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Home My WebLink About01-1251 FX ""' - -~ "" II ~ .,~I ,) l,1 ',,".,"'~~' . J ,"",,:' '''I7"f'' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v, Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) : NO. 6/ - 1.2~/ C-oIL y~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAItE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~Q .' .iBk.l1 klJ"'~~1 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades U otros derechos importantes para usted, LLEVE ESTA DEMANDA A 1JN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL, Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 - l':dI.~f~, i,~~ OO~J'. : - - - j- ~' '"l!!ii~ ~ ,; I il - ~ -~ iLtJililii1ii:li::I1iii '1ifi~~*--,*-"''''':W'!r,,,';'-';,''li.I> ! NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you, Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose, LAW OFFICES OF MARK J, UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 ." . ..........' ., 1. plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: Recording Date: Book: N/A 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: 3966 Enola Road MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Frankford Township COUNTY: Cumberland DATE EXECUTED: 10/26/98 DATE RECORDED: 10/29/98 BOOK: 1492 PAGE: 1109 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 February 21, 2001: Principal of debt due and unpaid Interest at 9.750%* from 12/1/98 to 2/21/01 (the per diem interest accruing on this debt is $53.37 and that sum should be added each day after 2/21/01) $199,806.74 43,443.18 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280,00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $178.86 and that sum should be added on the first of each month after 2/21/01) 6,436.16 Late Charges (monthly late charge of $85,87 should be added on the fifteenth of each month after 2/21/01) 2,060.88 Attorneys Fees (anticipated and actual to 5% of principal) 9.990 34 TOTAL $262,267.30 *Interest rate and per diem are subject to adjustment as more fully set forth in the Note and Mortgage 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected " ."'^''''''''''''5!~l'&r;'<:: in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000,00. The notice specified by the pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has not been sent because the loan is over 24 months delinquent and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $262,267.30 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mar~ "dren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 . _.'~" ~ P1l2/19 ....._...4..,~...~"t:talO J 'ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANXFORD TOWNSHIP, CllHBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: , . ~- BEGINNING AT AN IRON PIN.AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881. 57 FEET FROH PA. ROUTE 944).; THENCE ALONG LAND. NOW OF FORKERLY OF RAY A, ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864,29 FEET TO AN IRON PIN; THENCE STILL ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 HINUTES 00 SECONDS WEST 1,993,20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423;THENCE ALONG The EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 HINUTES' 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR J'ORMERLY OF HARVIN L. RUTH, SOUTH 77 DEGREES. 07 HINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF HARVIN< L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 HINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON .PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 HlNUTES 12 SECONDS EAST 99.32 FEET TO AN'IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EAST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH io DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IaON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES. 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECOIllDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORKERLY OF HAROLD T, SHOFFNER AND RAY A, ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRXVATE ROAD OR LAND EXTBIlDING FROH, SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A. WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A HEANS. OF ACCESS TO AND FROM TRACT OF LAND. . "" "'.'. .' ."4\,A V E R I FIe 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 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. I Mark~dren, ESOU'" MARK J, UDREN & ASSOCIATES iQ1i~f~~'-lliii,[t~~~lt/l~,Jlll%~Jiii"l-;;'d]Lf.M;''''"'';,'t>ij,,},,,,,,;!ti''>$.i''''''''4<.M-ii4~~~~~~~,miml~~~. ~Jl~~~'-~~ o'-~'!li 6a. (? ~ ~ "9- 9 ~ h ~ ~ c ....,-,' "~'J \ ~ , r-= -,-, ~ w 8 ~ .