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Home My WebLink About01-1195 FX ."-,,,-,,- ~ l_ ~ , ~ J" ",,--I , " ~ >~~i , MARX J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRt HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) : NO. 01 - /190 Gu'~l Cy-~ 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 (2'0) 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 ciaimed 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 I;'APER 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ",-~ . ~ "~-- AV1SO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar ala corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado quesi 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 importantespara usted. LLEVB ESTA,DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO TIENE ABOGADO ~ . o SI NO T1ENE EL DINERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECC10N SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR AS1STENCIA~LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 -'-"""~""'" - .~ ~~ ., " J - ~"""""'~ 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 ofthis Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an , , , admission of liability on your part. Also, uJllon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to' you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm, is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 ~_ . ~ " d " , " ---"><=', 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 Washington Mutual Bank, its successors and assigns 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 Plaintiff as security for the indebtedness. said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 783 Longs MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 5/17/00 DATE RECORDED: 5/23/00 BOOK: 1613 Gap Road North Middleton Township PAGE: 859 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 Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 2/20/01: Principal of, debt due and unpaid Interest at 11.49% from 9/1/00 to 2/20/01 (the per diem interest accruing on this debt is $28.93 and that sum should be added each day after 2/20/01) $91,910.74 Title Report 4,551. 85 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balarice) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 2/20/01) 0.00. Late Charges (monthly late charge of $54.62 should be added on the fifteenth of each month after 2/20/01) 273.10 Corporate Advance Attorneys Fees (anticipated and actual to 5% of principal) 96.00 4 S9S S4 TOTAL $101,957.23 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 -">.",,,~ ~~ , " ~ -- 11-'. 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 $101,957.23 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 MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ".o-_"....~_ "',... ; :i . , , I I I 's.u.-"""",~ ",1>....- ."" -- i\lL THAT CERTAIN lot or piece of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by Thomas A. t;eff, Registered Surveyor, dated December 20, 1973, as follows: BEGINNING ata point in the center line of Long's Gap Road, Pennsylvania. Legislative Route No. 21072. said point being 120 feet South of the Southern line of Hillcrest Avenue: thence extending along land of Wayne Caleman, being Lot No. 12 on the hereinafter mentionoad pLau of lOLl!. ,lorth 72 deer.el!!ll 30 minute,S East 160 feet to a po'i.nt in line of land of Robert Carpenter: .' thence alo.lg said la.~d South 17 degrees 30 minutes East 60 feet to a corner of land of 3ames Eberly: thence along said land being Lot No. 14 on said Plan, South 72 degrees 30 minutes.West 1,60 feet to a point in the centel:" line of Long's Ga~ Road aforesaid: thence along said center line North 17 . de~rees 30 minutes West 60 feet to the point and place of BEGINNING. BEING LOT NO. 13 on a plan of lo~s laid out by Amos D. KecK which sa~d plan is recorded in Plan Book 4, Page 52; Cumberland County records. HAVI~G chereon erected a one story frame dwelling. BEING the same premises Which George R. M~ister and Nellie E. Meister by their deed dated June 13, 1978 and recorded June 26, 1978 in and for the Recorder of Deeds of Cumberland COunty in Deed Book W, 27, Page 446. granted and conveyed unto Uchard Brown and Joanne Brown, G1:antora herein named. This transaction is elCelllpt from transfer t8.lC aa it is between husband and wife into wife alone. ,,,---,. l~ _,,_1 .__. """~ '-t, e , .. December 04, 2000 OPTION ONE MORTGAGE:: CORPORATION Joanne Brown 783 Longs Gap Rd Carlisle, PA 17013 . Homeowners Name: Joanne Brown Property Address: 783 Longs Gap Rd, Carlisle PA 17013 Loan Account No.: 312209-0 Original Lender: Optton One Mortgage Current LenderjServicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ~ROGRAM 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 CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS. ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. 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. OPl71 E}~b;iBIT A ~..._=.... COFlF'OFlATE OFFICES - 3 ADA - IRVINE - CAL.IFORNIA 92618~2304. P.O.'BCX 57041 - IRVINE - CALIFORNIA 92619-7041 L:J F'l:iONE 800.326.1500 - ~a.784.6100" FAXLINE 949.784.6032 I ~,_.~-~' " ....~~ _ J """""""" ~ ~~_"""-""'J e. OPTION ONE Re: Loan No. 312209-0 MOFlTGAGI: OOFlPOFlATION 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 designated consumer credit counseling agencies 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 fprth later in this Notice (see following pages for specific information about the nature of your default.) . If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file 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 APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the 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. OPl71 ~::-_=_... CORPORATE OFFICES _ 3 ADA" IRVINE. CALIFORNIA 92618-2304 - P.O. BOX 57041 - IRVINE - CALIFORNIA g2e19~7041 1:J PHONE 600.326.1500" ~9..784.6100. FAXLINE 949.784.6032 :,"",....__~'odD ~ I~ L. 1-, .1_1 ~ """""'''''~''''''",.,,-';,.......:'''''''';!, .,P e. Re: Loan No. 312209-0 OPTION ONE MORTG....GE CORPOR....TION ********************************************************************** 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 COLhECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE) . NATURE OF THE DEFAUL~ - The MORTGAGE debt held by the above lender on your property located at: 783 Longs Gap Rd, Carlisle PA 17013 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 @ $ 910.37 . 2 MONTHS @ $ 910.37 $ 2731.11 , (b) Previous late charges; $ 109.24 (c) Other charges; Escrow, Inspection, NSF checks $ 0.00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2840.35 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 $2840.35, 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 cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable. ) OP172' ~:-."=...... CORF>ORATE OFFICES. 3 AOA _ IRVINE. CAL.IFORNIA 92618-2304. p.o. BOX 57041 . IRVINE. CALIFORNIA 92619:7041 ~ PHONE BOO.326.1500. 949.784.6100. FAXLlNE 949.784.6032 ,--'a" ~~~- "'-~~~~ . .~~= "" """"~ - j ~. H. "=--c~";li',. e. OPTION ONE Re: Loan No. 312209-0 MOI'lTGAGE COI'lPOI'lATION IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice,the lender intends to exercise its riqhts to accelerate the mortqaqe 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. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you ,will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender. may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the riqht to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writinq by the lender and by performinq any other requirements under the mortqage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OP173 ~-=,.." CORPORATE OFFICES. 3 AOA. IRVINE - CALIFORNIA 92818-2304. P.O. BOX 57041 . IRVINE. CAI...IFORNIA 92819-7041 ~ PHONE 800.326.1500.949.784.8100 - FAXLINE 949.784.6032 I '_M',,-""_'''_' - . , ~ "~N~" e. OPTION ONE MORTQAQE;: CORPORATION Re: Loan No. 312209-0 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-784-6032 Rushie Taylor x5769 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 THIS DEBT. * . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU 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 OTHER 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. CALlFOANIA 92618.2304. P.O. BOX 57041 . IRVINE. CALIFORNIA 92619~7041 ~ PHONE 800.326.1500 1949.784_8100" FAXLINE 949.784.6032 ?;~..... ~~-w.mii!ill;~",,"~ l"'- Jl rn rn Jl l"'- r'l U1 postag.. s \ I $ postmark Here CertiliedFee l"'- r'l t::I t::I t::I t::I :r rn Return Receipt Fee (Endorsemer,\ Required] Restricted Delivery Fee (Endorsement Required) . Total postage & Fees 'Street~'APCNo.~.-or-p(nfo~.N-O..-.n.--.-..-.n.--.-.~--~____._.~.._nd_~__.___.~.n.n.~ Redpient's Name (Please pnnt Ciearly) Ito be completed by matlerj tr tr t::I l"'- 'Ci~~"siaie.~ziP:;'4.~----.--n.- .n.n.n'~ d~ ..~..~..__~.__" - .n.~..~.n_n~__~~'~____~~"~ --;:-_ ""7"-' _:t",=-'SeeR~Ye(S ...~.Iit....I'llottl.lul- lJ1:1i1iiillCtOl.I'S.ii[~imr.l.r;V";J;I'IIEI!>'---'--' d.---'" ,~~ " - --I llialbii' V F. RTF I CAT ION ,Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source. of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn ,falsification to authorities. 1tr\ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES ~!il~~s~j{4i'!f<iM~.~~.;l~tlli;h!~J"~l!'Uill^n\'{;';'~dlj';'-";',:~J-"iI.;"~i'",j"-""GiH_W;j~~i:"i!