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Home My WebLink About00-08438 ~ ,. - - . ~ --~'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 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 5 JANE LANE A/K/A JANES LANE, CARLISLE, PA 17013 Amount due , $63.525 64 V Interest From March 6. 2001 1. 023.00 to Pate of Sale June 6. 2001 Per diem @$ll.OO (Costs to be added) $ MARK J. Mark J ,Udren, ESQUIRE ATTORN FOR PLAINTIFF de \. ALL THAT CE:>TAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 33 on the Plan of section 9 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 24, Page 104; containing 85 feet along Jane Lane, having a depth along the West along Lot No. 32 on said plan of 125 feet, having a depth along the East along Lot No. 34 on said plan of 125 feet, and having a width in the rear along the North along Lots No. 28 and 27 on said plan of 85 feet. BEING improved with a dwelling house known -as 5 Jane Lane, Carlisle. BEING the same property which Agnes L. Frey, by her deed dated March 26, 1981 and recorded in the Cumberland County recorder of Deeds Office in Deed Book, 'I", volume -29, Page 769, granted and conveyed unto Mark A. Soderberg and Leslie J. Soderberg, his wife, the Grantors Herein. BEING KNOWN AS PROPERTY ID# 5 JANE LANE, CARLISLE, PA 17013 29-16-1096-044 TITLE TO SAID PREMISES IS VESTED IN PAUL W. MCMILLIN AND JOYCE A MCMILLIN, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETY BY DEED FROM MARK A SODERBERG AND LESLIE J. SODERBERG, HIS WIFE DATED 1/28/1998 AND RECORDED 4/18/1998 IN DEED BOOK G33 PAGE 1198 ~HimM~il~K:;;if!8f;JIHQ1;Iij!l;m--lim'-iM:f~~ti;~"~l"'<'lr-n"":01!\--,,!,;M~"~';~h~~'"--f '. "~:~JilimlI:ii!.iIii~' c - - '" ii't-~~~~~~' , ~ -.'" .'~. '." ~ "(;I.',' 1, >; . ' , " ,,,._~,,' \ ~i ~ I ~,I \' Co \ i - 2 0 0 i -S:\ ~ "On \ I cS "" :::Jt ~.,,-. .. ("l -OeD ;';"'" ~1 \ -... f1\n~ -;.",') Ie::, Z,:L' .~. , ~ z' :;~r-7 \ w-r,~ .r:- ],C} :..(L.~ GC:J -0 ::c~ \ ~ :;1: ~~o ~G \ ~ ~- ?-u r;-? Ofl1 - ~ PC: -'-4 ~\ 9-..., ~ - ~ -t:::--- - ~ w ?ii ~ 0 '< ~ 'ci 0 - .- "'~~ ~ . " '~ ~ ~"",'_H' ~ " , 1-, ""~, - -'~b", 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 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 1 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 12/5/00 to 3/5/01 Late charges per Complaint From 12/15/00 to 3/5/01 Escrow payment per Complaint From 1/1/01 to 3/5/01 $61,954.49 1,001.00 49.17 520.98 TOTAL $63.525.64 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy, of which is attach hereto. Mark . U ren, ESQUIRE Att~rney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS IND}ifl.TED.._ iJ /,,1 DATE: 3- / 4--01 ~ '& o(~ It., PRO PROTHY U U ~'~' ~ 1111I- - - L' Cll1!~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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Defendant(s) NO. 00-8438 Civil Term DATED: TO: January 2, 2001 Paul W.McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 NOTIFICACION 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, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 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,..- ,-'ow:: lL'~ 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Defendant(s) NO. 00-8438 Civil Term DATED: TO: January 2, 2001 Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN,SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 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. _"-'iIlo' -~.- ~ '.... ~, I ,.1_ ,~,_, 'i.~; 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Defendant(s) NO. 00-8438 civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Maryland COUNTY OF Frederick SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Paul W. McMillin Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Joyce A. McMillin a/k/a Joyce Ann McMillin Over 18 As captioned above Unknown Sworn to and subscribed before me this 12 day of _Jan,? , 2001' ~ . tJh1b- otary Public N~e: Den is Kieft T1.tle: V:r. President Company: F' t N t' 'd lrs a lnWl e Mortgage \\\""''''''1. '!Io\\ "\.. WAn "'- ~.. *'f;J'(\.........;:Jt.:~ $ -.')AQ",W>lh^~~ - I ~\- =;0: ~OTA~y ,p: =mi -.