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HomeMy WebLinkAbout03-1875MARK 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 Ba~k One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive Suite 200 Mendota Heights, M~ 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION . Cumberland County Ve Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) 0:3 - COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas si~uientes, usted tiene velnte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVEESTA DEMANDA A UNABOGADO IMMEDIATAMENTE, SI NO TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (8S6) 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: Alternative Lending Mortgage Corp. Assignments of Record to: Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee Recording Date: 08/20/99 Book: 622 Page: 779 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 102 5th Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland COUNTY: Cumberland DATE EXECUTED: 12/10/98 DATE RECORDED: 01/20/99 BOOK: 1513 PAGE: 1136 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 04/22/03: Principal of debt due Unpaid Interest at 10.625% from 10/01/02 to 04/22/03 (the per diem interest accruing on this debt is $13.86 and that sum should be added each day after 04/22/03) Title Report $46,948.43 2,827.44 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $22.18 should be added in accordance with the terms of the note each month after 04/22/03) 133.08 Attorneys Fees (anticipated and actual to 5% of principal) 2,347.42 TOTAL $52,786.37 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $52,786.37 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 · ' CUMBERLAED, CUMBERLAND O~ PARCEL OF LAND SITUATE. IAND BEING IN THE BOROUG]{ 'OF ~ ' , DESCRIBe' AS FOLLOWS,-'~ TO WiT= Ir/rage Print Page 1 of 6 N~ PA 1'/~) l. mn Numbs. 0~004118'1'8 EXHIBIT https://imaging~h~mec~mings~m/imageview/PrintImages.asp?D~cumentID=28234582&... 03/18/2003 I~age Print Page 2 of 6 : .. ACTgl NOTICE TAKE ACTION TO SAVE YOUR · HOME FROM FORECLOSURE ~ ~ ~ ~~ ~r~'~'~ ~ BB ~ F~ ~T~. ~ H~~'S ~~ ~T~ ~~ ~:~ ~ ~ic~ ~'~ s~ ~ To~ ~ ~ ~ ~1~ ~ ~ ~T ~ A G~~ ~ ~.~ ~ ~ I~N~~~ https://ima~mf~h~mec~minf~s~c~m/imaf~eview/PrintIma~es.ast)?D~eumentID=28234582&... 03/18/2003 I~nage Print Page 3 of 6 HOMEOWNERS' EE~:B~.N(~' MORTGAGE ASSI~ PROG1/~ ~ YOUR DEFAULT HA~ BEi~I CAUS]~ BY CIRL~JM~'TANCE$ BEYOND YC~R CERVIROL.. PAY YOL~ MORI~At~ PAYMtilq~, ~ AOENCY. STAY OF I~OP. ECLO~L~ - Und~ tl~ Aat. you ara ~fitl~l ~ a ~ ~ ~ ~ ~~ YOU ~'~ YO~ M~ ~ ~ D~. ~ P~T ~ ~ ~r.~.~ ~W TO ~ Y~ ~~ ~w.~ .~ H~ T0 ~ YO~ ~ TO DA~. ht~s://ima~,in~.homecomin~s.com/ima~eview/Printlma~es.aso?DocumentlD=28234582&... 03/18/2003 Ir~age Print Page 4 of 6 YOU ~- ~ YO~ ~~ ~o~Y. ~ YOU F~ TO ~ M OR W YOU~ N~. ~0~ AG~T YO~ HO~ 5~~Y ~ YO~ ~~ FOR M~T~GK NOT~ IF 'YOU ARE C~Y PRtYFF. CT~ BY THE yrlmqG OF .A P~ iI,~C~IUPI~nff, ~ FOLLOWING PART OF THIS ~'OTIC E IS MR ~F~N PITBPc~ES "ONLY A~ SH~NOT lJ~ ODNSTRUJ~ AS AN ATTEMPT 3%0 COL!~;F~T TIJX DEBT.: LF~S: Unnl~ud Funds: S 1,774.28 $ 110.90 $ 106,00 $ : 1.9~1,18 Hmue .emmtngs Finmadt], P.O/Box 78426 Phflou~r: AZ 9S06~2.-942~ OR OVERNIGHT TO~. sot cun~ 'r~ D~v^~_~.~ - ~,,.do ~.~ ~ ~ ~~ ~ ~vs ~ ~ ~ htt~s://ima~`n~h~m~c~min~s~c~m/ima~`evi~w/PrintIma~es~as~D~ument~D=28234582&... 03/18/2003 I~age Print Page 5 of 6 'l'lt~l'Y ia.g', 1)AY m, rhxl. ~mu roll not I~ I~elb~. TX 752O4 ~Olq' OF MORTG~GI~. - You n~, 1~ able'~o ~ ~ ttnm~ yo~ hot~t° a ~Snw ~ wanat'~e who YOU MAY ~ H~VE ~ ~. DI~BT. TOFI~ViS TInS ~ ALiT https://ima~ng~h~mec~min~s.c~m/ima~eview/PrintIma~es.asl~?D~umentID=28234582&.. 03/18/2003 Ifaage Prim Page 6 of 6 TO A~I~RT TI-IB NOel3 OF A l)BFAULT IN ANY FORBCI,0~LIRB PR(XIEBDINO 'OR ANY O'IX-l~ LAWB'r.~ TO ASSJ~RT A3IY ~~ YOU IIRI.lk'Vlt YOUMAY IHAVtt TO SUCH ACTION' BY~IB~ https://imaging.h~m~min~s~c~m/ima~vi~w/Print~ma~es.as~?D~cument~D=2~2345~2&.. 03/18/2003 I~age Print Page 1 of 6 Lmn Numhec 08004 ! ~ IN ~ AMOL~f OF S 12q~.18 'BY Mar~h OC~ ~ TO THB FCgaLOWINO ADDRI~ l~lmp Avmme,-Sulla li~ll PImm~ ~ ~I-:NM3. ' Tms~ to be immediately due sad. pa'~ble, ll~e lender thee inten~ to ~ tl~ ~ aold at a [mbl]c a£Tr, at ]=m~ end b~ ~~ ~ ~ ~~ You~~ ~ ~ ~ ~ ~m ~~ ~a~t ~~~~ ~ ~ ~ ~' ~~ ~T~~ ~~ BB ~ F~T.~. sino~¥, Horn~mlngs Flnmc~ol 27'11 htt~s://ima~ing~h~mec~mings.c~m/ima~eview/Print~maees.as~?D~umentID=28234588&.. 03/18/2003 I~nage Print Page 2 of 6 ACT'91 NOTICE TAKE ACTION TO SAVE YOUR .HOME FROM FORECLOSURE htt~s://imaging~h~m~c~minas~m/ima~v/ew/Print~ma~es~a~n?D~umentID=2~9.345~R~t... 03/1 g/200'~ Image Print Page 3 of 6 OU MAY ~ ~.T,T~ ~ ~~ ~~CE ~O~C~ ~ ~I,~OU M~ YOU ~Y ~ ~ ~O~ ~ ~ ~~'8 ~O~ ~RT~ ~~ ~ OF 1~ ~T), YOU ~Y W YOUR DEFAULT HAS BEEN CAUS~ BY CIRCI.~'TANCE$. BEYOND YER~ C, OHrR.OL. · PAY YOI~ MORTGAG[t PA~, AND APPI2EATIDN FOR MOI~G~E A~ISTANCa - Y~ ~/~ in d~fault f~e ~he ~as~s sat 6xth lattr LENDER CONTACT IN 1711Na'th ~ A~. Sui~ ~0 htws://imaa~n~h~mec~min~s~m/ima~eview/PrintImaees~as~?D~cumentID=28234588&... 03/18/2003 Image Print Page 4 of 6 NOTE: IF 'YOU ARE C~Y PI~'rw_.CTI!3) '!1c¥* ~ ~ OF. A PETITION IN ~, THE FOLLOWING PART OF THIS ~r~c E m POR RW~N PUI~OetES 'ONLY A~) SHOUU) NOT B~ CONSTRUED AS AN ATTEMPT TO C~ TKE DEBT.. $ 1,7~4.2~1 $ $ N/A $ : htt~s://ima~in~.homecomin~s.com/ima~eview/PrintIma'~es.asD?DocumentiD=28234588&... 03/18/2003 Image Print Page 5 of 6 l~jrll N, Hm~lk Sui~ 900 Dallas. TX 75204 TO HAVI3Hti~ DEFAULT CURED'By ANY THIRD PAR~Y ,t~-~lN~ Ct~T YOUR.BEHALF, htt~s://imaaina~h~mec~min~s~c~m/ima~eview/PrintImaees~as~?D~umentID=28234588&~ 03/18/2003 Image Print Page 6 of 6 TO A.~ERT ~ 'IqONtIX~ OF A DBFAUL.T IN ANY PROC~DINO 'OK ANY o~ii~ LAW.JEt INSII'ITYI'ED UNDBR ~ MOKT~AOB TO ASSF~T ANY O'[H[~ ItSFEN'~B. YOU BgI.~VE YOU MAY 1~/1~ I'O Sr~K~I ~ON htt~s://imakqng.h~me~mings.~m/ima~eview/Print~mages.asn?D~cument~D=2g2345~`~ 0~/1 gl?OO'l Image Print Page 1 of 6 Certifiod Mail. Rgmlm ~ Requ~sled Trus~ to ~ immediately due and payable, l'he k~xder then ~tends' to hn~e t~ property sold ~'~ ~~lc of~ ~. ~ com~Uns net~'tn,~ Hotnm::~mlngs Flnm'r3ol 271 I a:0.2o6,2~1 Home~q'nl~lS,Oom htt~s://ima~5n~h~mec~min~s~c~rn/ima~eview/PrintIma~es~as~?D~cmnentID=2823456~&... 