<-:iI;_d\Jjiffl1",I~liliIIIii.:1,~IIMlli~',jjm.J~1lI~1 ". ""-~ 'ig, ~~ , . -p (:J -!:::. ~l Iii ~ o ~ 0 D ~J ~~ I\)V 8~p:~ ~~ --< Ci C. 2;: , g -:J C:'- r,; i' -/ ..c___ ~~::: '-, u:; ~--: ;:.s ~, ----- ~ ,---." 'f1 r , ) -- "r ~ ~ ". ~ti? >c--:: z "1--'" __-l ~ :iJ -< .;;::- -< ,~_:_< ' f"".) ,_,/ t& ~ f> r ~f ~.- fl- . i r f ~ It. .1 ,.' .W.' l~ =---W~~~~'H:.(' 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 WE HEREBY CERTIFY THE WITHIN TO BE TRUE AND '. CORRECT COpy OF THE ORIGIN ATTORNEY FOR PLAINTIF Washington Mutual Bank, its successors and assigns P.o. Box 57038 Irvine, CA 92619-7038 Plaintiff : COURT OF COMMON PLEAS : CIVIL PIVISION : Cumberland County v. Joanne Brown f 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) - : NO. or-II9S 8o~L ~~ COMPLAINT IN MORTGAGE FORECLOSURE v YOU,aAVE BEEN SUED IN COURT. If you wish to defend against th~ 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 ~he Court without further notice for any money ciaimed 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 SJlOULD 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. Cumberland County Bar Association ,2 Liberty Avenue Carlisle, pA 17013-3387 717-249-3166 or 800-990-9108 TRUE COpy FROM RECORD III TeetImony wtl8reof, ! lwra unto _my hInlt .. .... seal 0<< $aidWirt at CarU$lo, Pa. ~ ~ daY.~~ ~_~ ___ ,Lh n./>o t?_~' _ ,~ ~ >;:,_\i~- ". " , - - AVl:SO ....;-.~~..".";,,,<=i"""',j; Le han demandado a usted en lacorte. si usted quiere defenderse de .estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que-si usted no se dafiende, la corte tomara medidas y puede continuar la demanda' en contra suya sin previo aviso 0 notificacion. Memas, 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. f.LLEVE ESTA DBMAmlAA tIN ABOGADO IMMEDIATAMENTE, SI NO TIENB ABOGADO o SI NO TIENE EL DINER.O S'O'FICJ:ENTE DE PAGAR. TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR, TE'LEFONO A LA OFJ:CINA CUYA, DIRECCJ:ON SE BNCtJENTRA ES,CRITA ABAJO PARA AVERIG'O'AR. DONnE SE PllEDE CONSEG'O'IR AS ISTENCIA LEGAL. v Cumberland County Bar Association 2 Liberty Avenue' Carlisle, PA 17013~3387 717-249-3166 or 800-990-9108 --~.. __'0" .~ i. , .,;....~'i:"" INOTICE I , The amount of your debt is as stated i4 the attached document. The name of the creditor to whom the debt is owed is as named in ~e attached document. Unless you notify us within , 30 days after receipt of this Notice and ~e attached document that the validity of the stated debt, or any portion ofit, is disputed, we ~ assume that the debt is valid. If you do notify us . in writing of II dispute within the 30 day Iperiod, we will obtain verification of the debt or a I /copy of a judgment against you, and mail ~tto you. If you do not dispute the debt, it is not an admission of liability on your part. Also, ~pon your written request within the 30 day period, we wiIJ. provide you with the name and a~dress of the original creditor if different from the current creditor. , , v . If you notify us in writing within the 301 day period as stated above, we will cease collection of your debt, or any disputed portion of ~t, until we obtain the information that is required and mail it to you. Once we have mail~ to you the required information, we will then continue the collection-of your debt. This law firm is decmed to be a debt coll~ctor and this Notice and the attached document is an attempt to collect a debt, imd any infotmation obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl M~k J. Udren, Esquire 1040 ~. Kings Highway, Suite 500 Cherh: Hill, NJ 08034 (856)!482-6900 '~-"""""r---""'" - ~ .:_,,,,," ~ ~~~ ~ -r,~"",'^,~'- 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: Option One Mortgage Corporation Assignee: Washington Mutual Bank, its successors and assigns Recording 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), Plairttiff (or its predecessor, hereinafter called Plaintiff) loaned to ,the Defendant (s) the sum appearing on said Mortgage, which ~ortgage was executed and delivered to Plaintiff as security for v the indebtedness. said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 10~9 (g). The information rega:r:ding the Mortgage being foreclosed is as, follows: MORTGAGED PREMISES: 783 Longs MUNICIPALITY/TOWNSHIP/BOROUGH: CQUNTY: Cumberland DATE EXECUTED: 5/17/00 DATE RECORDED: 5/23/00 BOOK: 1613 Gap Road North Middleton Township PAGE: 859 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. ',c""''"~ ~, v .J -, ;." 'ti..~Iil1i.if.$~,:} 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 2/20/01: ( Principal of, debt due and unpaid Interest at 11.49% from 9/1/00 to 2/20/01 (the per diem interest accruing on this debt is $28.93 and that sum should be added each day after 2/20/01) 4, 551. 85 $91,910.74 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.09 280.00 Escrow Overdraft/(Balarice) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 2/20/01) 0.00 Late Charges (monthly late charge of $54.62 should be added on the fifteenth of each month after 2/20/01) 273.10 ~ Corporate Advance Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 96.00 4,595.<;4 $101,957.23 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 "..~..ili;"".... ~. "- '~~;tl!l~::-~',."-''!'4..'<>'.;,,;, 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 "Ao, 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 demanqs judgment, in rem, against the 'Defendant (s) herein in the sum of $101,957.23 plus interest" , ~ costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. 'Y1 Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D.- No. 04302 ~.-~ ~~-'- ""." ! :1 .' , , I ,. J f I v - ..L '-~0iJlli~ - - ~ll THAT CERTAIN lot or piece of land situate in North Middleton Township, Cumberland County. Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by Thomas A. Neff, Registered Surveyor. dated Decembet 20, 1973, as follows: BEGINNING at a point in the center line of Long's Gap Road. Pennsylvania, Legislative Route No. 21072. said point being 120 feet South of the Southern line of Hillcrest Avenue; thence extending alon~ land bf Wayne Caleman. being Lot No. 12 on the hereinafter mema.ouoad pl.ll" oE 10L~ !lorth 72 deer.eell 30 minute,S East 160 feet to a potnt in line of land of aobert Carpenter l .' tnence alo.lg sllid lal~d South 17 degrees 30 minutes East 60 feet to a corner of land of 3ames Eberly, thence along said land being Lot No. 14 on said Plan, South 72 degrees 30 minutes West 160 feet to a point in the center line of Long's Gap Road aforesaid: thence along said center line NOrth 17 . de$reeS 30 minutes W~st 60 feet to the point and place of BEGINNING, BEING LOT NO. 13 on a plan of lo~s laid out by Amos D. Keok which sa~d plan i8 recorded in Plan Book 4, Page 52; Cumberland County records. ' . , . HAVING thereon erected a one story frame dwelling. . BEING the 8ame pr~i8e8 Which George R. Heister and Nellie E. Meister by their deeG dated June 13, 1978 and recorded June 26, 1978 in and for the Recorder'of Deeds of Cumberland County in Deed Beok'll', 27, Page 446. granted and conveyed unto IU.chard Brown and Joanne Brown, ,G1:antora . herein 118l11ed. ,This tranaaction i8 exemp,t fr01ll tranafer tax a8 it 18 between husband , and wife into wife alone. ~~ . ,,' -. '~"::-''''B'iiik<iWrti&;,;;i e. December 04, 2000 OPTION ONE MOFlTOAGE COFlPOFlATION Joanne Brown 783 Longs Gap Rd Carlisle, PA 17013 Bomeowners Name: Joanne Brown Property Address: 783 Longs Gap Rd, Carlisle PA 17013 Loan Account No.: 312209-0 Original Lender: Opt~on One Mortgage Current Lender,lServicer: Option One Mortgage Corporation f 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 CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABL1SHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure ,on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAY,S. 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. OPl7l ~;;;l\~C,.PJO'T A , .,' ~~!Q ;;;1m , ...~ ~-:_. CORPORATE OFFICES" 3 ADA . IRVINe - CAL./FORNlA 9.281&-2304" P.o. 'eox 57041 . IRVINE" CAl.IFOANJA liI2eJ;19-7'041 -..=.J P~ONE 800.326.1150q:.. 949.784.8100" FAXLINE 949.784.8032 'J'~~""""'- -- ~ ."-~ . " .'" ,~j -"-~ . ~ ~. - ~;^'""'~"'~"'~t i e. OPTION ONE Re: Loan No. 312209-0 MORTQAGE CORF"ORATION 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 counseling agencies for the county in which the property is located are set forth at the end of this ~otice. 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 fprth later in this Notice (see following pages for specific information about the nature of your default.) . If you have ~ried 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 Appliqation with one of the designated consUmer credit counseling agencies listed at the end of this Notice. Only consumer credit couns~ling 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. v YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the 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. OPl71 ~-=-, CORPORATE OFFICES'" 3 ADA. IRVINE'" CALIFORNIA 9281S-2304'" P.O. BOX 67041 - IRVINE'" CALIFORNIA 8281."041 1.:.1 PHONE 800.32&.16001- 949.784.8100 - FAXLINE 949.784.8032 ,,"-t<1ii~o-.l:::"< "'" - I J .~ - ~.