- ~:Z= S~~ PuSL,lC :;5~ \,"~N'l.t%fI "";; COUNi't ,~~,~ '''"111''\'\\ " ".--~~. ~ ,~~" - < ~~.. 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 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendant(s) TO: PAUL W. MCMILLIN 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 . NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 856-482-6900 ,. ,.,., ~ ' , _~. _ L ~ '"" b, .,. 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County Plaintiff : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin , a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 civil Term Defendatit(s) TO: JOYCE A. MCMILLIN 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA17013 . NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. ES~lire At this telephone number: 856-482-6900 ~~W.&ik,'!Jj,u01",.i4,.'l'iB~'t.i,,;i';I;j;*d:i~~&~tdi\.,A""',",,!,'b1'""".\;d.",:~~~i!aIl19~lIi_A~~.);.i~;lij"",w,,,'';'" j>jjj~ ~. ~, , ~,~ .~ it ~ ............. ~ --....... D- ~ ~ -..l:::--- V, \ ~ .,~. rt'. e: ~ -k. ~ . J\ ~ .~~~ ~) .. ,". ~ ~ ..4'>. "-'" ~:, \ ,'''''-/' . ~~ ~\ ~ G:). ~ ',,\ . \.---. j~ U,; I "- "'R ~ "" -...f\. ~ r (' G: i ,~~ -- ,<, -" . ..... 0 0 0 c ;s:: ,j -O'IT! 3: .-{ n1rp :> j'~~:'3 :z: ::u ::.0 ZJ:;:' " ~)~ T;m ..,.. :c'y .~ '-, ~CI --0 :,~~ ~o :A ;:~~ -0 )>~- i;.J '- 0 Z ......\ -l '" b -< \D 5:J -< " -;'"""- 00 . =" -,-"", . . .....1. '," if" '-~k 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 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: ( An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK Mark dren, ESQUIRE ATTO ,EY FOR PLAINTIFF ~~i?i:fu!)a:;}:.Mlli.fiit!\!:w"m,,"'! "';_'i\_~i;-"dj;~",~1,~'H",,!;,}k{,.~;./~~.&'''''~'-''''[Y" ...".",.i('" ~..i;;;,",~t';'M~:iit!lm.~IIi!~~~~__;",.;.,U"Jii.'!ID;:~'iiillmJilili.lI .&1illli_tI:;.1 b 0 \; c .' S. ::1!: --0 OJ :r;:... -- ~~ ;;.0 ,'G" , Zj.." _d2:l (f) -0 ~ -<2.~ .., I ~C ""'0 ~.:~C) ::~I'i ~O ;:;,;; ..~) " ::''7.(') >8 I)? Orn Z -, =< w ?o 0 -< I\;' ~'~'l~MIr~~ _~~Ij Icl~,', . ~'> '.,,,, ~ J. UDREN & ASSOCIATES '. e 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 First Nationwide Mortgage, 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: 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address PAUL W. MCMILLIN 5 JANE LANE A/K/A JANES LANE, CARLISLE, PA 17013 JOYCE A. MCMILLIN a/k/a JOYCE ANN MCMILLIN 5 JANE LANE A/K/A JANES LANE, CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose j~dgment 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. 2101 N. FRONT STREET, HARRISBURG, PA PENNSYLVANIA HOUSING FINANCE AGENCY ~~-"~. - ."~ . .......... '"' ~, Jc I ,~ " .':'L_ 'i~ ' '~-~ 5. Name and addreSs of every other person who has any record lien on the r 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 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 5 Jane Lane, a/k/a 5 Janes Lane Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MAR DATED: March 5, 2001 i Mar~ J. Udren, ESQ. Attqrney for Plaintiff ~~jo-i!ii,'~~""'-i"Ui4J~"';:it.ffi,"l,::,*:r~";~.MlI~@:iYll'&.M,'"~""',~.b;;'C'~".~..-..;,:<-""_,,",,,,;.~g~r-"~~ '.iail.li!Ui~lmj!iilili~t;t.~~" ->, ~ "., ,~ ~, " "~ ~ ~ (') c:> 0 c: -n S~ .... -- :0 ;:p.o:o .". ri"'l :;'-0 1'~~ z.~ rn Zt:,:> .l'""' ---i~\? ~~? ;',~.::\Q !.2c -0 ::..:.:-1-i - !~;;(::s ~(') ~. -m ~2. ~ ~ ~ .;..:J ~ c:> " ";'_~l ""...... - -~ . .1, '""~.~ , ' ""if". , ). 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PAUL W. MCMILLIN 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Your house (real estate) at 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 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 $63,525.64, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE-TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6QOO 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. mortgagee the back payment, late To find out how much you must pay, 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 J ,... " .li~" " / 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 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 SHOUz:,D TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 """"' ~'-- L..J.. ~1li.