !5c~
~IIlO'5i
O:::J:(.)(,,)
DODD
'"
:5.
U) It:t~.
W~ClO
t-!:::O
<::>>-
en-rqw
w O() >- en
() D:
;:;:en;;!;w
LLU)~~
0<:1:;:
;:o!l!;!w
crZ:l:Z
...J!!lcn ..J
~l.:l
C:z:::!
:::J\,:>:I:
.... >-
..., . D:
) ~:z: D:
; a: '" w
cr~:I:
::;:,..u
~ ~
w
=
.5
w
o
11.
,
w"
" 0
0=
.~o
0._
_ w
00
~o.
~ii '<t
E" m
~ ~ Y\ m
z> ~
-;;
Sg ~
~o:: m
2
w .t:J
Q)
" LL
u
~ ,.:
0:::...
-" .....
0" co
~M M
E,., E
~.c 0
=i LL
N M '<t '" .!!I- en
0'"
~ ~ ~ ~ 1--1 a.
0
Z
~ j
" ~
'O.c o::...i 0::
:e~ w< ~ w
-<z "'0 '" !XI
N ::;;
:::Jz N
<- 0 :::J
-1-1 0 0
~
c 0 ~
::l ~ N M .... '" co ..... to m ~ ~
~
"C"'~
c:"'~
mOl
Ol~
E:g Cf.l
~<(o
,
~j!,!~
.
11-1'1 ~,
>l
~'
,,- ._nO"""",_,_ ~~~, "4",'''''''_
"^ "''"r'l.'~1i Uil?fI1i'11T'il'V '
qIEf
fi~~",
t:5 e~,:
::i>
~E~'
Pc
L'~
~
()
<:;:::
..:-
a
(....,
-~71
:R:
-.:;
h:_1
'~
^>
-, !'~',
~ sj
~-;~)
l~1f~l
_,::1
::0
-<
""T1
, ,
':'";'
./;:""
"l!il!!I~III_"""_.~!f;!1i~~~~Nl!;~m~ffi*'l'~~n~~i'1j!1l!\fff*.~-';!''1fJi''!l'N~"'':~'-,,,""'''N'!'it'''''~,:._''''Pi~,:""",,,'~;~'''~~;F'I?F1;;'-'' "!;f'F,j'l,n;"","",,,,,,j<'!"-'~","'f"I'~'F_~I~J}'~':~',
~~u
Bank United
VS
Linda L. Lauffer
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-8015 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.
Sheriffs Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
20.00
]5.00
.50
1.00
25.09
]9.84
]5.00
]5.00
.89
]2.97
20.00
260.75
225.60
$661.64 paid by attorney
8/31/0 ]
Sworn and subscribed to before me So Answers: ~ A
This~dayof ~~ R.ThC~:rifft'~ ~
,
200], A.D. n.n,,,, (), /u~/~' ByA~:J,5VV1.~
~otary Real Estate Deputy
""Nf,JIl:~ ~
,.,~,~ -" ~I~ '" -,
> 1,:,-1)
"'~8'dJ
C./:2.,-=
~11(";2.7 <)
...
,
:"'" ~- ,
.
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
: NO. 00-8015 CIVIL TERM
AFFIpAVIT PURSUANT TO RULE 312~.1_
Bank United, Plaintiff in the above action, by its attorney, Mark J.
Udren, ESQ.. sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real
property located at: 47 Westwood Court, Enola, PA 17025
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
LINDA L. LAUFFER
47 WESTWOOD COURT, ENOLA, PA 17025
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
Plaintiff herein.
See Caption above.
COMMERCIAL CREDIT CORP.
3300 HARTZDALE DRIVE, SUITE 111, CAMP HILL,
PA 17011
5. Name and address of every other person who has any record lien on the
property:
Name Address
NONE
Aj~;;!i~
,~", " ,'r<"
,
.
-....,.
.
.
.
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
13 N. HANOVER STREET, CARLISLE, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128~0946
7. Name and address of every
knowledge who has any interest
the sale: '
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
47 Westwood Court, Enola, PA 17025
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 f ification to au horities.
MARK J
DATED: March 5, 2001
I
,
I
Mark Jt Ud en, ESQ.
Attorn\y for Plaintiff
\
,~
,'" ~<,
'j "r
"'.--
,\-
.
.
.
~
MARK J. UDREN &: ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
COURT OF COMMON PLEAS
. CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
: NO. 00-8015 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: LINDA L. LAUFFER
47 Westwood Court
Enola, PA 17025
.
Your house (real estate) at 47 Westwood Court, Enola, PA 17025 is
scheduled to be sold at the Sheriff's Sale on June 6, 2001 at 10:00 AM,in
the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to
enforce the court judgment of $110,591.05 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 imm~diate acti~n:
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: (956) 492-6900
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.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
r,~
~ ,-" '.',," - I
C]
,~ . ~
,~,
,
.
<
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 856-482-6900.
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 afte~ 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 LISTEJ;l BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
-;'~ ,~
- ,
I,
i-
" 'T
of"
.
",I l' ~ '~> - ~
.
.