03/18/2003 Image Print Page 2 of 6 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE ~.~o~c~ m ~ ~ro You ~ A~ An~a~r. m C~nLE~ ~ n~~SS ~D ~ro Io'aee if m~a,,a, m,~ hel_~ y~ m:~t m'r wrm A~ ~ crmr, m~.~rO, aom,,,L--w' ~ htt~s://ima~.qn~.homecomin~s.com/ima~eview/Printlma~es.asp?DocumentlD=28234560&... 03/18/2003 Image Print Page 3 of 6 HOMEOWNERS' EMERGENCY MORTGAGE A~'ISTANCE PROGRAM YOU ~y ~ ~ ~~ ~ ~ ~~'S ~~'~X~ ~~ ~ OF l~ ~ "~ YOU ~Y ~ ~ ~R ~y ~r~' 1~ ¥0UR DI~AIILT ~ BI/BN CAI~ BY CIRCUMS'TANCh'~. BEYON'D YOUR ~. PAY YOLR MORTC, AGIipAYMItNTS, AND ES'T-ARq'-~.q~ BY T~ PI~YLVANL~ HOI,ISIN~ F~C~. · TEMPORARY STAY OF ltou ~ut~__O_~_~g _ U~sl~ ~ ~ ~ ~ ~ m a ~ ~ ~ ~ M~T~E ~'1:~ YOU ~ B~ Y~ M~ ~ ~ ~. ~ p~T ~ ~'t*~[~ htt~s://ima~in~.h~mec~min~s.c~m/ima~eview/Print~ma~es.asl~?D~ument~D=2823456~&... 03/18/2003 Image Print Page 4 of 6 ~ IF 'YOU ARE CURREWI~¥ P'ROTECT~ BY THE ga:lNG OF .A ~ I~ · ONLY ~ gl~OUI~ NOT BE CO~UI~ AS AN ATTEMPT TO COLLF~T TI~ DimT.: ~lr you ht~ filed b~ntn, ut~ you emSttU Sider.far Emevfeu~ Mert~q~ AsdsUmee.) HOW TO OF ~ DF.F&UL? - IS SERZ~LY ~ DBFAfJLT ~: $ S 1(16,00 Nc~'BY PAYING ~ TOTAL AMOUNT DUE TO TI~ ~ WHICH IS S 1.~91.18. PLrJ~ ~ ~ YOU ~ N~ ~ ~ D~A~T-~.~ ~ ~ ~ ~ ~ ~ ~YS ~ httos ://ima~inff.homecominffs.com/ima~;eview/PrintImae;es.asp?DocumentID=28234560&... 03/18/2003 Image Print Page 5 of 6 Ddht ~ 752O4 ASSUMFIIO~r OF MOR~:E - Y~ may be able to ~ e~ tnmfer ymr home ~, a hw~m' ~ mmsfet~e wh~ 'fO S~-?- *IT]~ t~OPERTY TO oBTAIN MC~q~y TO PAY 0~ ~ MORTGAG]~ DE~:~ OR DI~T. TO HAVB .:'I~S 'I:~EFALILT K3cIRED BY ANY Tftl:RD PARRY ACT:lNG ~ YOUR BI!RtALF, htt~s://imaging~h~mec~mings~c~m/ima~evi~w/PrintImages~as~?D~cument~D=2823456~&~ 03/18/2003 Image Print Page 6 of 6 TO A.SSBR~ 17lB 'NO~TI~CB OF A DBFAI~I IN ANY FO~URB PR~fl. OR ANY O'EH]~ LA~ lbYJ~ L~IDBR ~ MORYt~AOB TO A,.RSr~T ANY ~ DEFEN~ YOU ]~IIB'_'I'P.V']~ YOU MAY N.A.'V3~, TO, ~LK2tt ACTION BY.~~ https ://ima~mg.homecomings.com/imageview/Printlmages.asp ?DocumentiD=28234 560&.. 03/18/2003 Image Print Page 1 of 6 Cl~t~,lN TI~ AMOLR~ OF $ L99L~a 'BY, Mlll$1_~}~'rO TI~ F~LOWINO Ha~mm:~rnJngs F~nc~al · ?./'11 I~o~11~ ~a~l~ll A~e .~11~ ~'3~DallaS. Texa~ :EO.Z~2g~I ~omec~mina~.cem https://imaging~h~m~c~mings~c~m/imag~vi~w/PrintImages.asu?D~cumentID=28234576&... 03/18/2003 Image Print Page 2 of 6 --:ACT 91 NOTICE TAI~ ACTION TO SAVE'YOUR HOME FROM FORE~OS~ https://ima~/n~h~me~min~s~c~m/ima~eview/PrintImages~asp?D~ument~D=28234576&... 03/18/2003 o Image Print Page 3 of 6 ltOMEOWNERS, EMERGENCY MORTGXGE A,S~STA.NL'3g PROGRAM IF YOUR Dt~FAIILT HA~ BEEN C~ BY CIRCI.~SYANCES BEYOND YOUR C, ONTRt~.. ~ Y~HAVE A~ABLBi~DI~PF. CT OF BliE~O ABLE TO PAY YOUR MOR~ pAYM]iN~, Al, ID IF ¥C)~M~IST O'I~ ~mlLITY REQUI~ ES~r_~ BY Tim ~,,~YLVAN~ ~OU~TO htt0s ://imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=28234576&... 03/18/2003 Image Print Page 4 of 6 goqty ~ tru~ YO't~R'APPLICAT~(~lq~O~y, ur You F~ ~ ~ ~ oR ~ Y~~ ~~ AG~T YO~ HO~ ~~y ~. y~ ~~ON FOR M~TGAGE ~ W YOU ~ C~V ~~'ny ~ ~.~ OF.A ~ m' IS SERZOU~Y ~ DI~F~8_~T b~ause: LF3S: Unal~li~d Fua~h: $ I,TY4~,H $ I10:DO $. 106,00 $ t.~ias · 2H.~~ Flnmaef~ P.O, Box 78426 Pho~qd,r; AZ SS092-9426 O11 0 .VF~NIGHT TO: ,44s W..nUnhp Avl ~ 1~~, ~ s~l~ YOU ~ ~O~ ~ ~ D~yA~ .T - ~ ~ ~.~ ~ ~ ~-~ ~ ~y~ ~ ~ ~ htt~s://ima~m~h~mec~min~s~m/imageview/PrintImages.asp?D~umentID=28234576&... 03/18/2003 Image Print Page 5 of 6 TOHAVB.I'HES ~11~! CORED BT/' ~ ~ PARTY ACTEq9 ~ YOI. IR.BItHA~, htt~s://imaging~h~me~~mings~c~m/imageview/Print~mages~asp?D~cument~D=28234576&... 03/18/2003 Image Print Page 6 of 6 TO A~BRT ~ NO~TI~CB OF. A D~FAULT IN ANY FOP, BC2,0~URB PR~o OK ANY OTHI/R LAbOR,IT INS~ UNDBR THE MORTOADB TO .-~SRR.T ~ Ort.l'{:/R DRFf/N"3~ YOU ~ :nr. Vl~ YOU MA.Y BY' TI-IR ~ https://imaging.h~mec~m~~gs.c~m/imageview/PrintImages.asp?D~cumentID=28234576&.. 03/18/2C)03 VERIFICATION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. this statement herein Pa.C.S. Section 4904 authorities. is made relating The undersigned understands that subject to the penalties of 18 to unsworn falsification to Mar~ J. Udren; Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES CASE NO: 2003-01875 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS STAFFORD ROLAND D ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STAFFORD JODY M the DEFENDANT at 1105 BRIDGE STREET , at 1717:00 HOURS, on the 29th day of April NEW CUMBERLAND, PA 17070 by handing to 2003 JODY STAFFORD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 11.73 Affidavit .00 Surcharge 10.00 .00 27.73 Sworn and Subscribed to before me this J6 ~ day of ,~, ~ A.D. ! ! PrAthon~a~y ! ' So Answers: R. Thomas Kline 05/08/2003 MARK UDREN - Depu~r~H~iff 33000026 SHERIFF'S RETURN OF SERVICE ( ) (1) The within upon defendant by mailing to · by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the ( ) (2) ( ) (3) ( ) (4) ( ) (5) The return receipt signed by defendant on the made a part of this return. Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) and attested copy thereof at is hereto attached and (1) (2), by mailing a true in the following manner: ( ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. By mailing to by. mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities marked is hereto attached. Other returned by the Postal SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-01875 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS STAFFORD ROLAND D ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: STAFFORD JODY M but was unable to locate Her deputized the sheriff of ADAMS serve the within COMPLAINT - MORT FORE in his bailiwick. He therefore County, Pennsylvania, to On May 8th , 2003 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 05/08/2003 MARK UDREN Sworn and subscribed to before me this 7~ ~ day of ~ 2~2~ A.D. Prothonotary ' R. Thomas Kline ~_ Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Bank One NA SERVE: VS. Roland D. Stafford Jody M. Stafford et al No. 03-1875 civil Now, April 24, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, pA, do hereby deputize the Sheriff of adans- County to execute this' Writ, this deputation being made at the request and risk of the plaintiff. Sheriff of Cumberland County, PA Affidavit of Service' NOW, within ,20 , at o'clock M. served the upon by handing to a and made known to SWorn and subscribed before me this __ day of ,20 copy of the original So answers, ¥ uepu'~ She~{'f of COSTS SERVICE MILEAGE AFFIDAVIT the contents thereof. Adams County, PA DATE RECEIVED MASON DIXON BUSINESS FORMS, INC. 3.3000026 SH RIFF'S D PARTM NT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 DATE PROCESSED SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTiFF/S/ BARK ONE~ NA 3. D-~..N DANT/S/ ROLAND D. STAFFORD, ET AL ~ERVE INSTRU~ION~: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reveme of the le~ (No. 5) copy of tht~ form. Please r2. COURT NUMBER 03-1875 Civil Term 4. TYPE OF WRrr OR COMPLAINT: Complaint in Mortgage Foreclosu~ 5. M.