-"" ~ '-' ~. " ~ fT'I,-." ~ CY ?: ~'.-~ ~ ~ I I (,'--J ~ ; t.n ~ }f ~c Q ~ .~ ~~L; $ 9-- ;..~ c_ '-~-; '.--' -:-+/ '~;. C=i ',- _,''OJ ~ ()O -< ~ ,. . ~~ - " .~ .. 1 -,'C '''-dtlg~ " ... SHERIFF'S RETURN - REGULAR CASE NO: 2001-01251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS JANESKO MICHAEL J ET AL DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JANESKO MICHAEL J the DEFENDANT , at 0013:35 HOURS, on the 9th day of March , 2001 at 3966 ENOLA ROAD NEWVILLE, PA 17241 by handing to E, JADE JANESKO (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 6,20 .00 10,00 ,00 34.20 So Answers: r~~f:~~ R. Thomas Kline Sworn and Subscribed to before 03/12/2001 MARK :~:UD~Cg. ~ Deputy Sheriff w me this 2. '7 ~ day of .~~\ A,D. q,'(t.Q llf\,el,.) ~. Prothonotary - ,- . '-';1 ., '~II- SHERIFF'S RETURN - REGULAR CASE NO: 2001-01251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS JANESKO MICHAEL J ET AL DAWN KELL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JANESKO E JADE the DEFENDANT , at 0013 :35 HOURS" on the 9th day of March , 2001 at 3966 ENOLA ROAD NEWVILLE, PA 17241 by handing to E. JADE JANESKO a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 6,00 .00 .00 10,00 ,00 16.00 S~~~~~~ R, Thomas Kline Sworn and Subscribed to before 03/12/2001 MARK J.UDREN, ASSOC. By: C0~~. ~ me this J. 7 ~ day of ~ bof A.D, (L. (]~ ' ~onotary ,~ Deputy Sheriff >,'-=.~~ L _ .~ '~ I ~-....:. ~=" . A' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) " .J =L . Till .MMiJl~ik' ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE : NO. 01-1251 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 (13) for failure to file an Answer to Plaintiff 1 s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As seC forth in Complaint Interest . From 2/22/01 to 6/05/01 Late charges per Complaint from 3/15/01 to 6/05/01 Escrow payment per Complaint from 3/01/01 to 6/05/01 $262,267.30 5,550,48 257.61 715 44 TOTAL 5268 790.83 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto, DAMAGES ARE HEREBY ASSESSED AS DATE: (, rO....-t'> \ EN Mark J Attorney INDUTED ,::..:-~ ~ PRO PROTHY ~~ (f ~1~~~,"~Ji~~*liwlr>ili@j~iBl~~,9,~f0""-;' ,;d1"i:Fci"'-Lo':;:::J"-",8;~li~\'lf-wi\j,r"~~I~$~~l\1mI!~~Illffi~d~~~~bil!M. "~ ~ ,,~~ . ,.1. ~":_i o C ? -oex:i rnn"; Z::r:.' ~;- ~. -' "~-' -<~?,' !;=c,- jSr". Z,,--, >0 C ~ < . . o n '-' " , c: ~ _~.:- '-'-OJ ',.:0": ---:;f~:4 ~~j ~~: . " (j2~ Or6 "-1 'l> :"-0 -< r'., :t:"" -;"f'" co ill-- c. -.... _,. ...,'., _, ~ ,.1 . .., ~"- ~ ~i~..J _.~~ ..~. L~ l~i~OOIlIii_lii~;;! MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D. NO, 04302 1040 N, KINGS BIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Riage Drive, Suite 200 Irving, TX 75038 . Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v, Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Roa.d Newville, PA 17241 Defendant(s) NO, 01-1251 civil Term DATED: TO: A:E'ril 2, 2001 M1chael J. Janesko 3966 Enola Road Newville, PA 17241 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 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 NOTIFlCACION, EL TRIBUNAL POPRA, SIN NECEStDAD 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 NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A 'LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL, SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, TBIS 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, .~ K. ~l.__,l__,~ ,~ .tiI"1 .........llIIb.. ~ " ~">"".'"~~-.~"" MARK J, UPREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D. NO. 04302 1040 N, KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Michael J, Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) NO. 01-1251 civil Term April 2, 2001 E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 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 NOTIFICACION IMPORTANTE DATED: TO: US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CAsO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAB DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTRQS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA . NOTIFlCACION 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 ABSISTENCIA 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, ,_.~=. ~.