ALt THAT CERTAIN LracL oC Jilnll ...iLuriLAo, lying "no hAing
in ]\ilSI:. PF.nn...horn Town...hip, Cumh",rlnn,l Count.}., P",nn...ylviHliri, hounllp.1l
ilnd cl",..."rihell "H foJ lowfi, ~.o wi,t-.:
flr.GTNNfNG ill. il fJni nL on t.hp. norLhwHHLp.rn 1 i nH of I'JH...Lwoocl
CourL ar. t:hp. divilling linA beLwp."", LoL... No.... 2~ "nil 24 "... ...hown
on t.he he.re.i.nafLAr IlIHnLi'H1Arl Pl...n of TooL...; Lhf'HIl'''' ...long ......i"J linH
NnrLh fill d..grep.H 49 minul:"... ;'0 ...",,,,',nll... W,~...L lfifi.7fi (,.,,1'. Lo " poinL
fit liindH now or fOimr.:rl,:i or ~'1ulJnt.n'i.n v.ip.w r.~..d.nt.AH; I":hAncH iilnng
fiaid l;;ndH Nnrth,09 O'Hgr"",,09minuLe... 20 H",r:nnd", ~~p....L 27.BO f",ed.
t.o a poi.nt:al:.,l..~,''''' ,rividingli.n",hHLwp.p.n TooL... Nmi.24 ilnll 2;'; LhHnc",
along sai<lJine Stlllth fiB IIp.grp.p.H 49mirluL",l'i!}0' fi.."ondH EnHL, 1112.4;'
"; feet f".n 0- polrltJ;orr' thf! nort.hwp.RI:p.rrr'l inp. (j r W?Rt:wi'Jod r.O]J rL;' Lh"rll:H
a J ong Lhen'1TLhwes.f".ern J)"" 0 r:' \~est;';ooll Court-. by .... "urVA, hnv i ng
a rdcliusoT175,.OO [A;',r.dnarc:.,)f'.rlgl".h of 24.011, [",Pol. t.o i; poi nt,
r.hA pla,,:<offl\iiC,.f\'lNrNG., '
,< " "" ,1...__",,,,,, "
CONTATNTNG4,'lIl3.94 "qudre fep.L.
----"'""-..-,.'------;-'>-..
~...,:
.'~.
"~
,...,....." ,"~ ",,<._,,:,,;?~::;]
BEING KNOWN AS
47 WESTWOOD COURT, ELONA, PA 17025
09-12-2992-081
TITLE TO SAID PREMISES IS VESTED IN LINDA L. LAUFFER, SINGLE PERSON BY
DEED FROM EASTERN DEVELOPMENT & PLANNING, INC. DATED 9/27/1994 AND
RECORDED 10/5/1994 IN DEED BOOK 112 PAGE 1045
PROPERTY 10#
'j
- '"-,J,,,, ~_~,~
,_.~,'..
".- . , ,. ,~~, _ ~ ",' " , E
"
lIlt:','c"'"
.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONW~~l.[fH Of PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-8015 CIVIL lUX TERM
CIVIL ACTION. LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt, interest and costs due Bank united
PLAINTIFF(S)
from Linda L. Lauffer, 47 Westwood Court, Enola, PA 17025
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description
(2) You are also directed fo attach the property of the defendant(s) not levied uPOI1 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/are 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 ofthe defendant(s) notievied upon an subjeclto attachment is found in the PO!\session of anyone other
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due S110.591.05
from 3/6/01 to 6/6/01 per diem @
Interest $?? R() - $? 1?() 4()
Atty's Comm %
L.L.
Due Prothy
Other Costs
$.50
Sl.00
Atty Paid
Plaintiff Paid
S109.30
March 14, 2001
Curtis R. Long
Prothonotary, Civil Division
4n"r ~ - P 7j>7/?~ r-
Deputy
Date:
.by;
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address: 1040 N. Kings Highway,
Cherry Hill, NJ 08034
Attorney for.: Plaintiff
Telephone: 856-482-6900
Supreme Court ID No. 04302
Suite 500
-<;~
,-
l'~ I
--~ -
,
~'1'Ji;:~ij"*Y.
'", ,
- """,,--
"0
.
REAL ESTATE SALE No. .;) '1
~
~
~
I
i
uil 11 ~ /5 J a. DC> I the sheriff levied upon the detenoarils
Interest in the real property <;jtlJ?~ed in I'o.-o.t- -Po,f1~J6WMAip
Cumberland County, Pa., known and ,lumbered as: L}7 u..r~ Uwct
Cflaf!.a.- and more~lly described on Exhibit "A" filed with
this writ and by tms reference incorporated herein.
'"late: f1a.,u)L I '5, ;;l 06 J By: ~ LWu.- .
~1lj ,~~
" ,c,~~")t\
, ~,\t v ,.r,
~1" ,","N',"
-q\ '~,'\c, 'S\ \~
\\~ ':l t ~\.I<~''J
\(\ ,,'\ ,,",' <~~. ~~o
", ,\}' " ':':: " ,,':.\
, " _~'J:' ~,>!iJ
~~", .,.,,~
J~\~1>"'~
...._~_~, ",_,~,w~~~pwIl~~"'_,__c"~~~"", _~~ _ "
, ~l'I'J',t~~fJAl[',,;~~"'"="""'f"lff':fl"~~"'J;""'"'\ry't*!ImI"';''':\'TI1<'W'<ffi'^l''''''''~''_''''~,g;1'1l"-ij'_~~~"
~- ,., "EArESTAre~AUrNo-:-27
W,ft No. 2QbQ,ao15
BankUnfted
VS
Unda L Lautter
,AttY::M~rk ~~ten
DE5C111PTlDN
, ALL THAI CERTAIN'tract of land :;ituatecilying
. and being ill t..lSt Pennsboro, Township,
Ctimberland, Co~n:!J~ r-ennSylvania; lxluridcd
. ;m'd d.escribed a~Jt.nilws, to wil: ,.,
: BEGINNlt\G at a po,in! on the northwestern line
I of ,West'Noad Corid, at the di~iding line between
i Lots Nos. 23 and 24 as shown on the hereinafter
, menHoned Plan of Lol~; thence along said line
North 6R" degrees 49 minutes 50 seconds. West,
, 166,76 feel, to a polnt all.mds now or iormerly of
~fountain View Estates; thence along said Jands
North 09 de,liI'~:;: ()9 minutes 20 sewnds West,
, 27.'80 f~t to a polnl at the diVidIng line hetw~n
: Lots ~os, 24 and f3; lhen,e illong 5i'Iid line South
68 degrees 4Y minl.\tes 50 seconds East; 182.45
feet to a point on the norihwestenr line of
'Westwood Courl; thence along the northwestern
line of Westl\'oo4 Court by a' curve h,:!\'ing a
radius of 17;.00 feet an arc len~h ,of 24.08 f~~~ "!'?',"
-:,:?a:'pOl:nl, the place of BEGINKL"1G. '::,",:\ c,':.