~E OF INDIVIDUAL, COMPANY, CORPORAT~3N, cio., TO SERVICE OR DESCRIPtiON OF PROPERTY TO BE LE~ED, ATTACHED OR SOLD. Jody M. Stafford 6. A~,~RE&~ (Street or RFD, Aw~,,~,,~,~; No., City, Boro, Twp., State and ZiP CODE) 1258 N. Browns Dam Drive, New Oxford, PA 7. INDICATE UNUSUAL SERVICE: [] PERSONAL r~ PERSON IN CHARGE [3 DEPUTIZE [] CERT...U~!L [] ~-=~!._eTERED MAIL [] POSTED [] OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. ~: |~,;,'-~ OF ADAMS COUNTY 8. CP-~CIAL INSYRUCTIONS Off OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN--Any deputy sheriff levying upon or aRaching any propmly under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the pert of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTC.%~:--Y or o;,%~ ORi~iHATOR requesting service on behalf of: ] 10. TELEPHONE NUMBER I 11. DATE Mark J. Udren, Esq. r][PLAIN~FF [] DEFENDANT SPACE BELOW FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELOW THIS LINE 12.orl ackno~leclgecomplaint asr~c~Ptindicated°f theabove.Wrlt [ SIGNATURE of Authorized ACSD Deputy or Clerk and T;tle I 13. Dele Received I 14. Expiration / Hearing date IApril 25, 20031 15. I hereby CERTIFY and RETURN thai I n have personally sawed, [] have sawed person in charge, [] have legal evidence of service as shown in "Remarks" (on reverse) [] have posted the above dascrlbed property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the eddreas inserted below by handing/or Posting a TRUE amd ATTESI'ED COPY therof. 16. ~[ I ;-,ere~,y c~,;;;y and return a HOT FOUND because I am unable to locate the individu,I, company, corporation, etc., n~,~,~, above. (See remarks below) 17. Na;~e and title of individ~=_! sewed 19. Ad~,r~ of ~,~,~,-~ ;;;-~cl (comp;.'e;e only if d~e~ent than ;,%ow,~ above) (S;ree; or RFD, Apa,J,,,~,,i No., City, Bom, Twp., IL' A ~ ~ ~uil~l~ ~ and di~cmtiofl J r~N~mg m Ihe defand,,nt'~ u~ual State and ZiP CODE) ~: ~ defendant bas moveed & 'le~t no fog-w-agd'i~§ ack]tess with the post office. ..... D~p_~..nt .... · --..~ Dap. Int. Date Mllea Dap. Int. D~te Mllea D~ 20. Date of Service 21. Time Read Order 28. CO~T DUE OR REFUND AFFIRMED end mJbeorlbed to before me this day of N/A MY COMMISSION EXPIRES I ACKNOW! ;_r~_E ~¢~_'Pl OF THE ~.'~'.~%~i~ ~ i ~..qN.. ~'A~.ATURE OF AUTHORIZED 18SUING AUTHORITY AND TITLE. Richard S. Keefer Date 5/6/2003 De'~/6/2003 J3g. Date Received PROTHONOTARY 33000026 SHERIFF'S RETURN OF SERVICE ( ) (1) The within upon defendant by mailing to by. prepaid,, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the (2) ( ) The return receipt signed by defendant on the made a part of this return. Outside the CommOnwealth, pursuant to Pa. R.C.P. 405 (c) and attested copy thereof at is hereto attached and (1) (2), by mailing a true in the following manner: (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not receivec~ (3) said envelope_back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. By publication ip the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits (4) from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at (5 The Authorities marked returned by the Postal is hereto attached. ) Other SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-01875 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS STAFFORD ROLAND D ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: VARUGHESE PHILIP but was unable to locate Him deputized the sheriff of ADAMS in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On May 8th , 2003 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 05/08/2003 MARK UDREN R. Thomas Kline ~ Sheriff of Cumberland County Sworn and subscribed to before me this /& ~ day of ~ ~;3 A.D. Prothonotary, In The Court of CommOn Pleas of Cumberland County, Pennsylvania Bank One NA SERVE: VS. Roland D. Stafford et al Philip Varu§hes e No. 03-1875 civil Now, April 24, 2003 , I, SHEPJFF OF CUMBERLAND COUNTY, pA, do hereby deputize the Sheriff of Ad~s County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, ,20. _, at o'clock M. served the within upon by handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before' me this ~ day of ,20 She~ff of Adams County, PA COSTS SERVICE MILEAGE AFFIDAVIT ZS :b V S Z I::tcl¥ 03Ai30 = MASON DIXON BUSINESS FORMS, INC. 33000026 DATE RECEIVED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAIh~,FP~S/ BANK ONE~ NA 3. DATE PROCESSEI~ IN~TRUCTION~: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reverse of the ~ (No. 5) copy of this form. Please type or print legibly, insuring re~ of all coplea. I2. COURT NUMBER 03-1875 Civil Term 4. TYPE OF WRIT OR COMPLAINT: Complaint in Hortgage Foceclosm NME OF ~~OIVIDUAL, CO~PA.Y, CORPO~TION. ETC., TO SERVICE OR ~OCRIPTmN OF PROPERTY TO SE U~VlEO, ATTAC.ED OR SOLD. ?hilip Verughese 6. AF.~RF.~ (~u,i~ or RF~, Apartment No., City, Boro, Twp., State and ZiP CODE') AT '~ 1258 N. Browns Dam Drive, New Oxford, PA 7. INDICATE UNUSUAL SERVICE: I-I PERSONAL [] PERSON IN CHARGE 0 DEPUTIZE I"] CERT. MAIL [] RF_~!$TERED MAIL 0 POSTED 00THE. fi Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. ~NF.~;ffff OF ADAMS COUNTY 8. SPECIAL IN~HUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN--Any deputy sheriff levying upon or altaching any property under within writ may leave same without a watchman, in custody of whomever is found in posseasion, after notifying parson of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTG~"~'Y er other ORi~iHA¥OR requesting service on behaff of: 10. TELEPHONE NUMBER I 11. DATE Mark J. Udren, Esq. ~PLA~NTIFF [] DEFENDANT SPACE BELqW FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELOW THIS LINE 12. I ackno~?