HomeMy WebLinkAbout01-0930 FX
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N.KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota,
National Association fka
Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust 1999-BC4
P.O. Box 57038
Irvine, CA 92619-70~8
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL- DIVISION
: Cumberland County
v.
Richard Seeger
142 S. Locust Street
Camphill, PA 17011
Defendant_(s)
:No.OI- 9J6C,c..>~t I~
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT.' If you wish to defend against the
cla.ims 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.
YQU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYERS REFERRAL SERVICE
CUmberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166 or 800-990-9108
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AVISO
Le han demandado a usted en la corte. si usted qui ere defenderse
de estas demandas expuestas en las paginassiguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Race falta ascentar una comparencia escrita 0 en
persona 0 con un aqogado y entregar a la corte en forma escrita sus
defensas 0 sUS objeciones alas demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previa aviso 0
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero 0 sus propiedades u otros
derechos importantes.para usted.
LLEVE ESTA DPANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
o SI NO TIERS EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA '0 LLAME POR TELEFONO A LA OFICINA CUYADIRECCION .SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONOE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013-3387
717-249-3166 or 800-990-9108
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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
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copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
.admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor..
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and. mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached'document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
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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:
Assignee:
Recording
Option One Mortgage Corporation
Wells Fargo Bank Minnesota, National Association fka
Norwest Bank Minnesota, National Association, as Trustee
for SASCO Mortgage Loan Trust 1999-BC4
Date: LODGED FOR RECORDING Book: Page:
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 Plai~tiff as security for
the indebtedness.
Said Mortgage is incorporated herein by
ref~rence in accordance with PA.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 142 S. Locust Street
MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Lower Allen
COUNTY: CUmberland
DATE EXECUTED: 7/30/99
DATE RECORDED: 8/20/99 BOOK: 1565 PAGE: 404
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
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secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant (s) continues to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments. of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated J:>elow.
6. The following amounts are due on the said Mortgage as of
2/7/01:
Principal of debt due and unpaid
Interest at 10.4%* from 6/1/00
to 2/7/01
(the per diem interest accruing on
this debt is $15.31 and that sum
should be added each day after
2/7/01)
$53,722.23
3,858.12
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
250.00
280.00
Escrow Overdraft!(Balance)
(The monthly escrow on this account
is $0.00 and that sum should
. be added on the first of each
month after 2/7/01)
0.00
Late'Charges
(monthly late charge of $29.37
. should be added on the fifteenth of
each month after 2/7/01)
205.59
Corporate Advance
Field Service
Property Inspections
Attorneys Fees (anticipated and actual
to 5% of principal)
TOTAL
96.00
144.00
8.85
2.686 ]1
$61,250.90
* The Interest Rate and ~er Diem are subject to adjustment as
more fully set forth in the Note and Mortgage.
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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 oflntent~on 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 $61,250.90 plus interest,
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costs and at.torneys fees as' more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
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Mark J.Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
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ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN
THE TOWNSHIP OF LOWER ALLEN, CUMBERLAND COUNTY, IN THB COMMONWEALTH OF
PENNSYLV1tNIA, MORE PARTICULloRY DESCRIBED AS :rOLLOWS.,
BEGIImING AT A POINT ON THE S01lTllERLY LINE OF LOCUST STREET, WHICH POINT IS 145
FEET WEST OF UE SOUTHERLY COENER OF ALLEN ROAD AND LOCUST STREET; THENCE SOUTH. 49
DEGREES 27 MINUTES WEST, 102.68 :rEET TO A POINT; THENCE NORTH.51 DEGmS 21 MINUTES
30 SECONDS WEST, 66.17 FEET TO A POINT; THENCE NORTH 49 DEGREES, 27 MINUTES EAST,
115.09 FEET TO A POINT ON THE SOUTHERLY LINE OF LOCUST STREET AFORESAID; TRENCE
ALONG SAME SOUTH 40 DEGREES 33 MINUTES EAST, 65 FEET TO A POINT, THE PLACE OF
BEGIImING.
TAX HAP NO. HAP. 13-23-0555-055
BEING THE SAH2 PREMISES KNOWN AS 142 LOCUST STREET.
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September 06, 2000
OPTION
ONE
MORTGAGE CORPORATION
Richard Seeger
142 S Locust St
Camphill, PA 17011
6736
Homeowners Name: Richard Seeger
Property Address: 142 S Locust St, Camphill PA 17011
Loan Account No.: 192624-5
Original Lender: OPTION ONE - _ ___ ,____ _ ___::___
Current Lender/servicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENCY MORTGAGE -ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU. MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
,* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CON'rROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA.HOUSING'FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must -
arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the'end
of this Notice.
THIS MEETING MUST, OCCURWIT!1:IN THE NEXT (33) DlWS. IF. YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE; ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE pART OF THIS NOTICE CALLED "HOW TO. CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
EXHIBIT A
OPl71
CORPORATE OFFlce=.!i .. :3 ADA" IRVINE" CALIFORNIA. Q2811!1-2~" P.O. eox 6704' .. IRVINE" CALIFORNIA 92810-7041
PHONE 948.784.8'00 I 800.328.1500 . FAXLINE 849.784.&020
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Re: Loan No. 192624-5
MOF\TGAQ~ COF\POAATlO,,",
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this Notice,_
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of desiqnated consumer credit counselinq aqencies for the county in
which the property is located are set forth at the end of this Notice.