:>:::~~'t--;TAI~f.\lG 4.,183.94 sq'uare feet. ,,::,:.,:':'}:::::,
t." . ~~,9i.:Y~f.:,~.~~:?:.:W~Y~.9,:..P.),u!t,.,~~PJ.~!:,
'!d)H.''ffJ2,~ , """""
I::::,: , ' " AID pieri.1isf.'S 'is Vf~'e.d ~n U.M~ ..1.;. ,:-
~'::::,{)j:qtr~ si~~'~,:,}'e'rson, by: Ueed II:Qm.,_~J~ttl,':"
:::- Ol;:~ekip[he'nf &: rlannlng, Inc. dated 9f27/199~
<:a:rid'iecorded 10/~J19941n Deed Book 112 page
l_:t..~~~ -_._-<_.~----_.
""
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
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager 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 Sundav 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 24th day(s} of April and the 1st and 8th
day(s) of May 2001. 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 stockhoiders 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 iiscellaneous Book "M",
V;I~::I~:~~~~' ...........................<h...4.......................................................
COpy . this 21st d of M 2001 A.D.
S ALE #27 Notarial Sool
rolty I.. Russoll, Notary Public
Henleburg, Douphln county
t.\yCOml~lsslonelqll...June6.2002 N TARY PUBLIC
Membor, Penn.yNenle AsSOCIation 01 Notari~y commission expires June 6, 2002
,
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 $
Probating same Notary Fee(s) $
Total $
224.10
1.50
225.60
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.
B~...................................................................
-.1i,*"f_~
~..,
~I ' r' ~ 0 r-
-.
,~ .~
.-'
'-
, ~-
-. ESTAIllE SM>E NO. 27
Writ No. 2000-8015 Clv1!
Bank United
vs.
Linda L. Lauffer
Atty.: Mark Udren
ALL TIiAT CERTAIN tract of land
situated, lying and being in East
pennsboro Township, Cumberland
County, Pennsylvania. bounded and
descrtbed as follows, to wit:
BEGINNING at a point on the
northwestern line of Westwood
Court at the dividing line between
Lots Nos. 23 and 24 as shown on
the hereinafter mentioned Plan of
Lots; thence along said line North
68 degrees 49 minutes 50 seconds
West. 166.76 feet to a point at lands
now or formerly of Mountain View
Estates; thence along said lands
North 09 degrees 09 minutes 20
seconds West 27.80 feet. to a point
at the dividing line between Lots
Nos. 24 and 25;-thencc along said-
line South 68 degrees 49 minutes
50 seconds East 182.45 feet to a
point on the northwestem line of
Westwood Court; thence along the
northwestern line of Westwood
Court by a curve having a radius of
175.00 feet an arc length of 24.08
feet to a point; the plae of BEGIN-
NING.
CONTAINING 4,183.94 square
feet.
BEING KNOWN AS 47 WEST-
WOOD COURT, EWNA, PA 17025.
PROPERTY ID# 09-12-2992-
08!.
TITLE TO SAID PREMISES IS
VESTED IN LINDA L. LAUFFER,
SINGlE PERSON BY DEED FROM
EASI'ERN DEVEWPMENT & PLAN-
NING. INC. DA1ED 9/27/1994 AND
RECORDED 10/5/1994 IN DEED
BOOK 112 PAGE 1045.
'""
0.-
, ,
,-
",'
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, 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 ofthe said Cumberland Law
Journal on the following dates,
VIZ:
APRIL 27, MAY 4,11, 2001
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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~hal'Ed;;
SWORN TO AND SUBSCRIBED before me this
11 day of MAY. 2001
,N ,SEAl. '" ,
LQI$ E. SNYDER, NoIaIy Public
CarIIIIe.Boro.l:umb8r18iid ~" ,
" ~ Commission ExpiI8s'March 5.~
';'._~,-
, ,
~
-
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
3200 S.W. Freeway, Suite 14
Houston, TX 77027
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
NO. 00-8015 Civil Term
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Linda L.
Lauffer has filed Bankruptcy in the Middle District of Pennsylvania
on June 5, 2001, Bankruptcy No. 01-03218.
^
--
Mark J. Udren, Esquire
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
,;~-~,~~ ," ~...,.~"",
, r
, I
'<
"
"
~. HI
tJl::~;
rrq' '
:<:::J"':
~C;
~~(:~:'
);.-. s::~.~
".:..
~
C)
,;.
C:J
, ,
I:
'-,'
)~\
~~ :_-)
'- ) ,~~~
~{l~
(n
C',
'''0
t
C-',
r:...:;
,',)
..-.-"
.~, ~~I[,*"m~~ ~~~ ~~,,~"'~~ffiffiIl!""'0'~,!''!mI['W-j',f-:;l'"~~'''_'\"~''''';;,,"rr;,;'!i\!i'"*~>i,~ijil~'!'~WM'!!!L~~I!'i!!i:j:~_
-""" ,
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank united
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
. NO. 00-8015 civil Term
Defendant(s)
PRAECIPE TO ISSUE WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$110.591 05
Interest From 3/6/01
to Date of Sale March 3. 2004
Per diem @$21.48
23,499.12
(Costs to be added)
$
MARK J. UDREN & ASSOCIATES
~ Esquire
ATTORNEY FOR PLAINTIFF
''d.'1l>l~ _~ ,~ _._~~_ ,_
~~r
"I
=~
141
rU
~
r ~
~ 1L~ ~ ~ ~6'" "t<l..