~e.- r~p~ of th.e writ / SIGNATURE of Authorized ACSD Deputy or C ark and T~tle I 13. Date--Received I 14. Expiration / Hearing date or compm~nt as inaicateo al)ova. / IApril 25, 2003I 15. I hereby CERTIFY and RETURN that I [:3 have parsonally served, [] have served person in charge, [:3 have legal evidence of service as shown in "Remarks" (on reverse) [] have posted the above described pro~erty with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 18.X:] I h~=by c~,~;;y and return a HOT FOUND because I am unable to locate the individLm_!, company, corporation, etc., named above. (See remarks below) 17. N&i~e and title of individual 19. A~di~ of v..'-_~ ~,-~;~ (c~.,q.,;~;e only ~ di~ere~; than s~n ~ve) (Strut or RFD, ~mem No., C~, ~ro, T~., ~te and ZIP ~D~ ~: ~ d~e~nt ~s ~ & left ~ fo~i~ ~s ~ t~ ~st offi~. petsun of ~ultable age and discretion I Read Order reekJing in the defendant's usual 20. Date of Service 21. Time 28. COST DUE OR REFUND AFFIRMED and subscribed to before ma thb day of N/A I AGKNO~ K_n~_E -_~,__-C~:.~P¥ OF THE '-:~._ .'~ m=l~lRN ~i~HATURE OF AUTHOriZED 18SUING AUTHORITY AND TITLE. Richard S. Keefer Date 5/6/2003 5/6/2003 3g. Date Received PROTHONOTARY SHERIFF'S RETURN OF SERVICE ( ) (1) The within upon defendant by mailing to by. prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the (2) The return receipt signed by defendant on the made a part of this return. Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) and attested copy thereof at is hereto attached and (1) (2), by mailing a true in the following manner: ( ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further~certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ) ( 3 ) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( ) (4) By mailing to by. mail, return receipt requested, postage prepaid, on the ( ) (s) a true and attested copy thereof at The Authorities marked is hereto attached. Other returned by the Postal SHERIFF'S RETURN - REGULAR CASE NO: 2003-01875 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS STAFFORD ROLAND D 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 STAFFORD ROLAND D the DEFENDANT , at 102 5TH STREET at 1948:00 HOURS, on the 5th day of May NEW CUMBERLAND, PA 17070 by handing to , 2003 ROLAND STAFFORD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 11 73 00 10 00 00 39 73 Sworn and Subscribed to before me this /6 ~ day of  ~ 003 A.D. 'P~othonotary ~ ~ So Answers: R. Thomas Kline 05/08/2003 MARK UDREN ty Sherif~ MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 85.6-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee Plaintiff Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION iCumberland County iNO. 03-1875 Civil Term pRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: May 28, 2003 J. UDREN & ASSOCIATES Mark-J.~dren, Esquire ATTORNEY FOR PLAINTIFF SHERIFFIS RETURN - OUT OF COUNTY CASE NO: 2003-01875 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS STAFFORD ROLAND D ET AL R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT VARUGHESE PHILIP but was unable to locate Him deputized the sheriff of BUCKS serve the within COMPLAINT - , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, MORT FORE He therefore Pennsylvania, to On June 24th , 2003 attached return from BUCKS Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Bucks County 48.00 .00 85.00 06/24/2003 MARK UDREN Sworn and subscribed to before me ~0 day this ~ A.D. rothonotar~ this office was in receipt of the R. Thomas Kli~e ,/ Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Bank One NA VS. Roland D. Staffor~ et al SERVE: Philip Varughese 03-1875 civil No. NOW, May 30, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Bucks County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA NOW~ within upon at by handing to a and madelmown to Affidavit of Service ,20 .,at o'clock copy of the original So answers, M. served the the contents thereof. Sworn and subscribed before me this day of ,2O Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA CUMBERLAND CCtJNT¥ I COURTHOUSE 17013 PLAINTIFF BANK ONE NTNL A ~$gC,:/K/ATHff F VS. / 05ZgZO03 C~MPLA.N~ CiVZL ~ iON AMOUNT PAI~ E,WIFE. ~NO OF CAS E BUCKS COUNTY_Jo,/_ SHERIFF'S RETURN Special instructions Action CIVIL ACTION -MORTGAGE FORECLOSUPd Plaintiff BANK ONE,NATIONAl, A,qSOC,f/k/a vs 'II4E FI~qST NATtfL BANK OF CHICAGO Defendant PIqII.TP VARUGHF. FE,RFAI. OWNFR 3172 n~;'~FI ROAn )~E.hlSAI~FU~I, ?A ~9020 Addres$Served ~ Different ~;~undar Ps.R,C.P. #402 lA) (i) Defendant personally served ~(A) (2} (i) Family Member lA) (2) (i) Adult in Charge of Residence (A) (2) (ii) Manager/Clerk at Defts. Lodging lA) (2) {iii) PO~on in Charge of Busina~ ~.~ By Handing to C~,;:~f~'/~RUC/'~O'~'"d''T~ By Posting Not ~en~ed 30 Osy$ Rsn Out Defendant Moved Def. Unknown Checked Pest Office F~rwarding Address Defendant Not Home Address Vacant Dap. Needs Better Add. No Forwarding Witness The above document wa~d on the defendant es ~r informati~a~ve in ~ou~ of BUCk'," Comm~l~~ So answms: She~ Bu~s Cou~ ubser)~ ~fore me on this day Prothonota~ Afl~rm~ and so~r~ ~fore me on this day Notaw Public My Com. Ex~. a,~, County C.,e # 03312 ~0 Invoice to_ b.e,~n~d ~o ~, ~n ~ ~ t~ ~ County S~riff's ~fice A~n. of OFFiCiAL RECEIPT RECEIPT # 2003 I 07083 TRANSACTION ¢ S,~ 26E'3 51780 FOR ,~iARK J Lg,~FEH,ES 06/04/2003 15:0~ P-~76/05/2003 PC ~00084i2 ~3.09 TOTAL PA!