It is only necessary to schedule one face-to-face meeting. Advise
your lender immediately> of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the' reasons set forth later' in this Not.ice _ ~'see foJ.lowing pages - for-... ,_ . .
specific ~nformation about the nature of yo~r default.) If you have .
tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance. Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR'APPLlCATION PROMPTLY. IF YOU ,FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND
YOUR\APPLlCATION FOR MORTGAGE ASSISTANCE WI,LL BE DENIED.
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AGENCY ACTION - Available funds for emergency mortgage assistance
are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act.. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your
application.
on 71
CORPORATE OFFICES. 3 ACA" IRVINE.. CALIFORNIA 82818-2304" P.O. eox S7041 . IFlVINE.. CAUFOANIA 8281&07041
PHONE &48.784.8100 1800.32e.1500'" FAXLINE 8418.7....608
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Re: Loan No. 192624-5
OPTION
ONE.
MORTGAGE CORPOR....TION
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NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION .
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for
Emergency Mortgage Assistance.)
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HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
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NATURE OF THE DEFAULT - The MORTGAGE debt "held bY"theabove -lender'-ot1'
your property located at:
142 S Locust St, Camphill PA 17011
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts'are now past due:
(a) Monthly payments: 1 MONTHS @ $ 489.47
2 MONTHS @ $ 489.47
$ 1468.41
(b) Previous late charges; $ 58.74
(c) Other charges; Escrow, Inspection,
NSF checks $ 0
(d) Other provisions of the mortgage obligation,
if,any $ 5.00
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED I'
As OF THIS DATE $ 1532.15 ",
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable) :
HOW TO CURE THE DEFAULT -You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $1532.15, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash, cashier's check, certified
check or money order made payable and send to:
Option One Mortgage Corporation
3 Ada
Irvine, Ca. 92618
You can cU~e any other default by taking the following action within
thirty (30). days of the date of this letter. {Do not use if not
(applicable. )
OPl72
CORPORATE OFFICES. 3 ADA. IRVINE. CAUFOANI.... 92018-2304" p.o. sox 57041 .. IRVINE" CALIFORNIA 9ze1e-.7041
PHONE 848.784.8100 /8oo.328.11SOO. FAXUNE 848:7&4.6026
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Re: Loan No. 192624-5
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within
THIRTY (3Q) DAYS of the date of this Notice, the lender intends to
exercise its rights to accelerate the mortgage debt. .
This means that the entire outstanding balance of this debt will be .
considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount
past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your
mortgaged property.
""C?FtTQAaS CORPORATION
OP173
C:ORPQRATE OFFICES _ 3 ADA _ IRVINE" CALIFORNIA. 92018-230-4" P.O. BOX 670041 .. IRVINE" CALIFORNIA 92818.7041
PHONE 949.784.8100 /800.326.1 SOD" FAXUNE 949.784.8026
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OPTION
ONE
MORTGAGe: OORPORATION
Re: Loan No. 192624~5
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
Address:
Phone Number:.
Fax Number:
Contact Person:
Option One Mortgage Corporation
3 Ada
I'rvine, CA. 92618
800-326-1500, Ext. 8004
949-790-8182
AMBER ROJAS EXT 5766
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EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will
end your ownership of the mortgaged property and your right to occupy it.
If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could
be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You mayor X may not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will assume the
mortgage debt; provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the
other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT TO:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF /1/
TIlTS 'DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY
CALENDAR YEAR.)
*- TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTijER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
OP174
CORPORATE OFFices. 3 ADA" IRVINE - CALIFORNIA 82018-.2304 _ P.O. BOX 57041 _IRVINE - CALIFORNIA 8281&07041
PHONE 948.7&4.8100' 800.328.1600 - FAXUNE 948.'7~.8026
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P5 Form 3800, July 1999 See Re\lerse fef InstructIons
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V E R I FIe A T TON
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Mark J. Udren, Esquire, hereby states that he is the attorney
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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
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verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the, foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904relq,$:ing to Unsworn falsification to
authorities.
Mark J. Udren, ESQUIRE'
. MARK' J. UDREN & ASSOCIATES
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00930 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK MINNESOTA
VS
SEEGER RICHARD
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
SEEGER RICHARD
the
DEFENDANT
, at 0013:02 HOURS, on the 23rd day of February, 2001
at 142 SOUTH LOCUST STREET
CAMP HILL, PA 17011
by handing to
RICHARD SEEGER
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.06
.00
10.00
.00
36.06
So Answers:
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R. Thomas Kline
02/26/2001
MARK J. UDREN
c..
Sworn and Subscribed to before By:
tv
me this .;l. I' ~ day of
J~7 olAnJl . A.D.
Q(t'Ja~~
P othonotary .
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY LD. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota,
National Association fka
Norwest Bank
Minnesota, National
Association, as Trustee for
SASCO Mortgage Loan
Trust 1999-BC4
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
. NO. 01-930 Civil Term
v.
Richard Seeger
142 S. Locust Street
Camphill, PA 17011
Defendant(s)
PRAECIPE TO MARK SETTLED. DISCONTINUED AND ENDED
TO THE PROTHONOTARY:
Please mark the above captioned matter SETTLED, DISCONTINUED
and ENDED, upon payment of your costs only.
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Mark J. Udren, Esquire
Mark J. Udren & Associates
Attorney for Plaintiff
Dated: April 18. 2001
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>c ~
~ r:- ~
<:.:> -<
~