(,.j ~-Olrlr:<.v.......
~ t . . . ~ ~
-:- ~ 00,",6"'"(.,,6.-
('i) .......::0 0 Ce0..c::Co-
~<:: ~ , . I I
S~~ [) ... r~
~ ~ - -
- ... ~
...
-
e. ... ~ - ... ~
...... .... -
-j- '"
V
~
'[ " "
~~ "'-
o
c:
-uti,
rnn-:-
~~:
c:c
d?;C-:'
~o
C
-7
~
-.,
--1.
n...
o
(..,.)
;;;e:
C;:)
C,C:
o
,.,
:-.3
"_i-:, :::n
"~
~g~:J
~ ~-i~ ~;~!,
';~~~
~~'
~....~
~~
N
-0
:3';
~
'::>
...J
,~,~, W~j ~D _~~'..,..'?"_ ,.,~~i!i i!\1!~.Jl\f~~l!U\j.ll!!Jln ~ ~~~ '\'~,a~~~'<&l!'lJIl!r"'I!l,Of\'!'l'WJF"",","B'l'P"-~"'"",~"',".~,.c:'i~"'!"~~-'>i""""~'l"-'1i1'I'~f,i-1"W'''e'''''~'t~ffl'O:f''1~~!.l~Q!!!'~ft~~~I~'
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-8015 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK UNITED, Plaintiff (s)
From LINDA L. LAUFFER
(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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify bimlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $110,591.05 L.L.
Interest FROM 3/6/01 TO DATE OF SALE 3/3/04 - PER DIEM @$21.48 - $23,499.12
Atty's Comm % Due Prothy $1.00
Atty Paid $783.44 Other Costs
Plaintiff Paid
Date: NOVEMBER 21, 2003
(Seal)
CURTIS R. LONG
ProthO~ p ~
'-----By: i?4- r2.. ~ /2-' r..l.J-
Deputy
REQUESTING PARTY:
Narne MARK J. UDREN, ESQUIRE
Address: 1040 N. KINGS IDGHWAY, SillTE 500
CHERRY HILL, NJ 08034
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ill No. 04302
~~,~
'I
1 ;
-'
J
* 0<l'1'l..3'-IL
,.._..._~.._-"
UNITED STATES BANKRUPTCY COURT ..
MIDDLE DISTRICT OF PENNSYLVANIA
INRE:
LINDA LOU LAUFFER
CASE NO.: 1-01-03218
CHAPTER 13
Debtor(s)
ORDER DISMISSING CASE
AND NOW, thi{'9th day of September,
Upon Trustee's Motion to Dismiss Case (and hearing if appropriate), and it having been
determined that this case should be dismissed, it is
ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and
it is further
ORDERED that the trostee hereby is discharged from further responsibility in this case, and
it is further
ORDERED that all pending adversary proceedings in this case be and they hereby are
dismissed, and it is further
ORDERED that any outstanding fees are immediately due and payable to the U.S.
Bankruptcy Court.
BY THE COURT:
DATE: SEP.r' 9 2llB
HARRISBuRG, PENNSYLVANIA
I
B
I
FILED
HARRISBURG
PA
SEP - 9 20m
Clerk, U.S. Bankruptcy Court
-;~1~lW!l!i'F,"
", '. "I,
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank united
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
. NO. 00-8015 Civil Term
Defendant(s)
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
X An FHA insured mortgage
Non-owner occupied
Vacant
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
{:w~
^ ~
',""'1-."--"-
" ~
c
ill
if..
~_..."~~Jl,,
'=
"" 'H.,,"",<__,,_, --- I ""'''"U')!''ll''
C'
.-0,
c:.~
-~
"":)
';.:::
o
c:.
_or
.~~
..-v \~:~:
0;),,;,
~t.-
V:',
?~(->
"-
~~~"
.~,
:~(
\')
.-
."0
~
~ ..:)
~..
Cf\
"
...,~.,
.j:-;~\
-\ \_-~
t::'.()
,j~,~~\
'-:.~
~~
-':'
.-1
~~~...-"W'Il''''''~~!fi!IIIJ;~1t.1~~,'' 'Wi"_""",",!!";I",,,,,~,';'c~,,,,"''-'''''l'''"'_'},,!''<,!c)l~',~~<;"'-"J;t>H"-;MI~"W[~""'~~=4I;fi':1"~*,I'l!f.'''<1!~~i~~'
MhRK 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
Bank United
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
.
. NO. 00-8015 civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Bank United, Plaintiff in the above action, by its attorney, Mark J.
Udren, Esquire , sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real
property located at: 47 Westwood Court, Enola, PA 17025
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Linda L. Lauffer
47 Westwood Court
Eno1a, PA 17025
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
Plaintiff herein.
See Caption above.
Commercial Credit Corp.
3300 Hartzdale Drive, Suite 111
Camp Hill, PA 17011
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 St., Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
47 westwood Court
Enola, PA 17025
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
MARK J. UDREN & ASSOCIATES
DATED: October 17, 2003
'i~",....
I""'
, '
Ii:
1'1-0 ,~.~<
~,"I!>~_),jtl.
.
, ~-<< . ~l ,~~~_~__,
~f,!!lIIij!
"=~_"~_~~ "4
,,,'""'""" """." ",,,"C,
o
-o~
{Tin',
2:.L'
ZC
:!~~~.
t:.:'.,
~E)
>c
Z
::<:
r~l
0)
iiUII illfT'"!",
,
.
C)
-,-,
z
~~
"';;::::
1'0
"'0
~"
~
-";c.)