~, 4S.OO TOTAL COST 4S- O0 CHANGE O, iDS THANK YOU 8AE MAR/( J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 2OO Mendota Heights, MN 55120 Plaintiff ATTORITEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Roland D. Stafford, Mortgagor NO. Jody M. Stafford, Mortgagor Philip Varughese, Real Owner : 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) 03-1875 Civil Term PRAECIPE FOR ~uDGMENT FOR FAILURE TO ANSi~ERAND ASSESSMRNT OF D~ 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 4/23/03 to 7/29/03 Late charges per Complaint From 4/23/03 to 7/29/03 $52,786.37 1,358.28 TOTAL ~211~1~9 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J~E~CIATES DAMAGES ARE HEREBY ASSESSED AS INDITED . PRO PROTHY MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEERY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee Plaintiff Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1875 Civil Term DATED: TO: July 10, 2003 Roland D. Stafford, Mortgagor 102 5th Street New Cumberland, PA 17070 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAR3~NCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PA-RTE 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 PER/DER BIENES Y OTROS DERECHOS, IMPORTA/~TES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, 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 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner Defendant(s) ATTOP. NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1875 Civil Term DATED: TO: July 10, 2003 Jody M. Stafford, Mortgagor 1105 Bridge Street New Cumberland, PA 17070 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. D-NLESS 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 REFERP~AL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTA. DO DE REBELDIA POR NO FLABER TOMADO LA ACCION REQUIRIDA DE SU PA. RTE 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 UNABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PAR3~ TAL SERVICIO, VAYA EN PERSONA 0 LLAME FOR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PAHA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PP. ACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. A1TY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1875 Civil Term DATED: July 16, 2003 TO: Philip Varughese, Real Owner 3122 Drexel Road Bensalem, PA 19020 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU RAVE FAILED TO ENTER A WRITTEN APPEAR3~NCE 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 TA/fE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CAI~NOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTP~A 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 NECESIDD~D DE COMPARA-RECER 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 UNABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as . Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTOR/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSD-RE NO. 03-1875 Civil Term Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey : : COUNTY OF Camden : SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Sworn to and subscribed before me this 15th day Not a~ Public Philip Varughese, Real Owner Over 18 As captioned above Unknown Name: Mark~ Title: Attorney .F.o..r_ Plaintiff Comp~/ 1040 N, SUITE 503 CHERRY HILL, NJ 08034 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORREY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION -Cumberland County MORTGAGE FORECLOSURE NO. 03-1875 Civil Term V. Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey : COUNTY OF Camden : SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Roland D. Stafford, Over 18 As captioned above Unknown Mortgagor Defendant: Jody M. Stafford, Mortgagor Age: Over 18 Residence: As captioned above Employment: Unknown ~~n ~s ~ Name: Mar , q. Title: A~t orne~A~7~n.', t i f f Sworn to and subscribed Comp before m~ this ]5th day 1040 N. KINGS ~JGHWAY ~f July,~003.~~ SUIIE 500 . %~ ,,,. ~~ CHERRY H,LL, NJ 0~ MAR/( J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTOP-NEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION · Cumberland County !MORTGAGE FORECLOSURE Roland D. Stafford, Mortgagor NO. Jody M. Stafford, Mortgagor : Philip Varughese, Real Owner : 1258 N. Browns Dam Drive New Oxford, PA 17350 : Defendant (s) 03-1875 Civil Term TO: Roland D. Stafford, Mortgagor 102 5th Street New Cumberland, PA 17070 NOTICE notified that a Judgment has been entered proceeding as indicated below. Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby against you in the above 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 ATTOPaNEY Mark J. At this telephone number: PLEASE CALL: Udren, Esquire, Esquire 856-482-6900 MA/~K J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as . Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTOR1TEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. ! Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor i NO. Philip Varughese, Real Owner : 1258 N. Browns Dam Drive New Oxford, PA 17350 : Defendant[s) 03-1875 Civil Term TO: Jody M. Stafford, Mortgagor 1105 Bridge Street New Cumberland, PA 17070 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, ygu 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 CONCERI~ING THIS NOTICE PLEASE CALL: ATTORNEY M~rk J. Udren, Esquire, Esquire At this telephone number: 856-482-6900 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-482-6900 Bank One, National ~ Association, F/K/A The First ~ National Bank of Chicago as - Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) ATTORREY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-1875 Civil Term TO: Philip Varughese, Real Owner 3122 Drexel Road Bensalem, PA 19020 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, notified that a Judgment has been entered against you proceeding as indicated below. 