- f"~"-",",-~_"" ,p e. Re: Loan No. 312209-0 OlPOTION NE MO...TG....GE CORPO.......TION *******************************~************************'************** 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 COL~ECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) *~******************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). NATURE OF THE DEFAUL~ - The MORTGAGE debt held by the aqove lender on your property located at: '783 Lonqs Gap Rd, Carlisle PA 17013 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 @ $ 910.37 2 MONTHS @ $ 910.37 $ 2731.11 . (b) Previous late charges; $ 109.24 v (e) Other charges; Escrow, Inspection, NSF checks $ 0.00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2840.35 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 -(3D) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $2840.35, PLUS ANY MORTGAGE PAYMENTS ANn 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 cure 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" CALIFORNIA 928184304" P.O. BOX &7041" IRVINE" CALIFOFlNIA 92618-7041 PHONE 800.328.15001- 949.'784.8100" FAXLINE 948.784.8032- I @ .. --- "'~Mil,"",'",d"J"l&!t="O~,",_ " e. OPTION ONE Re: , Loan No. 312209-0 MORTGAGE CORPORATION IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riqhts to accelerate the mortqaqe 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 mortqaqed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers ~our case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you ,will not be required to pay attorney's fees. v OTHER LENDER REMEDIES - The lender,may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have ,the riqht to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by payinq the total amount then past due, plus any late or other charqes then due, reasonable attorney's fees and costs connected with the foreclosure sale and any bthercosts connected with the Sheriff's Sale as specified in writinq by the lender and by performinq any other requirements under the mortqaqe. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. ' EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OP173 ~-=_.. CORPORATE OFFICES. 3 ADA" IRVINE" CALIFORNIA 92818+2304. P.O. BOX 67041 . IRVINE. CALIFORNIA 82619-7041 -...::..I PHONE 800.328.15001- 948.7~.8100" FAXLINE 949.784.6032 ~ " I , ~'''it~,i-, e. OPTION ONE MORTGAGE COFlPOFlATION Re: Loan No. 312209-0 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 8DO-326-1500, Ext. 8004 949-784-6032 Rushie Taylor x5769 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will ~ndyour 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. v 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 THIS ,DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU 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 OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 . ~-="--" CORPORATe OFF"ICES" 3 ADA.. IRVINE.. CALIFORNIA 92618--2304" P.O. BOX 157041 .. IRVINE" CALI....OFlNIA 92B1D-7041 1...:.1 PHONE BOQ.32e.150q'" 949.784.6100" FAXUNE 949.784.8032 , ['- ...!l m m ...!l ,['- 'r'! Ll1 ['- r'! 0 0 1 0 0 ;:r m n- n- O ['- u.s. PoStai:serv1ce'::' .,;.: "'.' ,:"..:' ':. ',.: ,,~";':', CE.E!'f'\FIEO:JIi.!A.II,.'B$~Ip,:( \.. :):';~'/, fDomiiStic Mml.oiiIy;N,o !JJ?~I{IDce;'t?overag~~videdX :~",',,' .' . ~. ;..' " . ' \~'. ",'1 ,~",..~.,' :., ~,~"., ,'.,. ~,: 1 ':'...."f.',J',':'.'..-~) :"'r.:'~i<' -,,\...,.....'.~,.~. 16(D<:; ,,I 3/d 8.oq 0 Is .. POs.tag.. Cert-rfiedF~ POS'1mark Return Rec~ipt Fee ".'" (Endorsement ReQuired) Restricted~liveryFee {Endorsement Reql:lredj . Total Postage & Foes $ Rllcipient's: Name (please Pnrir Ciearlyl (to be c:ori'lprere:;, 0.1' m8llerj srre9:~ApTtiro.;.o;:.p(TBo~NQ:---._..u.._....~.~._.~_-....n.-_._~._~-~--....~-.....- 'CIt}~'sra;;:i:7P"+:l.-.-~.--~.~.-;--..._..n. _......_._-.._".-.~_..-..._.~-.=~-~_=-_-_._.._.~.._~ D:.i-.'....'.......!:lt!.lU:0.'..",..,.....JJ]J.;J-. _ _ K:. _ '",_. "':';..>1:~l~""''''''..'r.r<!f.l'''''''..i'.l.~-P ~ ~ - I. .' ~. - 'M.I ".L~' ',!,,,~~-'<-i:.~~:J:_"-l , , V E R I FTC A T TON , 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 f,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 v this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn .falsification to authorities. m Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES _~~_!i:t;it.:tr1il1i1J<,lI}i!!lt.'f&\:1!jIWji~~~M<ffi;ii!(d;,'":"'.fu,_""",g'C'L"<>,-'-'1"":i"'di;,~~<;fl~.ili!lilll.!il8UJli"lift_~;~~i[W~~I"""'''''' ']"'"1"-- ~, (~ ~. \I\lfV^1),SH~3d 31 ~^: r" _.:,,\1.') \0. "J aE t \ ~,~ ~ll"lCU, i'i.CJ ilHn\) j.:l11l3HS .Hi ,10 3nl~~O ,.- ... , ^ ~ ~ ,. '-.-. =~d__,;, \ SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01195 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS BROWN JOANNE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT BROWN JOANNE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE . NOTICE , NOT FOUND , as to the within named PEFENDANT , BROWN JOANNE DEFT. MOVED, LEFT NO FORWARDING, RETURN NOT FOUND ~S PER HEATHER 3/14/01 Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 3.10 5.00 10.00 .00 36.10 ~ -~.//"."'. R. Thomas Kline " Sheriff of Cumberland County MARK J. UDREN 03/13/2001 Sworn and subscribed to before me this ~ ~..., - day of ~ ~J A.D. ~, ,(.f, "/JupL / 4~ Pro onotary I ,.""",i;j;,,,,,,,,,,,,,,,, ~ ; ~ . .~ '1~""---'" "~.. '-'-'-'-'!!>lk^ MARKJ. 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 Washington Mutual Bank, its successors and assigns Plaintiff : COURT OF COMMON PLEAS : CIVIL DMSION : Cumberland County v. Joanne Brown Defendant(s) . : NO. 01-1195 Civil Term MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Complaint In Mortgage Foreclosure upon Defendant(s), Joanne Brown by regular mail and certified mail and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) at 783 Longs Gap Road, Carlisle, PA 17013, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit B. 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint In Mortgage Foreclosure Lo""'"''"'" -~ =- ""'--~J~~..",_yk..', by regular mail and certified mail upon said Defendant(s), Joanne Brown. MARK J. UDREN & ASSOCIATES ~----- By: Mark J. U ren, Esquire Attorney for Plaintiff <<~- ~ - ~ ~~~1";, MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS IllGHWAY, SUITE 500 CHERRY IllLL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns Plaintiff : COURT OF COMMON PLEAS : CML DMSION : Cumberland County v. Joanne Brown Defendant(s) - : NO. 01-1195 Civil Term MEMORANDUM OF LAW Pennsylvania Rille of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165,360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Complaint In Mortgage Foreclosure. A good faith effort to discover the ,--",,~" WI. ~~ ....~~ ~.~ -,I. h!illlil_,"'~"<""",,,,-._", whereabouts of the Defendant(s )has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint In Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail. MARK J. UDREN & ASSOCIATES By: nil Mark J. Udren, Esquire Attorney for Plaintiff -- ';'i:~~ "' -- ~ .~- . , ,," .. ~ ~" ~~'~<,i" SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01195 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS BROWN JOANNE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a dilige~t search and inquiry for the within named defendant, DEFENDANT BROWN JOANNE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , .BROWN JOANNE DEFT. MOVED, LEFT NO FORWARDING, . RETURN NOT FOUND AS PER HEATHER 3/14/01 Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 3.10 5.00, 10.00 .00 36.10 So an,.~ ~s K;:::' ,'" ',', Sheriff of Cumberland County MARK J. UDREN 03/13/2001 Sworn and subscribed to before me this day of A.D. , Prothonotary EXHIBIT A al~o'1'b~ , . ~. .. "". ",~" '" -. '-;-j- Mar-29-01 09:04pm From-PLAYERS ASSOCIATION 5952300559 T -093 P. 14/23 H22 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number 0123933 Anomey Firm: MARK J UDReN & ASSOC.A TES Case Number: Subject: JOANNE BROWN At< A JOANNA a aROWN L.ast Known Address 783 ~ON~S GAP ROAD CARLISLE. PA 17013 Last Known Number: ( I - Michael K Gross. being duly sworn aCCOrding to law. deposes ane! says 1 I am employed In Ine capacitY of President for Players National L.ocator 2 On 03/25/2001 , I conducted an investigation into me wnereabouts of the allove named defendant(s) Tne results of my investigation are as follows: CREDIT INFORMATION- A SOCIAL SECuRIll' NuMBER: 224-56-2822 B EMPL.OYMENT SEARCH: Unable to locate a good employer for Joanne. C INQUIRY OF CREDITORS The creditora indicated that Joanne is usung 783 Longs Gap Road, Carlisle, Pa. 17013 with no valid home phone number. INQUIRY OF TEL.t:PHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has 00 listing for Joanne Brown. INQUIRY OF NEIGHBORS - Contacted 717-249-5301 registered at 780 Longs Gllp Road and spoke with a neighbor who stated Joanne Brown moved out of the last known address about a month ago. She had no forwarding information for Joanne. INQUIRY OF POST OFFICE- A NATIONAL. ADDRESS UPDATE As of March 20, 2001 the National Change of Address (NCOA) has no change for Joanne from last known addru$. MOTOR VEHICL.E REGISTRATION- A MOTOR VEHICI-E & DMV OFFICE The Pennsylvania Depal1ll1ent of Drivers Licensing has Joanne'is1ed at last known address. OTHER INQUIRIES - A. DEATH RECORDS: Afi of Mart:h 20,2001 the Sot:ial Sl3curity Administration has no death record on file for Joanne Brown and or a.k-a.'s under her Bociallilllcutity number. EXHIBIT e ""-". ",- , "';~U'!