~?/~
:9
-~
'2
,:;:>
_..I
_ ~~.,.,o_"' )~M";MJ["~'.'~t1!'!'f1"'~:;;pIJ_'1!O~~~>R'-~'ffiI~"\l~~~~'~~_J!!~_";'",~~_~~_~~"._
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
.
. NO. 00-8015 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Your house (real estate) at '47 Westwood Court, Enola, PA 17025 is
scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 AM
in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $110,591.05, 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 SAT,R
To prevent this Sheriff's Sale, you must take immediate ac~ion~
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856) 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or opEm the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
',1(;1
, ,~
. ,
, """l'9T
""
,"
. .,~,~
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
~. 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
(~O) days after Schedule of Distribution is filed.
7.
back, if
You may also have other rights and
you act immediately after the sale.
defenses, or ways of getting your home
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE 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 ~70~3-3387
717-249-3~66 or 800-990-9~08
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
CUmberland County Bar Association
2 Liberty Avenue
Carlisle, PA ~70~3-3387
7~7-249-3~66 or 800-990-9~08
-<,~
~ .,
)-"
"~
,l:!'
'~~
_~" ~1il_ .c ~
"
~,'< .n"-K^""~ ~
2-
~{~~,
-/-,
":---;".'
~/ I,
():, "
r;:
~~(..
~j;. 'si
--')
-',
o
Lo)
"'::1'*
~1
<'"
-
-0
~""..
.'-~
..
.", '","
o
-n
t-f1
.:;>
....1
-on
,r:
.~ ~:~
",.--
':-:_~;~?,
~:~'~'E~)
_~.:;". i"'-"
.:~'\
~~;
::<:.
..
"nij!!!\jj~.,,,,j."",Jj.j~r'''~~Il!!~~~!fI!!l~~1[,N~''r'''__''.W<c1''''*w<~?;'~""U9!W~~'ll';;)Ji)l!l!llr~,,1Y;1<f'iI!!\Ii~fU;'mf!ll'Wil!1'~~ffil1Ii~.~
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Bank United
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
Plaintiff
ATTORNEY FOR PLAINTIFF
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
: NO. 00-8015 civil Term
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of
which is attached hereto as Exhibit "A", was sent to every recorded
lienholder qnd 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 ~f compliance with said
Order is attached hereto as Exhibit "B".'
All Notices were served within the t'me
3129.
its s t forth by Pa Rule C.P.
This Affidavit is made subject to the p nal i s 0 18 Pa.C.S. Section 4904
relating to unsworn falsification to a hor t'es.
Dated: January 30, 2004
UDR N LAW
BY:
Mark J. Udren, Esquire
Attorney for Plaintiff
''''~'
.' -
"1o'-^-'" '; -"H.;--',- "',
" -r_"__
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Bank United
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 00-8015 Civil Term
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Defendant(s)
DATE: January 28, 2004
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): LindaL. Lauffer
PROPERTY: 47 Westwood Court
Eno1a, PA 17025
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
CUmher1and County Sheriff's Sale on March 3. 2004, at 10:00 AM, at
the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle,
PA. Our records indicate that you may hold a mortgage or judgment
on the property which will be extinguished by the sale. You may
wish to attend the sale to protect your interests.
A SChedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
EXHIBIT A
^ ',~ ."
~ ~,--
_ -.~ -~~-i: v
,,>.
o
CI:l...=
"0""
~- 0
~o:2
.!!! C1::
_00
~~g:
Ql E"a.
"'_ 0
0.00
E.Bai
.!!I~O
0~~
~:e:s
<( fii
i~
.E ~~<<i
-U ~, ~ .E >
~ ~~~;
~~.E]!~g
'C"tij_ II) .J:!
~:2-! ~~==-
~~~~
CI:lS=~
-E.!!!>":; ~Ql
Ql ~>> = 21
'" ~OO-g ~
() 0:: m:.r
"U
.E ~
15.
';; '2=
o ""
II)ID'-:;:
".!! ~ 12
~ -g cc: ~
G;J!~ e-
trl:J:W
0:!100
"
~"C "'C
701>> ~
.- '-0-
~ijo'5i
e:::.5(..HJ
0000
'"
'"
~N
GIGI
--
c-
" ::s
c.iUUl
c.:.s"CM
_ tV m Q
cn"-oo
~ 8.0:: ~
lE6(;;...,
OUeZ
~_u...:
CU:C"C=
-J .loo O:X:
"O~
C..,> ...'
m 0> "-
"- 0 'r"" II
"'>~.c
::J>_U
.
"CUJas
C"'O
Ill" C
'" ~ '"
e:gro
~~O
(-:" '" 1f!Ir!,c.
.~
'" 0 ~
.::::<eJju.
~ .
'"&0:;$
. '" u.
~
" ~
. ~
0"0
1:: ;0
o en u
S. 11)....
" ~-
~O
,
~
of 0
-l!
Q5 E
o ~
"tic::
'"
'.
:I;~
en"-
.
~
"-
.
01
.!!I
o
o
a.
o
o
~
"
::i!
~
o
E
o
;;;
o
a.
"
o
~
;;
~
Iii
~.
o
o
~
-l;
::i!
'0,
~
E
~
z
~
~ ~
~E ~
t:~_
<z ~
"
...J
~
o
::;
~" ~
F
'" <Ii
o~ ]i
::10 "i
~cD (J
~N
~~
m!::
Iii
<C ~
a. .
CU 2J Ei
~ ~ 0
fii ~ j!
ii>"E Z
"'''M
_:I: ~
o
15.
~'"
O;j;
<"~
o.N
co..
E~
" -
~B
""
0"
e=a
EE
00
uu
~
,
,
,
,
,
. IQS~L9(}9 /-:-0'1
.. I lU.1.:!wad~":' _
. - 0 S' I - ,
;::: ::::j If ;I...J ;o.8ZMvr OJ
.. . il.t--;i.,\...l" J: ·
:'~9V1SOd'S'n ~l"...;-;s, 'cly.~
:. . - ~~?y.....b-=.