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 ATTORNEY Mark J. At this telephone number: Prothonotary PLEASE CALL: Udren, Esquire, Esquire 856-482-6900 you are hereby in the above MARK J. UDP. EN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National : Association, F/K/A The First National Bank of Chicago as - Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTOR/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) NO. 03-1875 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 7/30/03 to Date of Sale December 10, Per diem @$13.86 (Costs to be added) 2003 $ 1.857.24 MARK J. UDREN & ASSOCIATES MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago ~s Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS ~ CIVIL DIVISION .Cumberland County : MORTGAGE FORECLOSURE Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant (s) NO. 03-1875 Civil Term OF E~RC~TION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 102 5th Street New Cumberland, PA 17070 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From ~ to Date of Sale DecemBer 10, per diem ~$13.86 (Costs to be added) By 2003 $ $54,211.19 1,857.24 Prothonotary Clerk Date Bank One, COURT OF COMMON PLEAS NO. 03-1875 Civil Term National Association, F/K/A The Firs~ National Bank of Chica~o as Trustee VS. Roland D. Stafford, Mortgagor Jody ~. Stafford, Mortgagor Philip Varughese, Real Owner WI~IT OF EXECUTION REAL DEBT $ 54,211.19 INTEREST $ 1,857.24 from 7/30/03 to Date of Sale .DecemBer 10, 2003 Per diem ®$13.86 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY . $ COSTS DUE PROTHY. $ PP~LISES TO BE SOLD: 102 5th Street New Cumberland, PA 17070 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 (856) 482-6900 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-1875 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK ONE, NATIONAL ASSOCIATION, FfK/A THE FIRST NAITONAL BANK OF CIHCAGO AS TRUSTEE Plaintiff (s) From ROLAND D. STAFFORD, MORTGAGOR, 102 5TM STREET, NEW CUMBERLAND PA 17070 and JODY M. STAFFORD, MORTGAGOR, 1105 BRIDGE STREET, NEW CUMBERLAND PA 17070 and PHILIP VARUGHESE, REAL OWNER, 3122 DREXEL ROAD, BENSALEM PA 19020 (1) You are CFLrccted to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 102 5TM STREET, NEW CUMBERLAND PA 17070 (SEE LEGAL DESCRIPTON). You are also directed to attach the property of the defendant(s) not levied upon in thc possession (2) of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a ganftshee and is enjoined as above stated. Amount Due $54,211.19 L.L. $.50 Interest FROM 7/30/03 TO 12/10/03 ~ $13.86 PER DIEM = $1,857.24 Atty's Comm % Due Prothy 1.00 Arty Paid $343.26 Other Costs Plaintiff Paid Date: AUGUST 1, 2003 (Seal) REQUESTING PARTY: Name MARK J. UDREN, Esq. Address: 1040 N. KINGS HIWAY, STE. 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF CURTIS R. LONG By: ~'/~ D MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856~482-6900 Bank One, National : Association, F/K/A The First ~ National Bank of Chicago as ~ Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) ATTOR/{EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-1875 Civil Term CERTIFICATE Mark J. Udren, Esquire, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: Sec. ( ) ( ( ) ( 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 4904 relating to unsworn falsification to authorities. Pa. C.S. Mark/J. Udr~, E~quir ,~a~ESQUIRE ~R/~EY FOR PLAINTIFF MARK j. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) ATTOP~NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-1875 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 102 5th Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Name Address Philip Varughese, Real Owner 3122 Drexel Road Bensalem, PA 19020 2. Name and address of Defendant(s) in the judgment: Name Address Roland D. Stafford, Mortgagor 102 5th Street, New Cumberland, PA 17070 Jody M. Stafford, Mortgagor 1105 Bridge Street,New Cumberland, PA 17070 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 record: Name of the last recorded Address holder of every mortgage of Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Nam~ and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 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 102 5th Street, New Cumberland, PA 17070 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: July 29, 2003 ESQ. 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 : Plaintiff ATTOP. NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) NO. 03-1875 Civil Term NOTICE OF SHERIFF'S SA?,R OF pW. AL PRORERT~ TO: Phillip Varghese, Real Owner 3122 Drexel Road Bensalem, PA 19020 Your house (real estate) at 102 5th Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthose, Carlisle, PA , to enforce the court judgment of $54,211.19, 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 SAI,E To prevent this Sheriff's Sale, you must take ~-~ediate action: 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: 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. 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.) 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 PA~ER TO YOU~ LAWYER AT ONCE. IF YOU DO NOT HA~'E A LAWYER OR CANNOT A~F0~D ONE, C~ TO OR TELEPHONE THE OFFICE LISTED ~ELOWT0 FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER I~EFEi~D~L S~VICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 : Plaintiff ATTORREY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Yo Roland D. Stafford, Mortgagor NO. Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) : 03-1875 Civil Term NOTICE OF SHERIFF'S SA?.E OF ~R~?. PROREP~d[ TO: Roland D. Stafford, Mortgagor 102 5th Street New Cumberland, PA 17070 Your house (real estate) at 102 5th Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthose, Carlisle, PA , to enforce the court judgment of $54,211.19, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NQT/~CE OF OWNER'S RIGHTS IOU MAY BE ABLE TO PREVENT THIS SHRRIFF'S SALR To prevent this Sheriff's Sale, you must take {mmediate 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU ~MA~[~TILL BE ABLE T~SAVE_ ~[OUB~_PROPERTY .AND~YQ~_}{Ai~E 0THE~IGHTS E~EN~I F T H E~ H E/{ IF FLS~ S A I~U~D/k~ S_ ~ LA~ F~ 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 9© 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 LIST~) BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYEH REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-%82-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 : Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Roland D. Stafford, Mortgagor :NO. Jody M. Stafford, Mortgagor : Philip Varughese, Real Owner : 1258 N. Brow-ns Dam Drive New Oxford, PA 17350 Defendant(s) : 03-1875 Civil Term NOTICE OF SHERIFF'S S~?.E OF ~RaT. PROPERTY TO: Jody M. Stafford, Mortgagor 1105 Bridge Street New Cumberland, PA 17070 Your house (real estate) at 102 5th Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthose, Carlisle, PA , to enforce the court judgment of $54,211.19, 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 P~VRNT THIS SHRRIFF'S SAT.R To prevent this Sheriff's Sale, you must take f~ate 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. 