~; Mar-28-01 03:04pm From-PLAYERS ASSOCIATION 6362300558 T-083 P .15/23 H22 B PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None Found C COUNTY vOTER REGISTRATION: The CUmberland County Voters Registration Office hilS no listing for Joanne. ADDITIONAL INFORMATION ON SuBJECT- A. DATE OF BIRTH: 08/41 "NOTAAY SEAL" Kri8liI)e M. SIlOll. Nll1aIy Pubfic SL LOuis CoIlllIV. SIal. of ,Missouri My Commission exPires 91112002 Players Narional Locator 113 Old State Road, Suite 104 St. LOUIS, MO 63021 Phone. (636) 23CJ..9922 Fax. (636) 23CJ..0558 EXHIBIT B ~~'_.m -~ ~ ~ 1IIliIIRiiI11i<l.. ~!iili VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. See 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES Date: 3 -z<r- o{ Mark J. Udren, Esquire Attorney for Plaintiff ~...-,ru,,",~ . ~~~ ~ .w ~. =~ """" MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS mGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and assigns Plaintiff v. Joanne Brown Defendant(s) l , ~~"~ ~ '-"'"",""'d~'-;,,'''''''''-- ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County - : NO. 01-1195 Civil Term CERTIFICATE OF SERVICE I, Mark J. Dillen, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attoruey of record by: Regular First Class Mail x Certified Mail Other Date Served: ..:s ~ z ? - 0 I TO: Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 MARK J. DDREN & ASSOCIATES By: Mark J. Dillen, Esquire Attoruey for Plaintiff --"~""""'-~ - LAW OFFICES MARK J. UDREN & ASSOCIATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HUL, NEW JERSEY 08034 856. 482 . 6900 FAX: 856. 482. [[99 MARK J. UDREN' STUART WlNNEG" GAYL SPIVAK ORLOFF"" HEIDI R. SPIVAK*" CHRISTOPHER J. FOX'" CORINA M. CANIZ'" .ADMlT1'ED ALSO IN PA AND FL ....ADM17TED ONLY IN Pft .........ADMITTED ALSO IN FA TINA MARIE RICH OFFICE ADMINISTRATOR FREDDIE MAC PENNSYl.VANIA DKWGNA TED COUNSEL "PLEASE RESPOND TO NEW JERSEY OFFICE" March L'1, 2001 Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Re: Washington Mutual Bank, its successors and assigns vs. Joanne Brown Cumberland County C.C.P. No. 01-1195 Civil Term Dear Joanne Brown: ~'~~".~ ~~,. .. PRNN.~Y1,VANIA OFFICR 24 NORm MERION A VENUE SUITE 24Q BRYN MAWI/, PA 19010 215-568-9506 215-568-1141 FAX In connection with the above captioned matter; enclosed you will find a copy of the Motion for Alternate Service which was sent for filing on March L'1, 2001. TillS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Should you have any questions, please contact our office. dren, Esquire J. UDREN & ASSOCIATES /cmw Enclosures !~.l\iiliiTh;,~_";i.'l,",,,;,!""ll;~""ilih.j:~!~'of~o"i"~'J-J;",_\!'h>"li'fM""",""~,,&,"^"'t"":"~_::li~"""ill'.,,,~lj&_.ili~h...~~ilI1iilllill!Wlti~~~u~ M~ _^"., ,-,~~ ir ~ -"'~...-" " Il'i~ "'_l!llilll"ii,,~.iiliIij o <.;:, s:V: .<0:"-"-"_ ~::-:: r-.:C:': <- )::C~ bL, ;pc 2' ~ o --(J -:::,:J \ " \' ~ -.~"'" - :.. ~'. '\ (.__,l(~ c"~;: ~'A (.J ::::.: 2:'0 ::<: - - N ...l ~ . f_,il~_""".,.....~ ,~. , ~.~ ! - "'~" ~ ,~ , '~~"""'"''o.~'''''~''"-~''',J,'> . MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS IDGHWAY, SUITE 500 CHERRY IllLL, NJ 08034 856-482-6900 IlPR 0 52001fj) ATTORNEY FOR PLAINTIFF , Washington Mutual Bank, its successors and : COURT OF COMMON PLEAS assigns : CML DMSION P.O. Box 57038 : Cumberland County Irvine, CA 92619-7038 Plaintiff . : NO. 01-1195 Civil Term v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) ORDER AND NOW, this I (~ day of ~ , 2001 ,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint In Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Joanne Brown, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Complaint In Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s) , Joanne Brown at 783 Longs Gap Road, Carlisle, PA 17013 and by posting the mortgaged premises at 783 Longs Gap Road, Carlisle, PA 17013. BYz;a 'ff ~:J -=""",",,",' " I: :\ .' ~ -" - l-([,~~, ~ APR 0 5 200tfl) , MARK J. UDREN & ASSOCIATES J . 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 Washington Mutual Bank, its successors and assigns P.O, Box 57038 Irvine, CA 92619-7038 Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : NO. 01-1195 Civil Term v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) ORnER AND NOW, this J J th day of F\ pr'tl , 20 0 I ,upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint In Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Joanne Brown, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint In Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s) , Joanne Brown at 783 Longs Gap Road, Carlisle, PA 17013 and by posting the mortgaged premises at 783 Longs Gap Road, Carlisle, PA 17013. BY THE COURT: /5/ thlff}~j {' CYill J. ~1!,j;~~~1l$itlIIl";;;'I~;'Bill.;g,:Si'~.",j~"""'~_4"iE~',,=,:",rr*'''.!6a''!!!b'~i''M:~'~AA",",~*ir_,"""O""-,'':'''''~'''''''o8lii'i.: ~" "'iilllilial.....,~' '^ .Il'....o , '"'-- ~ 0 C:-;. ,-' C~ c , ~: L. 1_-, c.:;: c:: fTt E " Z I -, ., Z j~- en ;~~: '..::::: ::' ~S ..C. ::;", (i L_ C; > C 1"'...) :z: ;~,.) '-', =<' -'-' .~ ~-'..., . l-_""~,,,,-- . , , - - -~ ~~ .'- '" - ....... ,-- ~'i;lj,,-.il-_;_ .. '- MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 1040 N. KINGS lllGHWAY, SUITE 500 CHERRY lllLL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and assigns Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION : Cumberland County v. Joanne Brown Defendant(s) : NO. 01-1195 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Complaint In Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: '-\\al.\ \D\ Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: MARK J. 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'~ J;il.-.J...b.f SHERIFF'S RETURN - REGULAR CASE NO: 2001-01195 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS BROWN JOANNE KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BROWN JOANNE the DEFENDANT , at 1648:00 HOURS, on the 20th day of April , 2001 at 783 LONGS GAP ROAD CARLISLE, PA 17013 by handing to POSTED THE PROPERTY LOCATED AT 783 LONGS GAP ROAD, CARLISLE 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 Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: . r'.{Jt~'~~(1~.!~ R. Thomas Kline ,04/23/2001 MARK J UDREN Sworn and Subscribed to before By: 4wt{ me this ),...,~ day of ~ ,J.,ru/ A.D. ~'.L- (] lH.o;'~ "A~7i rothonotary ~~">> = ,~ = > e ~__ ""~>.~ ~'~--;;, 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 Washington Mutual Bank, its successors and assigns P.o. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1195 civil Term v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: April 16, 2001 MARK J;;~S Mark' J. Udren, ,ESQUIRE ATTORNEY FOR PLAINTIFF ",-,I ,~ ~=~';~;l!;\";';"__ ,. MARK J. UD~N & 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 Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 civil Term Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (sl 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 @11.49% From 2/21/01 to 6/04/01 @$28.93 Late charges per Complaint From 3/15/01 to 6/04/01 @$54.62 $101,957.23 3,008.72 163.86 TOTAL $105.129.81 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 UDREN & ASSOCIATES Mark J. Udren, ESQUIRE Attorn y for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE:" )'I,)r: I.? ..:llX>1 , INDICATED 4 (J J/1 -t... OJ ~ PRO PROTHY jjjf Mii!~'M'lhil<'iIllill-1i!ll~fJl:~lm,li&1l1:iL'i<&l-~~h;&b~i'ci>j."j"",.i;:i:"H~~i:'4\M~il!.iliI!~-~\ ,,'" ,~ ~~~~ ~, ~",,, ~-,- ~ ~- . (") 0 () C --n s:: ~ -oU1 c: rnrn ';,t: :2J Z.:J.:.J ,-- 2C C~S (J)d::.:.. W ~..c, r.:;O "'" '''':'- -'1 :1>0 3': ~~B 20 )>C (3rT) 2 N :;! ::< :0 D::> -< - -d.~~~ ""'" , ~jn'ij1,i MARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and assigns P.O. Bo:lC 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF i COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) NO. 01-1195 civil Term May 17, 2001 Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU; UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 DATED: TO: NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME ,POR TELEFONO A LA OFICINA, CUYA DlRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ;~oil~l!,\1&!~,llit"Jll$f..j!1~""Jl;iIli1ti!tMl*illi.!Yll'i!!!_<'M\\I!>"~1Ai1'W.i8!i-,2i.&.Jdl,"',"l"-~,4','~"","&""_"""lml!fl~I__iIIilaillli't ~"'" '"",111';-& ,,- ., .-i~' ~,'" 'illi""""'~"'''' o ~ .~ -oC';.\ .....,t1:\ 'Z:s; -Zc:~ (p.?-7 %~, f.2\...~i "E;Q ?-:;L) '57c ~ o ..- I,", S--;:; ""'... ..- '-"" ., 0\ ~ -::;,. ..- .- .- ~,\t; -~'Y'-'( \~~"C.} --,}.-\I --,--'(\ ~~~~ 9. ~ ::<::. N cP . ,.""o.,t" - . .'-.", "' .-, - ~~t_ 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 Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Joa=e Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-1195 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COuNTY OF CAMDEN THE' UNDERSIGNED being duly sworn, de~oses and says that the averments herein are based upon invest~gations 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: Defendant: Age: Residence: Employment: Joanne Brown Over 18 As captioned Unknown Over 18 As captioned Unknown Sworn to and subscribed ,before me this 4th day of June, 200l. 1 ,~./'l, ~c , '.JACQ.UElINE A. GRIESS )'<'.Ml.~~ry'eubilt 01 New Jersey My comrois~ion Expires 41112003 above above tJ Name: a k J. Udren, Esgu~re Title: Attorney for Pla~ntiff Company: Mark J. Udren & Associates "-."~LiI. h"'~i'<W'IOW"I~illt ~lr~j*,Gil';ilU>.k~i,;,]3>\1i..4",-",,,..--~-~.j'~"~"'i'd'~i>.-#ii;ii~1llil!i:l)i;J ~~-;...........~. . -~.;'-'lj,-;;'''' ~ l~~ '- ~"b.!ID~ . t t ~ ~ 0 D C 0 <'" '-on -0-"" , g nlCU C ,,~l. rn ZIt Z :',i?J {ri ~ Z~- (1:1-' -=,fTl .......... iP -<2: w ~ :Ie} ........ - ~C' ! '" i j ~ j>c: "'"' .::-:-\(:) fJ r z -" i~5+1 '" -c:: )>c5 -,:,.0 ... -00 f; - Om .a:~ 1 ~ .. N c-l ;r;:- OO :J:J .< ~?""~'l \i"': ,,' EGO. .(1- j!il" --<,-, ~-~.- _.~,~~ >, ~,- .~. _, ~,,~0,~ "__ ~ >'. .. . -'-~=" " 0 ~~ a" I., '1~" J l .._- '~~M"h'--=ilii_"."i., . ' , MARK J. UDREN & ASSOCIATES BY: ~ark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 Civil Term Defendant(s) TO: Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary ..--X.-- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF yOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. udren. Esquire At this telephone number: 856-482-6900 --~"~""",,,"."-~ ""1I;~~ L . . , 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 Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) " ~.. ~llIIr.MI~""""'-~"~.w -'" ""'"1~;." ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE : NO. 01-1195 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff I 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 @11.49% From 2/21/01 to 6/04/01 @$28.93 Late charges per Complaint From 3/15/01 to 6/04/01 @$54.62 $101,957.23 3,008.72 163.86 TOTAL $105.1/.9 81 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. DAMAGES ARE HEREBY ASSESSED DATE:, Ju.J..,p: 1.2 .:J~I f MARK UDREN & ASSOCIATES Mark J. Udren, ESQUIRE Attorn y for Plaintiff ~ I~I~Tm ~ (? L/J-J~' ) k PRO PROTHY o"_""""'~~ "'"'., I ~'"" ~~I' ^ -~'""",,",~,~,- MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.o. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN & ASSOCIATES Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ~-""'"' LN~~ll1!tf~!i~JlJtllili1"':.;ltt;ii3ii,<M',ii-i.'ft,*~lM.M""";,sW:}"'~~__:JlililIl!jifMldJ~Iii.ii~Ri5iil.... ~ ~- N < ~,~~,_,_OO,~,"", ~,' _, > ,_" ~". " ~,_,T. ~," "....... -, ~ .lfu'H " ^~ . r~~ -'....., ("") C) 0 C -'1 <" C- um c -. mrl' d~ >or Z:Jj ,;,= Zc;:: :,,:,-l8 Cf) ,- w -<z :--) L r:;;C ~. .:~~:T: ~C ::z: ,~-. -,--,! L " ~('") -0 C:S!T1 )>c: Z !'-.:> ';! =< ::0 In -< " .;:,""""'...""" , ' .~- , ., . " ,~ .~ .'. "j: MARK J. UDREN &. ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMlV.lON PLEAS CIVIL DIVISION Cumberland County v. Joanne BroWIl 783 Longs Gap Road Carlisle, PA 17013 NO. 01-1195 Civil Term Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he ma!led a true and correct copy of the NOTICE OF SALE to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: JUNE 27, 2001 Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES Dated: ~ Mark J. Udren, Esquire "~-",,,,j,~.--~ ..;1 ., , .J :1 i ()....]y PI OJ 0 "W PI I-' ::1 1-'- t"'::1 {JJ 0 ro 1-'::1 ro lQ td - (JJ " o ~ '<:It;) ~~ f-' ....]:<1 00 f-'Sll W p: ~ ...~ ~ 0"; ITI ~!'- ;:II ZCI"" ?1~2s~~ :t--\ZITIO - G)z F:;:Ul",,~ ;zo:t)>o <:;:0 i5cn III .:> :t~(I) g ::Eo ..., ~:P. .... 0-\ m ~ o ~\ r:z: ~1J' ...\' \c... -:! "'" ~ ,,\\0;.i ~~.,,,,.\~~j Oi: '... ,: \)-......: ~~ ,...,.~( ~., ~;; -~~'~,~ \~l~~ ~ili\ll"'.~!~UC!. . .-~._-....... . '. .'1', , -'~~" '"' 'I or or ..D ..D Cl Cl 1"-, ?"- M M Cl Cl <0 <0 l"- I"- Certified Fee Postm"" <0 <0 l3etum ReCeipt Fee H... Cl Cl (Er1dorsemeOt Required) Cl Cl RestrI~ Derrvery Fee r Cl Cl ~orsement RequIred) , Cl Total Postage & Fees $ I ru ru m I or or Cl I"- ~,~"",L~'-'" ^ ~- '" ,. . . n ...J .~ ,. Q ~ ~ ~:~ g ::p " o\l n' g~:f~33 .- .., ,. .... ::r m '< ,../:0."0 r. ()J c. ffi:f;g~m: c. - Ci1"(1) ;,:ffil~. ,.. t ~ 0 a C'l C'l m"CIl CD ~ f} 0 ~ m ~ 3 '!:t 3 ,l! 0 c. ~a.... (1) ,g:oo (('f R .g'O"e.~:~w--" (> .1 ~:f30..o,!') rt (1) (1)....tl:I (1)m -- f!I c-::r 0..,::::::J -g tl:I CD Q-' Cii 0.. i?Ci) 3~~f8-<~ f;aa.~ Ci1.~ 0 . :f0":::I g.~ ,- -S 5 (1),< :f~.C'l 30(1) Cil 0 ...J ~.!=CilP..g 0 f? 0 -g: Cii ro 0 (J 3 . ~ - o "' . !!. -- E- -. . n' ()J :n 0 ~ 0 i" P " X :n " 0 :n DO ;;;;;iF (Jl 0 0 0 f!l. -<c. o' -g o. mo 0 0 -,n ~ ill m ~ ~ c c. 0 0 ~~ "- c.c. ". ~m 0 -< ~ ~ Q, 0 ~ Of{ . if C1 m c.o iil . CD x c. 0 0-" o - ;!1 . c 0' ~ if ~ . 0 :n 0-3 0 0 - ~" ~; 0 0 ~ 3 ;>. :::; ~ ~ ~ 0 ~ ;s: DODD ~ "' ~ 0 ~~6:~ ~ 0 ~ 0 ~ c.o ~ Cil ;a il c. 0 .. 0 ~ 0 0 0 J, r ' ~. ~. - ", ";"1 I 1 I Certified Mail Provides: . A mailing receipt .. A uniqueJdentifier for your mailpiece . A signature upon delivery . A record of delivery kept by the Postal Service for two years Important Reminders: . Certified Mail may ONLY be combined with First-Class Mail or Priority Mail. . Certified Mail is not available lor any class of international mail, . NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. . For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS fonn 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece QRetum Receipt Requested". To receive a fee waiver'for .a duplicate retum receipt, a USPS postmark on your Certified Mall recelpt.is reqUired. . For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mail piece with the endorsement "Restricted Delivery". . If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office fOr postmarking. If a postm~ on the Certified ~all receipt is not needed, detach and affix lab,el with postage and mail. IMPORTANT: Save Ihis racalpl and presanlll when making an inquiry. PS Form 38DU, July 1999 (Rav.~a) 192595-99-M-1938 "''''',-, , -~ ~ ..... iJ} STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. \ Robert P Ziegler I, _____________________________________________________~________________________Ilecorderol Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ________________ ___W~ng~-~l-~k-----------------------------------------______________ u the grantee the same having been sold to said grantee on the __________________2:~_________________________ day of September .2001 . , . ________________________________________ A. D., : _____, under and by vutue 01 a wnL_____________ Execution . 13th ____________________________ ____________________ ISSued on the _ _______ ___ _____ __ ______ __ __ __ ____ ___ clay of ___________~~!'.!:.__________ A. D., Civil __________________________ ____... _______ _____ ____ _ -________ _______ __________ ______ _ T enn, : 2001 . .. _____, out of the Court of Cornman Pleas of said County as of 2001 Number ___hh2.?_______, at the suit of __~:'_"_~~:'!\_t_'::'_~':~':~!___~~:.'~___________________________________ ______________________________ _ ____ against_ ___ _.. _ J-<tl!:g.!.l~_ JirQ!l1t___ ____ ___ ___.. ___ ______ ____ __ _ is duly recorded in Sheriff's Deed Book No. ____~4~_____, Page ____~]._n___. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office thu _.tcJ.______ day of -.(;lclltb.-!f::.______________ A. D., ~!__ ~~------R;;:d;;~De~ - ~-~. . . 'l,.. ",,*~lo-~ > Washington Mutual Bank, its successors And assigns VS Joanne Brown In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1195 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that 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 by regular mail, to one of the within named defendants, to wit: Joanne Brown, at her last known address of783 Longs Gap Road, Carlisle, PA 17013. This letter was mailed under the date of July 5, 2001. rpe unopened letter was returned to the Sheriff's Office on July 11, 200 I with the reason checked "Moved Left No Address To Forward." Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states th~t on July 03, 2001 at 7:40 o'clock PM, EDST, he posted a true copy ofthe above R~al Estate Writ, Notice, Poster Ill1d Description upon the property of Joanne Brown, located at 783 Longs Gap Road, Carlisle, P A 17013, according to law. R. Thomas Kline, Sheriff, who being duly swom according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: : The Sheriff mailed a pendency of the action to one of the within named "I defend~ts, to wit: Joanne Brown, by regular mail to her last known address of 783 Longs o!ap Road, Carlisle, PA 17013. This letter was mailed under the date of July 5, 2001 and returned to the Sheriff's Office on July 11,2001 with reason checked "Moved Left No Address To Forward." R. Thomas Kline, Sheriff, who being duly swom according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, pennsylvania, on September 5, 2001 at 10:00 o'clock A.M., E.D.S.T., and sold the same for the sum of $45,000.00 to Attorney Dale Shughart (for Attorney Mark Udren) for Washington Mutual Bank, its successors and assigns. It being highest bid and best price received for the same, Washington Mutual Bank, its successors and assigns of P.O. Box 57038, Irvine, CA 92619-7038, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $1,847.54. Sheriff's Costs: Docketing $ Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail 30.00 900.00 15.00 15.00 30.00 10.00 .50 1.00 3.25 2.40 ,,"''=' ",.... . . Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed Sworn and subscribed to before me ~-- ~ 15.00 20.00 293.30 234.93 25.66 25.00 ~ $1,647.54 paid by attorney 10-05-01 ~-.~"'#\'~"'~'JI.\"'''''''.", So AnJ)};r~ ~ ~~;~te:-t:?~ '~ This...JJ.u:... day of ~ 2001,A.D.~ a.. ~/~ Pro onotary R. Thomas Kline, Sheriff BY QrlA~~ Rem Est te Deputy ~~ 3o./JI:l ).t)O u.... yO (. I ~ lib' 31f "I c ;..,," "~ . ~--" 1iIi:~' 4~"""'..;"";W"''-'''",,,M.' , . - SCHEDULE OF DISTRIBUTION SALE NO. 39 Writ No. 2001-1195 Civil Term Washington Mutual Bank, its successors and assigns VS Joanne Brown Filed October 5, 2001 Date of Sale: Buyer: Bid Price: September 05, 2001 Washington Mutual Bank, its successors and assigns $45,000.00 Real Debt Interest Attorney writ costs $105,129.81 2,690.49 139.20 Total $107,959.50 Distribution Amount Collected Legal Search Sheriff s Costs $1,847.54 200.00 1,647.54 So Answers: ?,~~,I~~ R. Thomas Kline, Sheriff -~ < "~~ "":,:-, ." TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WilL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 39 Held Wednesday, September S, 2001 Date: September 4, 2001 TAXES: Receipts for all taxes for the year 1998 to 2000 inclusive. Taxes for the current year 200 1. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 200 I, and recorded ,2001, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Richard Brown and Joanne Brown, by deed dated June 13, 1988 and recorded June 24, 1988 in the office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "N," Volume 33, Page 489 granted and conveyed to Joanne Brown. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of 33 feet wide L.R. 21072, known as Long's Gap Road. 6. Conditions, easements and restrictions shown on or set forth on the Plan of Lots in North Middleton Township, Cumberland County, Pennsylvania, laid out for Amos D. Keck recorded in Cumberland County Plan Book 4, Page 52. 7. Rights in the roadbed of an un-named public street shown in Plan Book 4, Page 52 as a "proposed drive." ~~~ . -'- ...........,.Wl;Ui.m.~~~. " 8. Mortgage in the amount of $92,000.00 given by Joanne Brown to Option One Mortgage Corporation dated May 17,2000 recorded May 23, 2000 in Mortgage Book 1613, Page 859. Assigned to Washington Mutual Bank by instrument dated March 12, 2001 recorded March 22,2001 in Miscellaneous Record Book 670, Page 18. Complaint in Mortgage Foreclosure filed by Washington Mutual Bank as Plaintiff against Joanne Brown as Defendant in the Office of the Prothonatary of Cumberland County to file number 2001-1195. Default judgment entered June 13, 2001 in the amount of $105,129.81. 9. Municipal lien entered by Carlisle Suburban Authority as Plaintiff against Joanne Brown as Defendant in the Office of the Prothonatary of Cumberland County to file number 2001-2823 in the amount of $261.42. 10. Rights granted to Keystone Pipeline Company by instrument recorded in Miscellaneous Record Book 67, Page 24. II. Rights granted to Socony- Vacuum Oil Company by instrument recorded in Miscellaneous Record Book 83, Page 415. 12. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 13. Real estate taxes accruing on and after January 1,2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regardiug House Bill 1412, Act 58 of 1997, uor has any search been made for environmental liens in Federal District Court. 3:-1. Robert G. Frey, Agent Note: This Title Report shall not be valid 0 until countersigned by an authorized signata . " " REAL ESTATE SALE NO. 39 Writ No. 2001-1195 Civil Washington Mutual Bank. its successors and assigns vs. Joanne Brown Atty.: Mark J. Udren ALL THAT CERTAIN lot or piece of land situate in North Middleton Township. Cumberland County, Pennsylvania. bounded and de- scribed in accordance with a survey and plan thereof made by Thomas A. Neff.. Registe.red Surveyor, dated December 20. '1973, as "follows: BEGINNING at a point in the cen- ter line of Long's Gap Road. Penn- sylvania. Legislative Route No. 21072. said point being 120 feet South of the southern line of Hillcrest Av- enue; thence extending along land of Wayne Caleman. being Lot No. 12 on the hereinafter mentioned Plan of Lots North 72 degrees 30 minutes East 160 feet to a point in line of land of Robert Carpenter; .. thence along said land South 17 degrees 30 minutes East 60 feet to a comer of land of James Eberly: thence along sald land being Lot No. 14 on said Plan. South 72 degrees 30 minutes West 160 feet to a point in the center line of Long's Gap Road aforesaid; thence along said center line North 17 degrees 30 minutes West 60 feet to the point and place of BEGINNING. BEING Lot No. 13 on a Plan of Lots laid out by Amos D. Keck which said Plan is recorded in Plan Book 4. page 52. Cumberland County records. HAVING thereon erected a one story frame dwelling. BEING KNOWN AS 783 Longs Gap Road. Carlisle. PA- TAX ID NO. 29-15-1247-009. TITLE TO SAID PREMISES IS VESTED IN Joanne Brown by deed from Richard Brown and Joanne Brown dated 6/13/1988 and re- corded 8/24/1988 in Deed Book N-33 page 489. ." ~-""""Ji!iS@;:;;;:ll"", " "~ . > . , ('" WRIT Of,EXECUnON 811d/or ATTACHMENT ",':,J( : ';,;', COMMONWEALTH QF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01 1195 CIVIL 1~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Washinton Mutual Bank, its successors and assigns from Joanne Brown, 783 Longs Gap Road, Carlisle, PA'17013 PLAINTIFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to allach the property of the detendant(s} not levied upon in the possession 01 ;,rt1 :-\, Y.r,~J .-, _..~ _ ,',;',:::1 GARNISHEE(S) as follows: . ii, "",,."',",J,,,, " , '::IH;~fJ!:'1_: ' rlllr'J\Wh' _'(I';~~. and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) t~e ~arnjshee(s) is!areenjqined from paying any debt to or lor the accoUflt 09~tr, defe.ndant~>lIh",pd ,Irom delivering an~~ropertyol ~~. def~mdant(s)Or'otherwise disposing thereof; ". . . ." .,"~)!< If property 01 the delendant(s)~.I#l~iedH,P,O!"I ~flIiUbject,to.attactfmerilq~fb6'tid i~'il ~!\fe~h 01 anyone of her fhan a if.;Irio'ied garnishee, you are directedtollotily himifierthat he/she has been added as a garnishee and is enjoined as above stated. q~...': Amount Due 6ln'51 ?9Rl ,,, . fran 6/5/ 1 to 9/5/01 Interest Per diem @2g. 9J .~.$2"i6!:iO "-9 Ally's Comm % L.L. Due Prothy Other Costs $.50 $1.00 Ally Paid Plaintffl Paid $139.20 Date: ,lllnf> 13. 2001 Curtis R. Long Prothonotary, Civil Division ~ 4n-.. 2. 7?a~..f Deputy REQUESTING PARTY: Name Mark J. Address: 1010 N. Udren, Esq. Kings Highway, suite 500 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 ',' ".' '., = '1i:iJlilij:I*-il~~"""'''''''' "iilSll~'"'- ~=Iir.~'lllll - -. .~,""""-r'''''''''~''-~!l}~,iilililij'~'''''_'-I,,,~,,"~Ii<'"lI',~'''''''''"' ~~~JmI!!1Hjf!'l.::m(ijl[U-~~r~ _ _ .~. ~~~,.'~'JM:tlllfil . ." .. REAL ESTATE SALE No. 3j , I1I'l >>UhLl/5, "J.ool the sheriff levied upon the oetenoan" interest in the real prooerty ilituated in fJlfLtIt. IY/.I~ ~ SumbedMdCOunty, Pa., known and IltJmberedas: '7'i31Dt.j4 (::c.p eoA-d t~ and more tully described on Exhibtt "A" flied with ..... wdt and by this reference incorporated herItn. -: 0"", ~'lDoJ Br: ;f~et<Mc (} 0 ~~ ifINVf,lASIHI3d ::' -, c: ~ -! ' ~ 'i' 8 10. uv at 9 rl Hnr MNI!Q; ,e'j, , i",ji'!{j\i 1I11111~H~ 'iiHJ AD Ji)li/ilO ~" - . do' ",' ~ . MARK J. UDREN & ASSOCIATES BY: Mark g. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.O. Box 57038 . Irvine,CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, its successors and assigns, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets. forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 783 Longs Gap Road Carlisle, PA 17013 l. Name and address of Owner(s) or reputed Owner(s) : Name Address Joanne Brown 783 Longs Gap Road, Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same as # 1 above " 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein.. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Atldress .l~~ it;t-;fi!.!llBLiy I f ,I 6. Name and address of every other person who has any record interest the proper~y and whose interest ~ay be affected by the sale: Name. . 1\.ddress . " ~-~ .'0 ~ 1;;,""0 .. in Real Estate Tax Dept. 13 IN. I 13 iN. Hanover Street, Carlisle, PA 17013 Hanover Street, Carlisle, PA 17013 Domestic Relations Section Commonwealth ofPA, Department of Revenue Bu~eau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name otjher person of whom the plaintiff has i~ the property which may be affected by Aiddress Tenants/Occupants 783 Longs Gap Road, Carlisle, PA 17013 . I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements ~erein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating tp unsworn falsification to authorities. DATED: June 4, 2001 MARK J. UDREN & ASSOCIATES MARK 1!)EN' RSQ Attorney for Plaintiff , . ." . . -~ . J~,' . MARK J. UDREN & ASSOCIATES BY; Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Your house (real estate) at 783 Longs Gap Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,129.81, 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 PRF.VENT THTS SHERIFF'S SA"LE To prevent this Sheriff's Sale, you must take imm~diate ac~ion: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: 1856) 482-6900 mortgagee the back payment, late To finq. out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert,your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how , - - "," .-,,,," < i'it< . YOU MAY S~ILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE' SHERIFF' S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. Tbe sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale., YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 -"""",= ,--, ~ ~ , ,- ~ . " -"'."~lIlI~~~;~ . ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY AND PLAN THEREOF MADE BY THOMAS A. NEFF, REGISTERED SURVEYOR, DATED DECEMBER 20, 1973, AS FOLLOWS: BEGINNING AT A POINT IN THE CENTER LINE OF LONG'S GAP ROAD, PENNSYLVANIA, LEGISLATIVE ROUTE NO. 21072, SAID POINT BEING 120 FEET SOUTH OF THE SOUTHERN LINE OF HILLCREST AVENUE; THENCE EXTENDING ALONG LAND OF WAYNE CALEMAN, BEING LOT NO. 12 ON THE HEREINAFTER MENTIONED PLAN OF LOTS NORTH 72 DEGREES 30 MINUTES EAST 160 FEET TO A POINT IN LINE OF LAND OF ROBERT CARPENTER; THENCE ALONG SAID LAND SOUTH 17 DEGREES 3.0 MINUTES EAST 60 FEET TO A CORNER OF LAND OF JAMES EBERLY; THENCE ALONG SAID LAND BEING LOT NO. 14 ON SAID PLAN, SOUTH 72 DEGREES 30 MINUTES WEST 160 FEET TO A POINT IN THE CENTER LINE OF LONG'S GAP ROAD AFORESAID; THENCE ALONG SAID CENTER LINE NORTH 17 DEGREES 30 MINUTES WEST 60 FEET TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 13 ON A PLAN OF LOTS LAID OUT BY AMOS D. KECK WHICH SAID PLAN IS RECORDED IN PLAN BOOK 4, PAGE 52, CUMBERLAND COUNTY RECORDS. HAVING THEREON ERECTED A ONE STORY FRAME DWELLING. BEING KNOWN AS 783 LONGS GAP ROAD, CARLISLE, PA TAX ID NO. 29-15-1247-009 TITLE TO SAID PREMISES IS VESTED IN JOANNE BROWN BY DEED FROM RICHARD BROWN AND JOANNE BROWN DATED 6/13/1988 AND RECORDED 8/24/1988 IN DEED BOOK N-33 PAGE 489. <-< " ;, I , "' ;, "'j1:', '. , . ., . THE P A TRI'()T NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly SWOrn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of I.h!l Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 24th and 31 st day(s) of July and the 7th day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in :::I~::::"'~ " 0.00' " '"' '''~'':"=''~"~'"l[='~'.~'mmm COpy . t s 21st d~f A t 2001 A.D. S A L E #39 Notarial Sea' Tony L. Russall, Notary Pub . /" Harrls.urg; Dauphln County ( ~ My Commission Expires Juna 6, 2002 NOTARY PU sLle Memtler, Pennsylvenla Association 01 Nelarl~y commission expires June 6, 2002 CUMBERLAND COUNlY SHERIFFS OFFICE CUMBERlAND COUNlY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 233.43 1.50 234.93 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... REAL :ESTATE SALE NO. 39 Writ No. 2001-Il95 Ctvil Washington Mutual Bank, Its successors and assigns VS. Joanne Brown Atly.: Mark J. Udren ALL THAT CERTAIN lot or piece of land situate in North Middleton Township. Cumberland County. Pennsylvania, bounded and de- scribed in accordance with 5a. survey and pIan thereof made by Thomas A Neff. Registered Surveyor. dated December 20. 1973. as follows: BEGINl\1lNG at a point in the cen- ter line of Long's Gap Road. Penn- sylvania. Leglslative Route No. 21072, said point being 120 feet South of the southern line of Hillcrest Av- enue; thence extending along land i of Wayne Caleman. being Lot No. 12 on the hereinafter mentioned Plan of Lots North 72 degrees 30 ' minutes East 160 feet to a point in line of land of Robert Carpenter; I thence - along-said land South 17 . degrees 30 minutes East 60 feet to I a corner of land of James Eberly; I thence along said land being Lot No. 14 on said Plan. South 72 degrees 30 minutes West 160 feet to a point in the center line of Long's Gap Road I aforesaid; thence along said center ' line North 17 degrees 30 minutes West 60 feet to the point and place : of BEGINNING. , BEING Lot No. 13 on a Plan of Lots laid out by Amos D. Keck which said Plan is recorded in Plan Book 4. page 52. Cumberland County records. HAVING thereon erected a one story frame dwelling. BEING KNOWN AS 783 Longs Gap Road, Carlisle. PA TAX ID NO. 29-15-1247-009. TITLE TO SAID PREMISES IS VESTED IN Joanne Brown by deed from Richard Brown and Joanne Brown dated 6/13/1988 and rc': corded 8/24/1988 in Deed Book N-33 page 489. ~ . "" :'IlEAL ESTATE SALE No. 39 , ,Writ Noc200:l-1195 _,.o,,=ClvllTerm _ . .~ashimrt9.n ,Mutul}UJ.~J!l<. E . s successors and assigns .~_~;.~ :~.--':';1l~":'~'.----:-;-'.~ -- -~JOanne -Brown _,Ally: Mark.l. Ud~n DESCRIPTION : ALLiH;tCERTAj;hot;~r'pjcce Oibrnl ~(j:,\';l:~~ m~_ti(jnh_Ml~te_ton. .Township, .;'Cffin6ttrano - Cou,nty. Pennsylvania. , bounaoo and described in accordance with a ~Q.~y difdplan l~rOOf made by ThOn1a<;. A. ~cff,,,!}:.gjg.~~A .~D'.~:9r.. ,QJlte_d JNc~mbcr ;;z(f.l1173.a!>.rQHQw~:_ ___ ~ BEGINNING .:it a point in the center line Qf ;-t.:ong'sOap Road. Pennsylvania, 4gis.I,:uivc.-B-.o.~tc. __ . __ _. _. ~No~-t]dn-~id point being ,1:20 f~t south :l<<1T~thC.:.soutbctit liW: ,Qf Hillcrest Avenue; ~11~ .:~e~~l!!R_~LQng~aJ}~9L W3Y~ . ~leman. bemg l:ot No. J 2 on the- "'neremafier mentIoned Plan of Lol<;. oorth n ~degj-ees--jO.'riiriLltes east 160 feet to a point inJine of land.OLI\.Qben Camenter; lh~nce =-a 0 --, T~~~!61~~~fE~~ =- , . _~~l}sg_alQ.ng~~i4J~n_d_~ing-lAl -.N.Q._14_.on_said plan. south n degrees 30 :JIDDUWS .w~L lflQJe.CLLO_. a_ point in the ~nrcr:ljne.of wngJ; G3p_Iill!d_afo~d;___ UhC1tcC..:.:arong said -center line north 17 ~~ 3() miIlu~t~~ w.e;.<:,t.60 feet tc ~ Nlnt . ;mc!.PIl!.C~_I~[ltEQINNJ~9, _ __ .__._ __ _, - ;:::gElNG Lot No. 13 on a Plan of L.otfj laId ~~p~~AmoS_D-:'~ecK\vhich: said Plan is ~~@ -_JILJ~L<jJ"l.~-'~9Yk .f..- ,.P;1gc _ 52, +Cwnbenan_d. COUIlty Reooros.. ;"HAVl,N{i ,Jhcseqn 'lr~Jed. a one. 'stot}' :l.r;lJtWJly..~clling. _ __-n _ - , BElNG~K~.own as 783 Lon,gs Gap Road, }!r~~~~~-2~\S:T247-009~~"~-'-'-~ ~ ~TQ._~~J:!rc~i.,-<;:,;_ is vested in ~rOWnoy"aeea trOmRichard BrQ\\'n ~=SQanoii-BtW,on di~d 611J119&8 3nd ~i'Yicq--W~~~'9~ ,in Deed B90k..N-33 .-:l'Jge- "8.L ,_" " _ ,~ .,' .1 '" Jf ~, ~ [l .-' ~~. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), p, L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law . Journal on the following dates, v!z: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r-~ t/YU1- -.. Roger . Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 ~J~)~ kr/'PA- Notary , NOtARIAl: SEAt. LOIS E. SNYDE~ PublIc ClirIIIIiIBolQ. CoImtY .. MyOOlilll~BBIDn ExpIres Man:h 5,2005 I I . .~ " "~ '"' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.O. BoX 57038 Irvine, CA 92619-70~8 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION , . Cumberland County : MORTGAGE FORECLOSURE v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 Civil Term Defendant(s) PRAECIPE FOR WRIT OF E~ECUTION TO THE SHERIFF: Issue writ of Execution in the above matter: Amount due $105.129 81 Interest From June 5.. 2001 to Date of Sale September 5. 2001 Per diem @$28.93 2.690 49 (Costs to be added) $ MARK J. UDREN & ASSOCIATES en, ESQUIRE ,R PLAINTIFF ~~'ljIj~~d~~",,~~~~;,,'''C,''Y..:k';;~~':lr#~'''1.i\~il<t';;,;;;;_i@!Wll[~~/Io~m~'ilil~!filUM (:) ~ W ~ ~ t :'4 ~ ...0 f"".llJ ...0 W -. '*- . . . ... ~ "-> :..~ 0 . d 8 ~ - 0 0 0 0 CO D 0 C) c 0 <- --n <- I ucr' , ...... I I I , nln: 2 ..... \' e 2::r; ...s:- .' ,.... r~ r- 7.) ..... 21;: -,'"'[1 '"" ..c: r , (/J-:::.::: L..::- -.-:'J ~E-.'. (~~(~) ~ ~ ... - :::" ... , ~o - , , "'"' ~c . " u. ~;2~ ~t )>0 - C C:.:;rn , - ~ -< , - .. .... "" :t> - - .... .'1{.J:- U) :J:J -< ,,=. - " ...ma In" -..,j -"'-~ L__ <- '=~:~ .' .~ 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 Washington Mutual Bank, its successorS and assigns P.O. Box 57038 Irvine,CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, its successors and assigns, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets. forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 783 Longs Gap Road Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Joanne Brown 783 Longs Gap Road, Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same as # 1 above ' 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff nerein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address h_"'''-~"'''~ -I~ ~J ^ - ~~~, ~~.. ~~~ , ~. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: Name Address Real Estate Tax Dept. 13 N. Hanover Street, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street, Carlisle, PA 17013 Commonwealth ofPA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any ~nterest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 783 Longs Gap Road, Carlisle, PA 17013 . I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: June 4, 2001 MARK J.UD EN, ESQ. Attorney or Plaintiff ~~~~lauWll~~~i!i!!~M.i]~ffij';>d\1i'i> ~"K ~;'Go,::"~\F,,-,;M,j~y;il;:;lriiMBiM~_ilW!di!~Jl! , ~ M.: M1Jlllllilillllll"~~"-" -" 0 0 ~;~ C g '- -1 "Up ;; -", .,~ 92rn ::L' ";=: Zr-- 1~~; (f. ~~ (..,,) -~~~ ~". 4. ~c::; ~~ ~O ._~:~,~ - -.-,~ .J 5>~ ~rn u -~ Z N J> =< lO ~ . - -', 11 " I' n i:1 I " _~,u- ~ i.c ". 'J , """'k' . MARK J. UDREN & ASSOCIATES BY: Mark J. Vdren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.o. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 : NO. 01-1195 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Your house (real estate) at 783 Longs Gap Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,129.81, 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 AEr,E TO PRF.VENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate a~tinn: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900. mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how j-~~'''- ~ ~, . -~ " . ,,~ !:f,,' . ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. <!l. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. YOU have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~~~_I~~~il\libiliil@~\Ir"\~,:",:?,.&;,,,",,,j,,,,,,":k~"0t;:$i$llt;;;;;&~~~iIM1~~.!IiiJl ~~ >. - ... ~'. Iii'l'mI'!. -~ , I ~ ,~, b!:c'i .~ .. 0 C) 0 C -n ~ '- uOJ c:: ~-Q nlm ::;-~ Z"JJ ..r.,\-n ZC ;;~(? (f) ,,:<_ W ~.. -~;~ __C) ~ :c>- 0..::;-;-"""'" )-- ZC) <;:-~() --.0 Orn )>c: --1 Z N t:~ =< ::0 to -< ~ "" ~~ ,""'."-- . :.l >'" bihJ ~ J. UDREN & ASSOCIATES BY:. Mark J. Udren '~TTV I.D. NO. 04302 ~040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff o o COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) : NO. 01-1195 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/hiS/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the.date appearing on the attached Return Receipt, which was signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule CoP. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 2, 2001 .~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff -,. "I , -, k. ,w ~d">_ ..~,__,_> - ,~ - "i', . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. ~4302 1940 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, its successors and assigns P.o. Bo:x: 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 :NO. 01-1195 Civil Term Defendant(s} AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, its successors and assigns, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 783 Longs Gap Road Carlisle, PA 17013 1. Name and address of Owner (s) or reputed Owner(s) : Name Address Joanne Brown 783 Longs Gap Road, Carlisle, PA 17013 2. Name and address of Defendant(s} in the judgment: Name Address Same as # 1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address CARLISLE SUBURBAN AUTHORITY 240 CLEARWATER DRIVE, CARLISLE, PA 17013 ~iII!iIIlIb.i;l, . .....- , ~ 0 ,. ,- c'._ - .{.. _ J~~ 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address '. Real Estate Tax Dept. 1 COURTHOUSE SQUARE, 13 N. Hanover Street, Carlisle, PA 17013 Pomestic Relations Section 1 COURTHOUSE SQUARE, 13 N. Hanover Street, Carlisle, PA 17013 Commonwealth of PA, Pepartment of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every Knowledge who has any interest t:he sale: Name other person of whom the plaint:iff has in the property which may be affected by Address Tenants/Occupants 783 Longs Gap Road, Carlisle, PA 17013 1 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: AUGUST 2, 2001 ;1 MARK J.UDREN, ESQ. Attorney for Plaintiff ,,-, ..~- - . ~ o~ " - ~~ <" '.-, ~~ ""~'Il" " 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 Washington Mutual Bank, its successors and assigns P.o. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1195 civil Term v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) DATE: June 12, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER (S): JOANNE BROWN PROPERTY: 783 Longs Gap Road, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 5. 2001, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHiBiT A ,:.~ , "tl . (f) ~o' ~ ~ " (ifiir '" ... ~ 0. o"~ ,<C '" )- en3 CD ~![ '" 0.0 .'" m_ ~." " ar CD 0 CT m ~ 0 -< ~o' ~ O- m m CO ~.~ ~ 0.3 ;. !!to" .,,~ 00 ~- O:P. 3d~ " m m 0 " o ., 3 is: l: In - T /' ." o o 3" m o il" .~ ? ~ m 3 m c - il' ~ s' ~. <c W ." 5" 'ai .!!. CT CD o o 3 ." 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"'-4~ Igl W I ~i ~ ~II I I ! 1 -v' 1 \ t.":.';~,~:,:.~..,i:D':'f ,~;~~~:r';OSl~~tJ'~. ~J. \ ;,,,, \,tk.J~; 1,,,"'1'-075 ' .fj<, ::-~ ;\;-;. " ," . , ::: . -, ,"'.II'i)' ./ tv J .",M..... 1 ~! 67l)1l2~'L- .' -t- I '~ tv~'. ~Vlit'Al~+v~"y.;) c~ ni!'~~rf;at~'j}il$ ;t;;" """" .I i'lLilmd 11"9 iR' ('\t!' ""t'il ti !J; ~Ii", l~lf ~~it'LH'~ ~ee;rd"Jit i I I I 1 I I I i i 1:1. ~> ~f [ r6UH ~~ f r~,~ ~ ~CZ~ ~ C:e. ~ ~f.1> ~ P f l~ . s l 1 . i"')-A ~I 5 . ~B a 0,," ffi t~ :Ilzd;r- ~oo".~ :L~zrno --lG)2l. l=moo",,-n - 0'1 l"(fj"'T1 zo;!;~O <-oG)~m o :LoCI) '" ::Eo o )>_ '" '"()> ~"".m - , I . > il'1 " z ~ I cr ~ o ". . 5mooo ~ ~~ ~o~ ~ @@ii5O=-o a.ffl-<! l! (b !i:g> a ~::I 3 3 ~ ~ ,r , DDDDO ~ DODD 00 . < 1r ~ l'Jl:Il:D,lJ ~. !!~. g ~3ita "'::C"' en ~~~~ o m_ CD ::::I "C __ :::.- < 3 0' _!!l .' ~ gff , 1l , . , 0. .. " , .. 3 ~ 6' , 2, ~-o 8~g~~ _~ 12.C3'~Cii--- " . ~3 C>....::!iCll X en 0 lI>~g15cn ClI .....tu a&iiCl.S' :o~ S~c1ll3 ~ III iii- g .... Ul-o !!!-a ga~ Ill:::c oiif- ,:::; ~ ~ i~ 'P (\) <g~' -> '"" . 0 c. ~< 9l~ 00 0.. <or . . _0 0' .~ o o ::;:(11 '>en 00 0.. ~ "0 ~o ;:'''' 00 EXHIBIT A ie'''' 1m:!: 'I''''" ~o I"," Ig::o "'" ~ . , -. -}. ~-<' -- , - 'j'-,' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and assigns P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAIN'I'IFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 NO. 01-1195 Civil Term Defendant(s) VERIFI~ATTON OF SERVICE BY CERTIFIED MAIL AND RF:GUI.AR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaint~ff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the NOTICE OF SALE to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: JUNE 27, 2001 Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES Dated: ~ Mark J. Udren, Esquire EXHIBITB ., I>j 0 () -..I c., PI co 0 11 w PI i-' l:l 1-"1:"' l:l m 0 CD i-'l:l CDLCl tJj ',,', m 11 0 'l:Jc;J ~ );Ill! 'd i-' -..1::<:1 00 i-'ll! w 0.' ,1>.1 1::<:1 1 :O~ .r ':\ . '" ,~~ . '-"'._~.'."," . ~ ...~ () 0'" ffi 2:;,.. :D zcr- :D(JJ:"'Cl~ -<C~:D", :t-zmO ;=r;lGlZ-n r",CIlI"':!! ZO:t~O ,,-0 15C1l rI! c :t~(IJ ... =Eo o ~_ "" ~'" .:- .....'-1 m (J) c, ~ ~r\ 12: ~: ~\ \c.- :;; "u l "\ \X;,~I ~i"'''\'\fr' 0'1: .... ,I \ ~'~ . ,,,',,,( II ~~ _ .A-~'~~~ \. ~ '~\I I II ,.. ~~..!~~ . ..w._~ '<1 .-. > ~ ~-'-'j'i:H ,',_C,' lr lr .n' .n CJ CJ r'-. r'- .-'I .-'I Postage. $ CJ CJ '" '" r'- r'- Certified Fee '" '" F.\stum f!ecelpt Fee CJ CJ (El,dorsement Required) CJ CJ RestrIpted Delivery Fee CJ CJ . (Endorsement Requlrad) CJ CJ TutaI Postage & Fees $ ru ru ru ru m m lr lr lr lr CJ CJ r'- r'- .... n._., e',-,"'.,'_ Postmark He<> l , I I I .J ",' .. -' .",. -. :.' . '::" ..... "::,:"<:, ," ,"'-'..: &)("'''~l'''' .~ 0 c' . . D ...J 6-\ ,. Q ~~;P.~~ '" ::p ~ n' g~s:?.33 " ., ,. _::r llJ,< ~"'O' t. ()J 'f' il: is=~g:;;i 1- . _ iji':CIl .., JJ CD ~ . a. 0:,0:J !Jl ;::;' ~ r; . :::Iw~ww_m ~ '" ::a':::I~~.~ 0. R - ,-. - <<7 {g'a:m-~ !..... S J ~:r3a.c:Jl'J rP CD CD _ w !!. w cr:::r C. -'::J v(f\ ~ m' CD Q- ~ a. 3~~!Jl-<[;J :P 0 OJ iifs.a~ C;;'~ . :ro::J.g.~ -lJ 5 CD "< :T~. 0 -- 30 CD Ci3 0 ....J ~. ~ CD fl..a 0 E? 3 -g: di (i" 0 CJ 3 ~ (J (if '" .'" '" !<l ,... E- o' ()J " '" ;r 0 !'- "' 0 >< !'l " '" " 00 "" ;;; Ul 0 '" '" . iTl~ <c. 'S 3: 0 0 JIl ~ a l!" ~ ~ < 0. . 0 . ~~ " 0.0. ~. '" . -< ~ &': ~ ~ Q, 0 w OH "" ii " m ~@ . . x 0.0 0- u . - ~ . < " . if ]:) :3 CD . ~ " 0" 3 ~ '" ~ -- 5" . .... !!.~ ~ 3 " - Iii Q ~ ~ 0 0000 ~ s: ~ ~ '" a:g~A' ~ a ~ ~ . " c.. . p " 0 0. ~ .. ~ . - . . . , -, 'Ll:t ~ ~ ~1Jf',( .,', j ) Certified Mail Provides: . A mailing receipt . A uniqueJdentifier for your m~rpjece . A signature upon delivery . A record of delivery kept by the Postal Service for two years Important Reminders: . 'ill Certified Mail may ONLY be combined. with First-Class Mall or Priority Mall. . Certified Mall is not availableJor any class of international mall. . NO INSURANCE COVERAGE IS PROVIDED with Certified Mall. Far valuables. please consider Insured or Registered Mail. . For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 3811~ to tne article and add applicable postage to cover the fee. Endorse mailpiece 'Return Receipt Requested". To receive a fee waiver.for a dupUcate return receipt, a USPS postmark on your Certified Mail receipt .is required. . For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the rnailpiece with the endorsement "Restricted _Delivery". . If a postmark on the Certified Mail receipt is deSired, please p~sent the arti- cle at the post office for postmarking. If a postmark on the Certified ~ail receipt Is not needed, detach and affix lab.al with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. PS Form 3800. July 1999 (RBVll~lI) 1025!15-Q9-M.1938 . . .. - . . -.' .~. EXHISIT--E3-. """,-""""",.,;..:Jt-- I~ I . :..... - . , ~ -, ~- -.1',,11.1,': "".-;, J.\PR 0 52001t!l , . . ~ MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQulRE '" ATTY LD. NO. 04302 1040 N. KINGS IDGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors and ass igns P.O. Box 57038 Irvine, CA 92619-7038 . Plaintiff . A TIORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : NO. 01-1195 Civil Term v. . Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant( s) ORDER AND NOW, this J I ~ day of F\ p"ll , 2001 ,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint In Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Joanne Brown, shall be complete when Plaintiff or itscounseJ or agent has mailed true and correct copies of the Complaint In Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s) , Joanne Brown at 783 Longs Gap Road, Carlisle, PA 17013 and by posting the mortgaged premises at 783 Longs Gap Road, Carlisle, PA 17013. BY THE COURT: /5} a/IflJJ {' oiJll J. EY"',QIT ~ ,~~~_H . MARK J~REN & ASSOCIATES BY:~rk J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, its successors .and assigns P.o. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 Defendant(s) - ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland county NO. 01-1195 Civil (") C $: uG~: mn-:. Z::t' zr" UJ):- -<2: C:::C..:. j> ~'. -7( -' TennC Pc Z =<! VERIFICATION OF SF.RVICE BY CERTIFIED MAIL AND REmIT Jill MAIL PURSUANT TO COURT ORDER CJ S= ,= l tD (") ""1 ,-< :32 .... 'r'" -.----:1" ~~~~ -~ :::-.,~c=s ?Srr: ~ ;';> Xi -< N i""..) , ...... The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the NOTICE OF SALE to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: JUNE 27, 2001 Joanne Brown 783 Longs Gap Road Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: MARK J. UDREN & ASSOCIATES ~ MarkJ. Udren, Esquire EXHIBIT ~ ~1!MlI~-"~iaiilJl!~W!jJlt.VjU~~-Bl;;"~""');''''~'''Jk,,;',,~~,",,"ui,jj;ijl&...ilii!l~!@lI~'~ '"'''''''~'illlil!iiilliliilMllliil'i!lilillifi!!ll~_~-'~~''ilIHi!ol < , "-",,,- 'i" -,'. <".',,,,, <-~.~. ,_., ~~~ __ ~.. 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