~~' 0 ~ ~~i. '" _ ~ t ,". I ';J, ~'N':;~~:'~ MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D, NO, 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-4'82-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation . MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-1251 civil Term v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey SS COUNTY OF Camden THE UNDERSIGNED being duly sworn, del'oses and says that the averments herein are based upon invest1gations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s} are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Michael J. Janesko Over 18 As captioned above Unknown E. Jade Janesko, Mortgagor Over 18 As captioned above Unknown 9wo~n to and subscribed ~efore me this 5th day 0.". fo. ..June.., .2..0.. G1. . ~ :; ; .' J - ~ ": .. JACQUElINE A GRIESS A NotaiyPubllc 01 New Jersey My Commission Expires 41712003 en, sgu1re Attorney for Pla1ntiff : Mark J. Udren & Associates _: ---- ~"~_"'.I .,.-.l- '" i,~ ~. - ~" .,'. -~"~-""4~,.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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 750:38 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Michael J, Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) : NO. 01-1251 Civil Term TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, pA 17241 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 ~ Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, ES~lire At this telephone number: 856-482-6900 .1 " ....~~ ''"' ", , .~ -< , ~'mtiW'iL~. 1. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D, NQ, 04302 1040 N, KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff. . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Michael J, Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 Civil Term Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest From 2/22/01 to 6/05/01 Late charges per Complaint From 3/15/01 to 6/05/01 Escrow payment per Complaint From 3/01/01 to 6/05/01 $262,267,30 5,550,48 257,61 715 44 TOTAL $268,790.83 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. Mark J Attorney ~- Il-O( IND~ED. ALAj PRO PROTHY K c/(] f DAMAGES ARE HEREBY ASSESSED AS DATE: Ii!.' ~. pt- . "11'-. MARK J, UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-4S2-6900 United Companies Lending Corporation MacArthur Ridge rr 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v, Michael J. Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) TO: Michael J, Janesko 3966 Enola Road Newville, PA 17241 _J ~..,"- . ! -,~'" ',,- ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE : NO, 01-1251 civil Term 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. Money Judgment ~, Judgment by Default Prothonotary Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QOESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J Udren, Esquire At this telephone number, 856-482-6900 . ~ . ~ "^ ~,""'-=" j" ~ 'iJu ':it' ~, ... " .. MARK J, UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NQ. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v, Michael J, Janesko E, Jade Janesko, Mortgagor 3966 Eno1a Road Newville, PA 17241 Defendant(s) : NO. 01-1251 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 '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 forCh in Complaint Interest From 2/22/01 to 6/05/01 Late charges per Complaint From 3/15/01 to 6/05/01 Escrow payment per Complaint From 3/01/01 to 6/05/01 $262,267.30 5,550.48 257.61 715 44 TOTAL $268,790 83 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, EN & Mark J Attorney DATE: {;-I-<- ~D I INDICATED (ILiA, ..U<l PRO PROTHY ~/j ,. ~ r DAMAGES ARE HEREBY ASSESSED AS !.~~llihtli~,I:P]~~',;"c'i ;~i4'}i.,~""~hJ>i~~""-~M:i,,,:JI>iiii;'J'.,,,;,'M~'."""""il;h:'.i;Ji,'."i!*,~~Iil.~ljJ~~~~~Ai~;,lli;1~~b",~1t!ii~~ - _~':O-i'Y!!!~ - . . ~ "',' , , ... I II ;\l l ~@) R ~t... - ~ I f0\)~ t! ~ ',,\" '-" C::{ t-- ~ ~ . r ~ ~' ; 0 <::) 0 ,-= " :?: '- -u Gj rTr";-j -'.,.'" -n Z':'T.1 , r::, zc ':J en ,> f'0 ~~;:::~ '=1~:; !;2G ::r.:. ~~ .'--, " 7() ~ ~...;{~ ~~= sd r-n Z =< (Xl :J., -< ~ ~ ~ ~ I, \1 " \i - }:I 0' ~ :L ""\- " 1 "- I' e -... b:: 1, J\ t ~~ -~",.- t<; , '", ..n ,.. ,~ - ~ ' , . -"~. ' ,- ~ ~ "- - '" ,,- ~ ':\i:'" " . MARK J, UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D, NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ OS034 856-4S2-6900 ATTORNEY FOR PLAINTIFF united Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) : NO. 01-1251 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $268,790.83 Interest @6% From June 6. 