-i.illJ;,j;I"""WAh1;!~",:~....f~b~"...;;;;-;"!~'~Mjt>k.1N<l~'!I~"fX~.J"sJ."-,,,,!dii:,","j![1,~.J!!ji~~.il!iiMilIl~~lililtillMi'i.lliilU!l!i&!lri!"" -= ""''''''''!~P'''~''''''''''''\It.LljU .'-'....-. ''ll~ (") 0 0 C -n ~ ::x ----1 -0 , """ ~-~i,p mm :;0 z::[c zc ~ ~t'8 05-,d,~ ..- ,-",," , -<..c. .,~(') kC .." ,... -r, ~(') -',,,, ;:t;::J: ~, ~g~~ :J:;8 N u -~ :z: w :;::... =< :0 <.::> -< "',~" - ~ ~ '...... , , . -'",,-,<.l.lI"""'-"'-"""--""""""'" ~ ., 'M' ~. l> " ."""'~',,- ',MARx J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-69ClO First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOYCE A. MCMILLIN a/k/a JOYCE ANN MCMILLIN 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Your house (real estate) at 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 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 $63,525.64, 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 ABT,E TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-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 .,,,, -~ L I' n' '_ih;llll~flel""k 10b 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 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 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 ~~~.i1J;',l:"H"""""'~',<,jdd~"l,i~Mi$~\<l><;in~~>2;r,,,',,,,lk',".., t'.-~~",,,,,_. ~,~ . ,,-i~~!' _~',~'~~ ""~,,,,,,,,,_, '.'9 >'-"",,",""',' no ",(;,';" "';,3-~.t-J:;'!,j;,~A~~M~illlI!l~li8IM*~8~.~~ ,,< ~.th;.m~ni . 0 0 tJ C -('1 s: ::r.: .~-! vCJ:j ",. mfTi ::4:1 -~'1 ;;1 z::n zC;:- .~; :C1 S2:t: .co _J.~''''/ ~c' v '~:~~ ~~~ ~o -,<,~ t~f~ ~. ~o >c ~ (jrn Z W b' =< :u -< . '. , _ f .~ "--~',_ ,,; __"~, ~ ' . .liiL--; .' 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Defendant(s) : NO. 00 - rf'-lJ? CLHL '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 the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 . ., .~ .~~.. ~. - ~- ~".'''I . I " ~: - ",," I~, J<' -'''.'i~' ..,,~~ -~-~""J 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. LLEVEESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLANE POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCR!TA ABAJO PARA AVER!GUAR DONDE SE PUEDE CONSEGUJ:R ASISTENCIA LEGAL. ASOCIACION DE LICENCIADOS DE FJ:LADELFIA SERVICIO DE REFERENCIA E INFORMACION LEGAL ONE READING CENTER, 11TH FLOOR FILADELFIA, PA 19107 TELEFONO: 215-238-1701 Cumberland Connty Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 ~ - , 'u , . " , ' .__;, I_~'j _!_~, ,......t, '~'" . --ni: NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached document. Unless you notifY us within 30 days after receipt ofthis 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 Hill, NJ 08034 (856) 482-6900 M' ~ .J 'v .W' , Cldn"L'~~ 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: Sears Mortgage Corporation Assignments of Record to: First Nationwide Mortgage Recording Date: Lodged for Recording 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (gl. The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 5 Jane Lane a/k/a 5 Janes Lane MUNICIPALITY/TOWNSHIP/BOROUGH: North Middleton Township COUNTY: Cumberland DATE EXECUTED: 1/28/88 DATE RECORDED: 4/18/88 BOOK: 900 PAGE: 261 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums ,^ ~ c' --" o ~ ""d J, " "" '"" ~'li---i, 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 12/04/00: Principal of debt due and unpaid Interest at 7.375%* from 5/01/99 to 12/04/00 (the per diem interest accruing on this debt is $9.14 and that sum should be added each day after 12/04/00) $44,628.37 5,727.77 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $173.66 and that sum should be added on the first of each month after 12/04/00) 3,053.47 Late Charges (monthly late charge of $16.39 should be added on the fifteenth of each month after 12/04/00) 16.39 Suspense bal 9.47 Recoverable Bal 5,757.60 Attorneys Fees (anticipated and actual to 5% of principal) ? ?31.4? TOTAL $61,954.49 ",'--' . ~ , ~., " ~ L, ,1;:' .,,<', , ~ *This is an Adjustable Rate Mortgage and The Interest Rate and Per diem are subject to adjustment as more fully set forth in the Mortgage and Note 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit nAn, and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $61,954.49 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark MARK dren, ESQUIRE UDREN & ASSOCIATES ~ ~ ~ ~~ ,..