.."~--'- ._=--=-='.( L.:.....:_..__..__
"
.Q
Q
"
CJ)
"
.2
1ij
;;
cr
.g~
;;;0
~...
E~
0<C
00.
N
"
M
N
N
o
o
N
"
~
"
::s
0-
en
~
o
~
o
t
u
15.
"M
Q~
xo
"...
>--~
..!l<C
"a.
u; -
w.!2
..
"iii=e
.."
o:u
c:
~z.
'" C
.o~
eo
::sU
U"O
'"'
<C
a.
<Ii
"0
"
W
1::
::s
o
U
"0
o
o
~
o
~
...
"
..!l
'S
CJ)
1
11
is
"
i
"
:r:
o
o
~
" ,
,
1
" dE,
~~I'" '~~
ill, (', u"" ~~~.
':~ p~j:".,
, ,,' '<If '''1.,'
)~'.,.',!.:,""l""'" 'j;\I'''.'
J!l
"
"
0-
::s
o
o
Q
J!l
""'
"N
"0
m...
>--~
~
~
'0
~!::
U<c
::::0..
]=
eJI
-0-
.~ E
~ "
~U
e~
8~
I,
,,"
.!2~
5~
....
o
~
~
~
to
<Xl
en
'"
r--
,
,
I
N
~
,
'"
~
I
I
I
,
,
....
~
1
~ ~ J.!.E
lIIc...miliii
>.0 l1> l1>::J .
[&:615 a~
~g'~o;:;;: e
~f>'t''6 ~'a 8-
ill!!: Qjro::!;g
~g,;~~~
g~~~~=E
E ~ II) 'a E.E
-;"c: !~!!-g
E c c..1tI.5 III
Illtitr/3:re
Fgg~cn;5
'i~.!!~'iil.9
E"'.gge~
"CI e >.8"0 0
f'E [ 0 >-
Qll1>>.:E,(.J"iS.
]i E'2~"O_Jf
l[1lg E 'E a II)
i~.g:ll.~~
I:: 1lI"-=::J III
g;:;;: E 1lI ~'6
III II)::J E_ CI
~ ~.sijl6,i
'- d..~ ~ m"C
~~ E1~~
aliil!l!!l!1iii
u"Cl-... 6'[3
''iii 5 Gi.E u [
mmgoocn
g"E eg_~=
~E~~gE
iii5c~~iii
6.g-Qi-;,i~
~~~:i5.E~
:s.!!l!o!:.... ...
C'"oq[~~
l!!~g~(I)c
Sc:..,.<::"CIO
~ 0_ E; l1>
J.a~-gcoi:~
E-- .
o6=e~6
1::= 1lI::J .'"
,g~.9.5gc
l!! lIIU ~8: ~
~6~e-.9
G''''::J Ql CII_
~e,CIlF~~
.a~_~g:E=
~.sQ.~~
Gi'
}
~
'"
'"
.~
'il
8!
'C
~
:!l!
~
~
"
a.
,
II--
..5
o
o
a.
0"
" 0
Ole
.!!O
0._
'5~
~o.
.81;
E"O
~ ~
z>
mil
~~
~
,
c:
..
D-
-
c
'0
D-
O; ,
III
~
0
;x.
E
.:
GI
-
";:
~
c.
...
I-
...
..,
'tl
S
..
is.
E
0
u
..
..,
-
.,
::s
:;:
E
...
o
....
,~
....
en
Cll
~
~
ClI
OJ
...
..,
Q)
....
,.:
r--
<Xl
CO)
E
...
o
LL.
o
"
L\{)'
'0-8
~ "
. ~
E~
~.o
""0
so!!
~:3 EXHI1BltA
'"
~
-
Bank United
VS
Linda L. Lauffer
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-8015 Civil Term
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on November 26, 2003 at 7:33 o'clock PM, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Linda L. Lauffer, by making known unto Linda Lauffer,
personally, at 47 Westwood Court, Enola, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that
on January 13, 2004 at 6:45 o'clockP.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
Linda L. Lauffer located at 47 Westwood Court, Enola, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Linda L. Lauffer, by regular mail to her last known addr,ess of 47
Westwood Court, Enola, P A 17025. This letter was mailed under the date of January 12,
2004 and never returned to the Sheriffs Office.
This _ day of
~~:
r ~.....:...~ ~<.f'
R. Thomas Kline, theriff '
ByJO
Real Estate
Sworn and subscribed to before me
2004, A.D.
Prothonotary
, .-,.r
.,'
. ,:' -,. ,,-~
EXH~\a~" B
'r." R,l L L ! ~ , .",..,. ,
.~
" ~,'
'.
.
1Il
-
^' ~
~,
~,
_.,..,". .. ,JUIIJ1ilI!ll..~.,,~
^"_o_
r.lf.-~
'. ''''' n_ ""'W"'"-"hi>''''''''~''o'''"~'_ _.,
!-;~--'i
/
,]",
r-CO
..-...
);.~ ~~
Z
--;
-<
o
c
~::-
- \'~'"-~,s,:e-iUn~ifltR(~'t~t1!l "'-,,'
"'"
=
=
-"'"
."
1'1
G:J
()
-[I
..-I
F~;g
-,om
:,::.1Q
0'
_..l(~
-f-'"
~~h
~5nl
~~
f'-'
~
-0
--e.
Y?
-'
J.__IIII!/'i!~~*~Y'l;rwlPi-""'i'.\~~~~_R~~_~~.~~~a,L ,:~
ii' -
Bank United
VS
Linda L. Lauffer
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-8015 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 Udren.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Levy
Surcharge
Service
Law Journal
Patriot News
Law Library
Prothonotary
Share of Bills
30.00
689.49
15.00
15.00
15.00
20.00
20.70
237.50
232.51
1.00
29.32
$1305.52 paid by attorney
03/01/04
Sworn and subscribed to before me
~~
This ~ day of '] 'l14.u.lv
2004,A.Df)1" fA ~""~
Prothonotary
'tfil
j,
Q<.JylS',,/
~, 1'1'117/
,~ "I __ I
r"
.