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.) EVEN IF THE SFE~WFF'S SAT,R DOES TAKE PT.~CE. 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 ou= 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 HAV~ A LAWYER OR CA~NOT AFFORD ONE, ~O TO OR TELEPHONE '£~ OFFICE LISTm~ BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. LAWYER REFEP~AL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR pLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland. County NO. 03-1875 civil Term Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant (s) TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 17, 2003 MARK J. BY: Mai UDREN & ASSOCIATES k J. Udren, Esquire, )rney for Plaintiff ESQUIRE Bank One, National A%ocinfioth et. al., ptsiufiff(s) Roland D. Stafford, et. al., Defendant(s) Se~/ice of pmce~ by APS International, Ltd. 1.800-328-7171 APS lut~ruatioual Plaza 7800 Glenroy Rd. Minneapolis, MN S5439-3122 MARK J. UDREN M~. Lillian Torres 1040 North Ki~s Highway Suite 500 Cherry Hill, NJ 08034 AFFIDAVIT OF SERVICE -- Individual Se~ice o! proce~ on: --Phillip Varghese Court Case No. 03-1875-Civil Term State of: Name of Server: ~-x that at the time of service, s/he was over thc age of twenty-one, was not a party to this action; thatoathe ) _dayof _~'~ .,20 O-_q2L, at JO~O,°'cl°ck t0'M Date/Time of Service: Place of Service: Documents Served: at 3122 Drexel Road the undersigned served the documents described as: Notice of SherifFs Sale o[Real Property ill Be,,,~.l*m. PA 19020 Service of Proceas on: Person Served, and Method of Service: Description of Person Receiving DocumentS: Signature of Server: A tm~,aad correct copy of the aforesaid document(s) was served on: Phi~io Varghese ~ ~ ~the hands of the person to be servea, a erson of , P [] By delivering them into the hands of _ suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is The person receiving documents is described as follows: Sex-P~ ; SkinColo~5',~v~ .; HairColor ~l~r¢//( _; FacialHair Approx. Age_'3,~ _; Approx. Height -~q .; Approx. Weight [fi,t) _ [] To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that,the foregoing is tree and co~ect. ~S ~temafion~ Lt& APS File ~ ~8~0~1 Subscribed and sworn to before me this ~ day of ~0~ ,20 ~ Nolary Public (Commi~ion Expires) · mn~lon 8reno, ~omrv ~ul~ 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 One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Vo Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) AFFIDAVIT OF SERVICE ATTORNEY FORPLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ! NO. 03-1875 Civil Term PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". Order is attached hereto as Exhibit "B". All Notices were served withinthe time ~mi~ 3129. This Affidavit is made subject to~p~] relating to unsworn falsification utI ~iti~ Dated: November 17, 2003 ~K J. BY: ~ rk J. Udren, Esquire, Esquire Attorney for Plaintiff If service was by Order of Court, then proof of compliance with said orth by Pa Rule C.P. 1~ Pa.C.S. ~'~904 TES MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive New Oxford, PA 17350 Defendant(s) ATTOP_NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-1875 Civil Term DATE: November 3, 2003 TO: ALL PARTIES iN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OWNER(S): Roland D. Stafford, Mortgagor & Jody M. Stafford, Mortgagor, & Phillip Varghese, Real Owner PROPERTY: 102 5th Street New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the C~berla~d County Sheriff's Sale on D~, 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. Bank One, National Association, fA¢/a The First National Bank of Chicago As Trustee VS Roland D. Stafford, Jody M. Stafford and Philip Vamghese In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1875 Civil Term Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 09, 2003 at 1:45 o'clock PM, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Roland D. Stafford, by making known unto Roland Stafford, personally, at 102 5th Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 09, 2003 at 6:00 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: Jody M. Stafford, by making known unto Jody Stafford,'personallY, at 1105 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 09, 2003 at 3:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Roland D. Stafford, Jody M. Stafford and Philip Vamghese located at 102 5th Street, New Cumberland, 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: Roland D. Stafford, by regular mail to his last known address of 102 5th Street, New Cumberland, PA 17070. This letter was mailed under the date of October 6, 2003 and never returned to the Sheriff's Office. 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: Jody M. Stafford, by regular mail to her last known address of 1105 Bridge Street, New Cumberland, PA 17070. Thi~ letter was mailed under the date of October 6, 2003 and never remmed to the Sheriffs Office. Swom and subscribed to before me This day of 2003, A.D. Prothonotary Real Estatd/Deputy MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, F/K/A The First National Bank of Chicago as Trustee 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff Roland D. Stafford, Mortgagor Jody M. Stafford, Mortgagor Philip Varughese, Real Owner 1258 N. Browns Dam Drive : New Oxford, PA 17350 Defendant(s) : P~IPE TO FILE PROOF OF SERVICE ATTORNEY FOR PLAINTIFF ' COURT OF COMMON PLEAS i CIVIL DIVISION . Cumberland County ]NO. 03-1875 Civil Te~? : TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 17, 2003 MARK J. BY: Mai Att UDREN & ASSOCIATES k J. Udren, Esquire, ESQUIRE )rney for Plaintiff Bank One, N];tional Association, et. al., Plaintiff(s) Roiand D. Stsffotnl, et. aL, Defendnnt(s) Service of Proce~ by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 MARK J. UDREN M~. Lfllian Torres 1040 North King~ Highway Suite S00 Cherry Hill, NJ 08034 AFFIDAVIT OF SERVICE -- Individual Service of Proce~ on: --Phillip Varghese Court Case No. 03-187S-Civil Term State of: ~/'~ )ss. Name of Server: ~ ~,~ ,~ (~) ~/~L~ , undersigned, being duly sworn, deposes and says that at the time of service, s/he was over the age of twenty-one, was not a party to this action; Date/Time of Service: thatonthe ~ dayof ~'~' ,20 O.