~ n'__!lImo-, ALi,-'o:rHAT CERTAIN tract of land with the improvements thereon ereoted situate in North Middleton Township, Cumberland. County, Pennsylvania, bounded and descr1bed as follows: . BEING tot No. 33 on the Plan of Section 9 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Pag-e 104; eonta1ning 35 feet along Jane Lane. hav.ing a depth along the West along Lot No. 32 on sClid Plan of 125 feet, having -a depth along the East dong Lot No. 34 on said Plan of 125 feet. and having- a width in the rear along- the North along- Lots Nos. 28 and 27 on said plan of 85 feet. -~ ) BEING improved with a dwelling house known as 5 Jane Lane. Carlisle, pennsylvania. BEING the same premises which Agnes L. Frey I Single woman, by deed .da,ted March 26, 1981 and recorded March' 26, U81 in the Office of the Recorder of Deeds in and for 'Cumberland county at Carlisle, 'Pennsylvania in Deed Book "I", Volume 29, 'Page 769. granted and conveyed to Mark A. Soderberg- and Lesl.ie J. Soderberg, his wife, Grantors herein. .- COMMONWtAlTrl O' PENNSYLVANIA -= :: DEPARTMENT Of ~R~~;F.~.N\IE~. __~ 2 r_ il~I"~~Y', ~ . ' = _ '.......i. AP.,.',. '" 7' O. 00 = ,,..x _....... ! 1= f:e.:;!.:.' ___1_ ~ ~ -, r. <>1'" ~.~ . 'W 1 . . "";' '~--";"'~'f.t: -..-.............................__......"'.......,..........~...."'7.'......_..~-......~~___...,,,...,,_''''''''''=.....,,''''''''''',..''''....,......-..=-.~,u..,'"'"""""''''''''"''''''''''''''''''''_ ""'-'~""'..W.._"'''''''~,'''''......''_','...",''''''''.''~ II. lfATIONWIDE MORTGAGE PO, Box 9481 Gaithersburg. MD 2089B.9481 October 06, 2000 Certified Mail '" '" ~ Joyce A McMillin 5 Jane Ln Carlisle PA 17013-1035 /-/ RE: Loan No. 8816572910 Dear Joyce A McMillin : Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPl may be able to help to save Your home. This notice explains how the program works. To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counseling agency. The name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If yOU have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) . This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a laWyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion irnmediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su cas a de la perdida del derecho a--l redimir su hipoteca. . EXHISaT A DR231-003/C26 J 5280 Corporate Drive, Frederick. MD 21703 .' ,- ". ;1<-1>'.' ~..,; i: .. -'''''''''''''''''''=\\l\,"~...........~"",,,,,w.>;;.'><IU~''''\O\U\<''''''W'''''',"I>1''''''''''''''''\,,,",,,'_-\'ii''''''-~~~\l\li'JI'.llll'.!>tll~<l\<;'<l'-<'""""",\':U~\t\i'M!\'.\l.~ ~ ~~.~"J '--.~ ~ , October 06. 2000 Loan No. 8816572910 Page 2 PA Act 91 Homeowner's Name: Paul W McMillin Property Address: 5 Janes Ln Carlisle PA 17013 Loan Account No.: 8816572910 Original Lender: SEARS MORTGAGE CORPORATION Current Lender/Servicer: First Nationwide Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH 'CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEET!NG MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS aow TO BRING YOUR MORTGAGE UP TO DATE. DR235-002/C26 "- ,".. <,' ,,--,l,,; , :lIillili-. '.-------------.---...---.-----..-,.-......-...---'.-.......'.......--'"..-..--.---.....---.......--...-------..--.....~-.._-'......,....,...