.
,~.
MARK . J. UDREN &: ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank united
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
- COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
Plaintiff
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
. NO. 00-8015 Civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Bank United, Plaintiff in the above action, by its attorney, Mark J.
Udren, Esquire , sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real
property located at,: 47 Westwood Court, Eriola, PA 17025
1. Name and address of Owner (1) or reputed Owner(s):
Name Address
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
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
Plaintiff herein.
See ~aption above.
Commercial Credit Corp.
3300 Hartzdale Drive, Suite 111
Camp Hill, PA 17011
i'~!flW__, ~~
'~~. "
5. Name and address of every otherpe~son who has any record lien on the
i 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 ~state Tax Dept.
1 Courthouse Square, Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover St., Carlisle, PA 17013
Commonwealth of FA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, FA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/occupants
47 Westwood Court
Enola, PA 17025
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties'
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
MARK J. UDREN & ASSOCIATES
DATED: October 17, 2003
G:::!'j~~ire
Attorney for P1a t~ff
'c:-"
~,
MARK 'J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Bank United
9451 Corbin Ave.
Mailstop N010204
Northbridge, CA 91324
COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
"
"NO. 00-8015 civil Term
Defendant(s)
NOTTCE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Linda L. Lauffer
47 Westwood Court
Enola, PA 17025
Your house (real estate) at" 47 Westwood Court, Enola, PA 17025 is
scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 AM
in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $110,591.05, 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 MIIY BF. ABLE TO PREVF.NT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immedia~e aetion~
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: {SS6} 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the jUdgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also b~ able to stop the sale through other legal proceedings.
You may n~ed an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
-:\11!~ ,',
I"'.
.
,
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1.. If 'the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
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. Tj:J.e sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed, by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE. GO TO OR ,TELEPHONE THE OFFICE LISTED BELOW TO FJ:ND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
.;'~
c_ , I
"
ALL THAT CERTAIN tract of land situated, lying and being in East
Pennsboro-Township, Cumberland County, Pennsylvania, bounded and
described as follows, to wit:
BEGINNING at a point on the northwestern line of Westwood Court at
the dividing line between ,Lots Nos. 23 and 24 as shown on 'the
hereinafter mentioned plan of Lots; thence along said line North 68
degrees 49 minutes 50 seconds West 166.76 feet to a point at lands
now or formerly of Mountain View Estates; thence along said lands
North 09 degrees 09 minutes 20 seconds West 27 80 feet to a point
at the dividing line between Lots Nos. 24 and 25; thence along said
line South 68 degrees 49 minutes 50 seconds East 182.45 feet to a
pOint on the northwestern line of Westwood Court; thence along the
northwestern line of Westwood Court; by a curve having a Radius of
175.00 feet an are length od 24.08 feet to a point, the place of
BEGINNING.
CONTAINING 4,183.94 Square feet.
BEING KNOWN AS:
47 WESTWOOD COURT, ELONA, PA 17025
PROPERTY ID NO.:
09-12-2992-081
TITLE TO SAID PREMISES IS VESTED IN LINDA L. LAUFFER, SINGLE PERSON
BY DEED FROM EASTERN DEVELOPMENT & PLANNING, INC. DATED 9/27/1994
RECORDED 10/5/1994 BOOK 112 PAGE 1045.
-RJi",,,,~ '"
'I,
,
>r
;~!"'''7_'_!
WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-8015 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK UNITED, Plaintiff (s)
From LINDA L. LAUFFER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $110,591.05 L.L.
Interest FROM 3/6/01 TO DATE OF SALE 3/3/04 - PER DIEM @$21.48 - $23,499.12
Atty's Comm % Due Prothy $1.00
Atty Paid $783.44 Other Costs
Plaintiff Paid
Date: NOVEMBER 21, 2003
CURTIS R. LONG
(Seal)
prothon~ 2 ~
'-----By: 0",.' ~. './?,.Y. /'
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: 1040 N. KINGS IDGHWAY, SillTE 500
CHERRY HILL, NJ 08034
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ill No. 04302
'''-
I .,
I'"
.'"
!ill
. . - ^'._ -., ..0" --, -- ".,. ~" '
Real Estate Sale # 35
On November 25, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 4 7 Westwood Court,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: November 25, 2003
.~
By:J& - -
Real Est ' e Deputy
'd\ \)\j i\ \ '.
'; ',;
, , ,":\,~
C:,: "-,->'-
\,1 t.\\\\
~ \\~!..'n \ \
t; l; 1\
\_'.f
,.;, r~H'.)