~,at /0~Oo~clock /~M Place of Service: at 3122 Drexel Road , in Bensnlem~ PA 19020 Documents Served: the undersigned served the documents described as: Notice of SherifFs Sale of Real Property A tmpand correct copy of the aforesaid document(s) was served on: phtiilip Varghese Service of Process on: Person Served, and Method of Service: ~ By personally delivering them into the hands of the person to be served. [] By delivering them into the hands of suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is , a person of Description of Person Receiving Documents: Signature of Server: The person receiving documents is described as follows: Sex ~ ; SkinColor /~,~ ; HairColor ~l~td~ ~ FacialHair Approx. Age B~ : Approx. Height ~<ct ; Approx. Weight [L.t~ [] To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury and correct. that the foregoing is tree APS International, Ltd. APS File #: 062388-0001 (Date) Subscribed and sworn to before me this ~ day of /~o,,~t.,.~ ,20 Notary Public ~Com~im ~pires) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Bank One N A is the grantee the same having been sold to said grantee on the 10th day of Dec A.D., 2003, under and by virtue ora writ Execution issued on the .I st. day of Aug, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 1875, at the suit of Bank One N A fka First Natl Bk of chicago tr against Roland D Stafford & Jod¥ M & Philip Varughese is duly recorded in Sheriff's Deed Book No. 26!, Page 1564. 1N TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c~--~7' day of ~f/~c~ ~ ~-~ Recorder of Deeds Bank One, National Association, f/k/a The First National Bank of Chicago As Trustee VS Roland D. Stafford, Jody M. Stafford and Philip Varughese In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1875 Civil Term Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 09, 2003 at 1:45 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: Roland D. Stafford, by making known unto Roland Stafford, personally, at 102 5th Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 09, 2003 at 6:00 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: Jody M. Stafford, by making known unto Jody Stafford, personally, at 1105 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the sanae. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 09, 2003 at 3:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Roland D. Stafford, Jody M. Stafford and Philip Varughese located at 102 5th Street, New Cumberland, 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: Roland D. Stafford, by regular mail to his last known address of 102 5th Street, New Cumberland, PA 17070. This letter was mailed under the date of October 6, 2003 and never returned to the Sheriffs Office. 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: Jody M. Stafford, by regular mail to her last known address of 1105 Bridge Street, New Cumberland, PA 17070. This letter was mailed under the date of October 6, 2003 and never returned to the Sheriffs Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for Bank One, National Association, f/k/a The First National Bank of Chicago, as Trustee. It being the highest bid and best price received for the same, Bank One, National Association, f/k/a The First National Bank of Chicago of 1270 Northland Drive, Suite 200, Mendota Heights, MN 55120, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $65h93, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 12.78 Posting Bills l 5.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary h 00 Mileage 23.46 Levy 15.00 Surcharge 30.00 Law Journal 204.95 Patriot News 169.84 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 651.93 Sworn and subscribed to before me This ,,/~lay o~ 2004, A.D. rPrbthonotary So Answers: R. Thomas Kline, Sheriff Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Ac~ No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mamh 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 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S A L E #17 ~17 Sworn t a(f4,~;Ysubscribed before~,1~j3is 19th day ,ol'"Nove~2003 A.D. Ci~yOfHardsburg, Daup~nCounty ~ ~ ~ ~. ~ Uy~ ~r~ j~e 6,~ ~ NOTARY PUBLIC~ ~,pe~anlaA~~ My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 169.84 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL F~TATE SALE NO. 17 Writ No, 2003 1875 Civil Bank One, National Association, f/k/a The First National Bank of Chicago as Trustee VS. Roland D. Stallord. Jody M. Stafford and Philip Varughese Atty.: Mark d. Udren ALL THAT CERTAIN piece or par - eel of land situate and being in the Borough of New Cumberland, Cum- berland County, PermsyIvarda. more particularly bounded and described as fo[lows, to wit: BEGINNING at the northwest corner of the Old Warehouse Build- ing; thence along the line of Water Street to Pffth Street; thence by the Bne of Fifth Street to an alley; thence by the said alley to a point in the same equal in distance to the afore- SWORN TO'AND SUBSCRIBED before me this 31 .day of OCTOBER, 2003_ LOIS E, SNYDER, Nota~J Public Cad~e Bom, Cumbedand County My Commissim Expires M~ 5, 2~ Philip Varughese Atty.: Mark J. Udren ALL THAT CERTAIN piece or par cci of land situate and being in the Borough of New Cumberland, Cum- bet]and County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the northwest corner of the Old Warehouse Build- ing; thence along the line of Water Street to Fifth Street; thence by the line of Filth Street to an alley: thence by the said alley to a point in the same equal tn distance to the afore said front: thence in a ltne parallel with Lot No. 41, to the point or place of beginning, COMMONLY KNOWN AS 102 Fii;rh Street, and also subject to all conditions set lYrth tn the prior deed referenced in Deed Book 192, Page 1097. BEING KNOWN AS: 102 5th Street, New Cumberland. PA 17070. PROPERTY ID NO.: 25 24 0813- 062. TITLE TO SAID PREMISES IS VESTED IN Philip Varughes¢ by Deed from Tax Claim Bureau, of the County of Cumberland dated 12/ 2/02 recorded 12/2/02 Book 254 Page 3817. LOI Cad MyCo