-,,-1 , I I I' I I October 06, 2000 Loan No. 8816572910 Page 3 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice. the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of the designated consumer credit counseling agencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. i' [, [: " ~i !! APPLICATIONS FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies l~sted at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in sUbmitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. I " !,' i YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DR235-002/C26 ~' , r I,',,' " !lii",' --.-------------.------'---.~,--,-------,-.--.-------_-.-__"._"".___~_____'___._._._____._____________.~__.__~'M_M""'" . October 06. 2000 Loan No. 8816572910 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proceedings will be pursu~d against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. I I I Ii I' NOTE: IF YOU ARE CURRE~LY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY. THE FOLLOWING PART OF THIS IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) ~ ' ~ ' HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5 Janes Ln Carlisle FA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: /8 Months at $540.31 ~ ..4.322.48 13 Months at $543.301 1~.629.90 .(6 Months at $586.29 = .13.517.;14 Late Charges J240.71 Bad Check Fees .00 Foreclosure Fees J. j. 00 Bankruptcy Fees 5.157.60 Other Fees ..-1.05. Of) / Less Suspense Balance /-- 378.57 TOTAL AMOUNT DUE /15.194.86 AS OF THIS DATE HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 15.194.86 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check. or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine. IL 60055-0107 DR236-003/C26 ," ' - i!Et "1ST NATIONWIDE MORTGAGE P,O, Box 94Bl Gaithersburg. MO 20B9B.94Bl October 06. 2000 Certified Mail ~ Paul W McMillin ~ 5 Jane Ln ~ Carlisle PA 17013~1035 ~ RE: Loan No. 8816572910 Dear Paul W McMillin Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when yOU meet with the counseling agency. The name. address. and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may call the'Pennsylvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) , This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa'de la perdida del derecho a redimir su hipoteca. DR230-003/C26 5280 Corporate Orive. Frederick, MO 21703 ~ .. t' ~ -"' ""' '~ October 06, 2000 Loan No. 8816572910 Page 2 PA Act 91 Homeowner's Name: Paul W McMillin Property Address: 5 Janes Ln Carlisle PA 17013 Loan Account No.: 8816572910 Original Lender: SEARS MORTGAGE CORPORATION Current Lender/Servicer: First Nationwide Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. DR235-002/C26 ~~ ~ .. ~ ',"" 'c;'_" '" ".'~ ,-"."""",,,,..,,,;,,,,,,,,,,,,,,"'''''-''.\P-'''''''l\,,,,,,,,,,,,,,,,,~,.-,,....~,,,,,,,,,,...-,,,,,,.,..=...''''m."""..,...<.""'<...\,,',,"',,""',"""..........\..~~~~..,,.....,..,""'''''...,,'''''''''U''=l_'5='''''''~,''''''~'u_~~__''''''''''Ui'''''"_'''''''............____........"."''...''=-''''''''....''''""....''''',.......,,'''."'"""""'...~'" October 06, 2000 Loan No. 8816572910 Page 3 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of the designated consumer credit counseling agencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this prOblem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in sUbmitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DR235-002/C26 -/..... '" , , " ,,~ ,,"> "lijft" " ~ \~~,m\t\~.~I&.'lF..w.w,.\'.lI1'M1\\Ilm\llll~m~'!l\\l.'\I..\W11:'.\.'!.\.:~j~lXI""'\\,&~'.;',lB.\\\1"tlU\\i\lIi'l\iil"'\\im~iWii\\i1:\I\m1".Wi\\t."i~;ll),t\\i~\1\\.~\l"\l'~,,"~m;.J\'U\'l\l\u~~\W>~\"'\\\:\\%:i;'i\\J\\',\s\,,;\;\~"""!lli~Wi\t'i>\.,'lX.i\,-.:\\tI,\\\&,;\,~:i . ,- October 06, 2000 Loan No. 8816572910 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY. THE FOLLOWING PART OF THIS IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5 Janes Ln Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months an~e following amoun~re now past due: ~ jYMonths at $540.31 = 4,322.48 ~ /3.