3~':l:lG
J.J.~~\';;:' "-\\-,1- \U \ I
j;\(\;lD" '
'C' ~",-",,",-",,_,r'-" ~o 'M~-",,"-- Rfl"l" 'Tr
(3
I:::u:i]
1=;:;:;]
I::;:::::J
(5e)
1M
;;l~~~-
_ l ,..,<lItf~'",!!<eil"'m~~,"'''''''.'l'!~~I'",11f?Ji'<WfIj!'''l'lc'j;I'c,!m,'",,'-~:n~_'''__').''l1,,~mtffi;m1F~j(lI""'f>;*,"1:';!!<;IW,';""'!'"',:"""f'!(T_h "-'<i.e.,,':",'--". -j. ,,_,"-~';o;\';.F,'-'-'l,', '"'-;':~"F!";,,;,y,;,,'-",~~9'J",,q-0"'C!"~"!"lhf""'!'~~f'H,~~r~,~~WNPh
".;i-', .'-<",
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the 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
Sundav Patriot-News newspapers of general circuiation, 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 dally and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the
3rd day(s) of February 2004. 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 Co of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
SALE #35
REAL ESTATE SALE No. 35
Writ No. 2000-8015
Civil Term
Bank "United
Vs
Lln'da L. Lauffer
Atly: Mark J. Udren
DESCRIPTION
Sworn to and
Notarial Seal
Tony L. Russell, Notaly Public
Cily Ot Harrisburg. Dauphin COUnty
My COmmission Expires June 6,2006 NOT Y PUBLIC
Member, PennsvM1nia Association OtNo\a!ieS My commission expires June 6, 2006
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
ALL TIJAT CERTAIN tract of land situat~d,
lying and being in East Penns~oro Township:
, Cumheriand County, Pennsylvania, bouuded ana
d~cribedasfoUO'.VS,towit
BEGINNING at a point on the ~o~wes~m
line of We>twood Court at the dIvIding line
between Lot~ Nos. 23 and 24 as shown on the
hereinafter mentioned Plan of Lots; thence along
}laid line North 68 degrees 49 minutes 50 seconds
West [66,76 feet to a point at lands now or
f{)rmerly {)f Mountain View E.~tates; tlle,nce alo~g
said lands North 09 degrees 09 mmu~~ ,20
secol1ds West 2i 80 feel to a p~in~ at the dlYlding
linebetweenLotsNos.24an<l.2J;lh:noce~IOldg publisher of The Patriot~News and The Sundav Patriot~News newspapers of general
lJaidlineSnuth68degrees49mmutes:l seEOIl S _' .
E.st 182.45 feet to a poiot on fue oarth, w<>tern e receipt of the aforesaid notice and publication costs and certifies that the same have
tine of "Westwo.ud Court; tben.ce al~ng tb~.
northwesternlineofWestwo?dCo\lrt;byac~rve
having a radlus of 175.00 feet an arc lengm of
24.Q8 feet to a point, th~ place of BEGINNING .
CONTAINING 4,183.94 square feeL
BEING known as: 47 Westwood Court, Enoia,
PA 17025. 81
PROPERTYIDNO.,09,i2-29?2-0, ,
.. TITLE- TO SAID PREMISES IS vested 10
Linda L. Lauffer, single person, by deed from
Eastern Development & Planning, lnc~ dated ~1271
t994 recorded 1015/1994 book 112 ~:JQi~--
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Total
$
232.51
Publisher's Receipt for Advertising Cost
By....................................................................
~~ >~
,,",- -", , - "",",~"
REAL ESTATE SAlLE NO. SI)
Writ No. 2000-8015 Civil
Bank United
VB.
Linda L. Lauffer
Atty.: Mark J. Udren
ALL TIIAT CERTAIN tract of land
situated, lying and being in East
Pennsboro Township. Cumberland
County, Pennsylvania. bounded and
described as follows, to wit:
BEGINNING at a point on the
northwestern line of Westwood
Court at the dividing line between
Lots Nos. 23 and 24 as shown on
the hereinafter mentioned plan of
Lots; thence along said line North
68 degrees 49 minutes 50 seconds
West 166.76 feet to a point at lands
now or formerly of Mountain View
Estates: thence along said lands
North 09 degrees 09 minutes 20
seconds West 2,7 80 feet to a point
at the dividing line between Lots
Nos. 24 and 25; thence along said
line South 68 degrees 49 minutes
50 seconds East 182.45 feet to a
point on the northwestern line of
Westwood Court; thence along the
northwestern line of Westwood
Court; by a curve having a Radius
of 175.00 feet an arc length of
24.08 feet to a point, the place of
BEGINNING.
CONTAINING 4,.183.94, Square
feet.
BEING KNOWN AS: 4,7 WEST-
WOOD COURT. ELONA. PA 17025.
PROPERTY 10 NO.: 09-12-2992-
081.
TITLE TO SAID PREMISES IS
VESTED IN Linda L. Lauffer. single
person by Deed from Eastern De-
velopment & Planning, Inc. dated
9/27/1994, recorded 10/5/1994,
Book 112 Page 104,5.
-\ ~,
. -r~"
I!"
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.l784
STATEOFPENNSYLVANIA :
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,
VlZ:
JJ\NUARl' 16,23,30,2004
Affiant further deposes that he is authorized to verifY this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
30 'day of JANUARl' 2004
NOTAR lIL SEAL
LOIS Eo SNYDER, Notary Public
Carlisle BolO, Cumberland County
My Commission Expires March 5, 2005
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482~6900
ATTORNEY FOR PLAINTIFF
Bank United
Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
. Cumberland County
v.
Linda L. Lauffer
Defendant
: NO. 00-8015 Civil Term
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT
WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment
of your costs only.
~
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
DATED: Auqust 25. 2004
,,,~~...~
."!
'I ",
.'11
- ,--
-
.,,"
"
~ .~!iI~: ~.m"~""JI!!i~~I!'.,
,. ~-
---
.
--'-~"","H' ~- '_'d.n_ ,""_"""""..,,
, --~~-,-- ."""~-->",,,".,,,,,-
0 ...., ~
"'"
c:: =
:;;;: Jr ~..,.,
"..
-oLTJ c::
n"tr't" f11:,=
'zjj (;') :B1~
ZC w
U~);: Cl b
~t~~l "'" "
6'
~ -:tl
)..--;r--. :z,~,
z-
s:;O - CI ,-
"'C:: - -I
~ :E;
UI ~~
","~","","m:~'~_lfflR"l~l':~-J~;'fi\C;""":~"'';.'l")W'W''i~.!'!\Wi~~il1'W.~~~QIIIQifJlliJWllllm.._ _ "~ ";'~ 1]"!~