-Months at $543.30"'// 1,629.90 /' ~Months at $586.29 ~ 3,517.74 / Late Charges 240.71 V Bad Check Fees .00 Foreclosure Fees .00 / Bankruptcy Fees 5.757.60 ./. Other Fees 105.00 ~ Less Suspense Balance 378.51 ~. TOTAL AMOUNT DUE 15,194.86v7.S OF THIS DATE HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 15,194.86 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaYMents must be made either by cash, cashier's check, certified check, or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine. IL 60055-0107 DR236-003/C26 -,,:iIi.I.Wl , ~ l':'''M: ,",', ~ .~, '-:, . " V E RTF 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 autborized 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. MARK J. dr n, ESQUIRE , REN & ASSOCIATES ~PiHfilili-ifimlil!~jm~",il;;;;j!'i!""C~'!JM~~&!i!lfilldlf\i('khWhi.":M~;:;,dl'C'.t.'~"'"V't.l,~',,,,,,'AK","' ,,;'!)'c0.m;[(~lif1lID: ","" i;I;'~_~I!!;n&ffi-&~~l'l'!!~~~iffi'jj:jjl L Ii:~ . 1J ~ ~ "'69.. f4:. ~ 0 e, .~ ~ C c') :;) ... " & . "1J "', c"" .,.., 8 ....... w 8 a fT1 r&' j"'Y1 C\ Z" C) ;:~ ~_...:., ~ c.., &;\,: I ,-:~"'::ci ~ I j ;::;<" CJ'l :::::,Ci ~;~ () ~ k;J ~ " zQ ~"w ~ _.,h >Li c ~ 1-- z t =< :n :::,;! 'D 5:J -< '-..( y~-~,.,.", '~-'.' ~,~,' . " _ ~" ., .r ~, I" tt m;::-~~"^~ "" '<', ~.lli.' LJ:liii!(,)! ..., SHERIFF'S RETURN - REGULAR CASE NO: 2000-08438P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE VS MCMILLIN PAUL W ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCMILLIN JOYCE A A/K/A JOYCE ANN MCMILLIN the DEFENDANT , at 0009:50 HOURS, on the 7th day of December, 2000 at 5 JANE LANE A/K/A 5 JANES LN CARLISLE, PA 17013 by handing to JOYCE A. MCMILLIN 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 6.00 .00 .00 10.00 .00 16.00 So ?~~~~~ R. Thomas Kline 12/08/2000 MARK J. UDREN Sworn and Subscribed to before me this If'f!::: day of APu.P~ ~ A.D. n. ()_ 11.tdj,.v . $5- '---f1'Prothonotary ,~"""l,," ~ 1., ;, - .... \ SHERIFF'S RETURN - REGULAR CASE NO: 2000-08438 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE VS MCMILLIN PAUL W ET AL JASON VI ORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCMILLIN PAUL W the DEFENDANT , at 0009:50 HOURS, on the 7th day of December, 2000 at 5 JANE LANE A/KIA 5 JANES LN CARLISLE, PA 17013 by handing to JOYCB A. MCMILLIN a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So A::~:51: '., A .#/.AIP ~~1'~ R. Thomas Kline 12/08/2000 MARK J. UDREN Sworn and Subscribed to before By: #~ eputy Sheriff me this If<le- day of Io.~",""", A.D. e,~,# rothonotary ~~. .., - . Jid,........ ., L 'c" ~.' ~,'. ~' "~~...._w . First Nationwide Mortgage VS Paul W. McMillin Joyce A. McMillan a/kJa Joyce Ann McMillan In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-8438 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Law Library County Mileage Levy Certified Mail Surcharge Postpone Sale Law Journal Patriot News Share of Bills 30.00 14.34 15.00 15.00 .50 1.00 3.10 15.00 1.39 30.00 20.00 288.65 272.28 25.09 731.35 , paid by attorney .. 05-22,01 Sworn and Subscribed To Before Me This 6~'e Day of Q"M--<- 2001 A.D. ~~ ~.~ P onotary ~~~ R. Thomas Kline, Sheriff BY(~~ Deputy heriff I.~ :,)5,0 eft..- <f S'r 1W~2. ~~~ ~i' J "" I ~iiI ...,. ~ . 'kARK J. UDREN & ASSOCl:ATES 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Plaintiff : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendaht(s) AFFIDAVIT PURSUANT TO RULE 3129.1 First Nationwide Mortgage, Plaintiff in ~he 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: 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address PAUL W. MCMILLIN 5 JANE LANE A/K/A JANES LANE, CARLISLE, PA 17013 JOYCE A. MCMILLIN a/k/a JOYCE ANN MCMILLIN 5 JANE LANE A/K/A JANES LANE, CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose j~dgment 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. 2101 N. FRONT STREET, HARRISBURG, PA PENNSYLVANIA HOUSING FINANCE AGENCY ,,"~-' " I' .~'"' ,~". '~ "~,f S. 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 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 5 Jane Lane, a/k/a 5 Janes Lane Carlisle, PA 17013 . I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: March 5, 2001 Mar~ J. Udren, ESQ. Att9rney for Plaintiff ._".""'~ '", ~'J~ ~ ~,...:. "~>h'l~lilill~." . , MARK J. UDREN & ASSOCrATES 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 : Cumberla.nd County : MORTGAGE FORECLOSURE First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 civil Term Defendant(s) .' NOTICE OF SHERIFF'S SALE OF REAL PROPERTY . TO: PAUL W. MCMILLIN 5 Jane Lane a/k/a 5 JaneS Lane Carlisle, PA 17013 Your house (real estate) at 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 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 $63,525.64, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE'TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will, be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to pO$tpone the sale for good cause. mortgagee the back payment, late To find out how much you must pay, 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 at~orney.) The sooner you contact one, the (See notice on page two on how ",. .' , ~ ' ~'~ . , . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be. sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 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 Pi'stribution 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 LISTEP 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 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 ., '_" I, ".....~~': ."'" '~" ALL THAT CE:'TAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 33 on the Plan of section 9 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book' 24, Page 104; containing 85 feet along Jane Lane, having a depth along the West along Lot No. 32 on said Plan of 125 feet, having a depth along the East along Lot No. 34 on said Plan of 125 feet, and having a width in the rear along the North along Lots No. 28 and 27 on said Flan of 85 feet. BEING improved 'With a dwelling house known...as 5 Jane Lane, Carlisle. BEING the same propert.y which Agnes L. ,Frey, by her deed dated March 26, 1981 and recorded in the Cumberland County recorder of Deeds Office in Deed Book 'In, Volume"29, Page 769, gr~lted and conveyed unto Mark A. Soderberg and Leslie J. Soderberg, his wife, the Grantors Herein. BEING KNOWN AS PROPERTY ID# 5 JANE LANE, CARLISLE, PA 17013 29-16-1096-044 TITLE TO SAID PREMISES IS VESTED IN PAUL W. MCMILLIN AND JOYCE A MCMILLIN, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETY BY DEED FROM MARK A SODERBERG AND LESLIE J. SODERBERG, HIS WIFE DATED 1/28/1998 AND RECORDED 4/18/1998 IN DEED BOOK G33 PAGE 1198 ,," ~'" ~k~,. '.." , , ... ,,-" Lia&. '~': #'- . '. MARK J. UDREN & ASSOCI"ATES 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 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff . COURT OF COMMON PLEAS . CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin '5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 : NO. 00-8438 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY . TO: JOYCE A. MCMILLIN a/k/a JOYCE ANN MCMILLIN 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Your house (real estate) at 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle, PA 17013 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 $63,525.64, 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~diat~ action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: 18561-482-6900 2. YOU may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,=' - ~ ,- o ~"'" 'm'- ,j J, ",'~ 1M ~_ ..~ . . 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 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, Qistribution is, wrong) are filed with, the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also ha,re 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 OCT WHERE YOU CAN GET LEGAL HELP. . LAWYER REFERRAL SERVICE cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 ijQilI "~. . , ~"-,--,l..j".__.J ~ 1illI~, . , ALL 'rHAT CE:>TAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 33 on the Plan of section 9 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 104; containing 85 feet along Jane Lane, having a depth along the West along Lot No. 32 on said Plan of 125 feet, having a depth along the East along Lot No. ,34 on said Plan of 125 feet, and having a width in the rear along the North along Lots No. 28 and 27 on said Plan of 85 feet. BEING improved ~ith a' dwelling house known ..as 5 Jane Lane, Carlisle. BEING the same property which Agnes L. Frey" by her deed dated March 26, 1981 and recorded in the Cumberland County recorder of Deeda Office in Deed Book 'I", Volume'29, Page 769, gr~lted and conv~yed unto Mark A. Soderberg and Leslie J. Soderberg, his wife, the Grantors Herein. BEING KNOWN AS PROPERTY W# 5 JANE LANE, CARLISLE, PA 17013 29-16-1096-044 TITLE TO SAID PREMISES IS VESTED IN PAUL W. MCMILLIN AND JOYCE A MCMILLIN, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETY BY DEED FROM MARK A SODERBERG AND LESLIE J. SODERBERG, ~IS WIFE DATED 1/28/1998 AND RECORDED 4/18/1998 IN DEED BOOK G33 PAGE 1198 "~. - ". ~ "- l j", ", " ~' ;"'-"'j;, WRIT O,F,EXECUTION and/or ATTACHMENT ~, ,,;, ',,"':i - ) COMMONWEAlTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-8438 CIVIL 19 CIVIL ACTION. LAW TO THE SHERIFF OF CUMBERLAND COUNTY: First National Mortgage ,To.satisly the debt, interest and costs due PLAINTIFF(S) Irom Paul W. and Joyce A. a/k/a Joyce Ann McMillin, 5 Jane Lane, a/k/a 5 Janes Lane, Carlisle PA 17013. DEFENDANT(S) estate located (See attached (1) You are directed to levy upon the property 01 the delendant(s) and to sell Real at 5 Jane Lane. a/k/a 5 Janes Lane. Carlisle PA 17013. legal descripto.n.) (2) You are also directed to attach the property 01 the delendant(s) not levied upon in the possession 01 GARNISHEE(S) as lollows: and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined Irom paying any debt to or lor the account 01 the delendant(s) and Irom delivering any property 01 the delendant(s) or otherwise disposing thereol; (3) II property olthe delendant(s) not levied upon an subjectto attachment is lound in the possession 01 anyone other than a named garnishee, you are directed to notily him/herthat he/she has been added as agarnishee and is enjoined as above stated. Atty's Comm Atty Paid Plaintiff Paid % L.L. $1.023~ Prothy Other Costs $.50 $1.00 Amount Due Interest 3/6/01 - 6/6/01 @ $11. OO/diem $63.525.64 $119.10 Date: March 14, 2001 CURTIS R. LONG 'f1.-.u.. Jon ary, Civil Di~iSiOn Deputy by: REQUESTING PARTY: Name Mark J. Udren, Esquire Address: Attorney lor,: Telephone: Suprerne Court ID No. 1040 . Kings Highway Ste 500 cherry Hill NJ 08034 Plaintiff (856) 482 6900 04302 , LL' '" ,_..,~~~..i..,"""""""o}",.,~",,,~,,,,,,..~~,,,,,,";';,'i.l'~'"'".~:_' "'-" UiJll~1Illi~~"" ~.jl!ij(i_i!,i1!iIi~..~]i~;!I>Jli:i\.~'"1>:tl~""~-"","",l;.,,,,..,t'-=='~""i<"-""'.''''''''''''-'<-~'' ' ,'c ~..,..k""'i ',; ,r.,.~""_,,,(=""" , ,,"," '<! " ( - REAL EST ATE SALE NO",' 4~ ~ r=;:;\\ C\iV c::;:::a e:e> (iii\l On '1o.MJ....l {;,2CJDI the sheriff levied upon the detenoali, Interest in the real property situated in 1r511:L fY/~~ Gum berland County, Pa., known and numbered as:.'5tJ1fl tML ~1..a.. and more fully (leSenbed on Exhibit "A" filed witi' this writ and by this reference incorporated herein, 'late: i"lcucJL./~,;)Dol By: ..,r~ ~ Dpu.~~ VIW~^'USIHUd -'~I C 1"'."",,,:1'1 .:'; l"...J WI fld!€' 91 OM i.1IJIiUiYw:S C:'~I;:!; ld';;'.Q,tM:m~ ;lP3I111S ]Illil~@ 3l::Jli!.:iIilII . ,".< ~,~, : I , "" ~;"'~'" . MARK J. UDREN & ASSOCIATES BY: MarkJ. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 First Nationwide Mortgage 5280 Corporate Drive Frederick, MD 21703 Plaintiff v. Paul W. McMillin Joyce A. McMillin a/k/a Joyce Ann McMillin 5 Jane Lane a/k/a 5 Janes Lane Carlisle, PA 17013 Defendant(s) . L i~;""",~ ~ , lM-t -"~ ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 00-8438 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. DATED: July 18. 2001 ~~'!/c0--- Mark J. Udren, Esquire Mark J. Udren & Associates Attorney for Plaintiff -