2001 to Date of Sale September 5, 200] Per diem @$53.37 4,9]0.04 (Costs to be added) $ MARK J, UDREN & ASSOCIATES ---. ~ " . " ~_I ,~ --" -. --:',. ~'l;Jt ..... '. ~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND ,NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881,57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A, ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864,29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A, ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T~423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE _BY LANDS NOW OR FORMERLY OF LEROY H. . , RAUDABAUGH AND LANDS NOW O~ FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONqS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET ToiAN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SEcrONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 pEGREES 46 MINUTES 01 SECOND EST 324,81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213,45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINuTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS ~OW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T, SHOFFNER AND RAY A, ORNER, THE PLACE OF BEGINNING, CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S" DATED FEBRUARY 20, 1975, TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO, 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND, BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J, JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. ,~st~~;t1!'i"'","""jlili,'!l""Jli;;Iii'[;t'~&r@'@.i1ii&iM;1lt"*j,i,~",,,,,"';~:'ili\,,;;;i.''-->1,'ii,j'i-~r';'JW"H~~M~~''I~_~~~-''~ .. '~'~~.'~WiliIi~l~,.'~>>li'-""'~.~' 1,::L" \-~ r . v- ~ - ~ ,..., . \.9-' o """. ~ <:> - r->~ ~ F0 c>f' , (.N~" -t:- U', 7".1 t -......'-'" (j,\ - c;J\ Cf o C ? -0 OJ rnn-' 2::c- Zr- (fji? -<L.. yO i:o 20 :J>c: ~ o '-- c:: :z. r-........:;. ..,U ""f. S~:~=) Om _-l :5:! 0< \.D H ~~ k' .. ,. (8) -,!-n ,," ,~" . "~ ~ '".~~".... """"'''"'"''''~~''~l,,''''ii::'--<>-'',,",iJ: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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMlVlON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v, Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled, Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C,S, Sec, 4904 relating to unsworn falsification to authorities. MARK J. & ASSOCIATES Mark J. ATTORNEY .':'~"J" ~'~~1:i~':'l'<~'Mli!~~~&"jjW*',1h''''h'!::.~~,;"",(,~<,~jUA~'''c1<,"~~~"""';!tliii~~~_~3l&',....Ml"'ill'~~l<j~~,.~!l.J"olr~ '"Mt 0 0 c: () t?' " 'U-'- c..... fl1 CD c: , ~#] ~ ___ end';: ,,-en ;:s ~~; 1'0 _ ~ _.' L~::") ) ,} .,-L; -;'1(-) ~O """ - ' " -.:ii~ ;'-"~~ 7": )>0 (~~,~ c: ~ s;! <D ::tJ -< 'ril~ ..,~",.. .~",,",,~.b ~". -.J_,...~, ~ --= . "' ~'"*-~~~. > '.il '1 .~ .~,~~~... . '~!;\l,.;\illill!8k~" , 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v, Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO, 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J, Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 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 Greenwood Trust Co" Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E, Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 .~,~_J..~ ,". ~ _ I~L _ ,". -jj , "'--"R'l\<:' ... I 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank, NA, A National Bank 8550 United Plaza Blvd., Ste. 203, Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 13 N. Hanover Street, Carlisle, PA 17013 Domestic Relations Section 13 N, Hanover Street, Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept, 280946 Harrisburg, PA 17128-0946 7, Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 5, 2001 MARK J, UDREN & ASSOCIATES Mar~ "'C. - Attorney for Plaintiff ,=1_- ~" " ,~ ~,-- . - MARK J, UDREN & ASSOCIATES BY: Mark J, Udren, Esquire ATTY I.D, NO, 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-4S2-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J, Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 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 $268,790,83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAT,E To prevent this Sheriff's Sale, you must take immAdiatA action~ 1, The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 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 .~' " ~ ck_ .~' ~ , ~" ~ ~.~ -L_~ ~ . '-'-'i'~\S~~"-,, . ""- YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling 856-482-6900. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900, 4. If 1:he 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 ac1: immediately after the sale. YOU SHOULD TAKS THrS PAPER TO YOUR LAWYER AT ONCE. rF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFrCE LrSTED BELOW TO FrND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERvrCE 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 #]mft~!t6~~!lliili~lli"':"~~"J,+:i!l!i~<1;Iil!ii~'!!H<,",lkj:;'"i&i.i;M;-i,,,,,!!.gU"4~"'N",.~~)t",~"1<Ali<itl'14~!l#'!s~"llt'i\liii!l>~~IMJl!,~~Y~~~~~"'" 'w'" '~ ~!llt~_ ,,, ""l'}' - . 0 CJ C '~ ,; s: ,'1 ;:gto L I,' C Z::n Z . ~ :::.':~! Z~ ., r-~ ; ,,'-' (J)", N _r", ;:,>Z J\.......' '" I <,C "" .-~~i~ )>0 Zc :"11: <.J;;:'::f :5>' - 6f+ c Z .. ~ =< ',0 ::0 -< - ,='-~'~' .". """"11-' ~~ _N, 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 S56-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO, 01-1251 Civil Term Defendant(s} NOT+CE OF SHERIFF'S SALE OF REAL PROPERTY TO: E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 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 $268,790,83, 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 ART.E TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (8561-482-6900. 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 ~_i>u.;. ,od 6_ .. -~ . ,'J ". - ~-" " ,',. ~' il;j 1I,i!!!liL~rt,': < "' YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call 856-482-6900, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days ~fter 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 ~W!i~~~jjWl1;tlf-ofK"JMI'"*~~,,,;,~"('!l.l!iio!""i:ill:>,c3i:Fi'''''M"#i,"';2\i'':'';'''-';''IJ;o~"'''''''fM"",-i~!;i'-lJ:iill~I;!I."""",,EI!!r~.iHWl~~W'!M.J.W;i~;l~~~ ~I~ -" ,. () 0 c: -9 <- -O"CO '- 5P~:;! S __,,1 Ze ........ " We f'0 .,!--;; rs~.. -.1(:; (-, I S:"-~' ~~:!~d ~o :t"!l>. :J,~ r''):::!:.r j;O - ?:Sf;? c:: - Z .. ::< - "" )o. 'D :n -< 'CJ~ .~~ -.-. ..2[ ."~ '"",<-, ,~"I.",~. ., ~' ~ L""-< ~'~ ~--'~'-~-c:"\,, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D, NO. 04302 " 1040 N, KINGS HIGHWAY, SUITE 500 ,CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Michael J. Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) : NO, 01-1251 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 C,P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: J1 MARK J, UDREN & ASSOCIATES Dated: August 2, 2001 Mark J, Udren, Esquire Attorney for Plaintiff ~ ~ ~. ~" ~ ~~ l '",-~' ), I~, """-"'~''j'.~'' MARK J. UDREN & ASSOCIATES BY: Mark J, Udren, Esquire ATTY I,D, NO, 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMlVlON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E, Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 civil Term Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J, Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 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 Greenwood Trust Co" Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E, Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 ~j -~ ~. "' I,. . ~ ',' J.'. f """u'i" . 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank, NA, A National Bank 8550 United Plaza Blvd" Ste. 203, Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA l70l3 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. l COURTHOUSE SQUARE, l3 N. Hanover Street, Carlisle, PA l70l3 Domestic Relations Section l COURTHOUSE SQUARE, l3 N, Hanover Street, Carlisle, PA l70l3 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA l7l28-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA l724l 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 l8 Pa,C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J, UDREN & ASSOCIATES DATED: AUGUST 2, 200l /'/) Mark J, Udren, ESQ. Attorney for Plaintiff .."~J . " -- -= , "'"~ "" "",::.",...",.It; . MARK J, UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-690p United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO, 01-1251 Civil Term v, Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (5) DATE: June 12, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): MICHAEL J. JANESKO & E. JADE JANESKO, MORTGAGOR PROPERTY: 3966 Enola Road, Newville, PA 17241 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 COURTHOUSE, COMMISSIONERS HEARING ROOM, 2ND FLOOR, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. 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CD::!" cg ~ ~ ~i ~ :::r:::rCDll) ~d'~:g ~t:"O !e.3:a ;ol"'""g!!.l>>"g CD < S':r;:::iir ce,2?. -en S' ~ffi!f~ g: e; 5 g mm '" <5"5 0' !!.~ CD ... ffi~ Ccl' _c . _m - (")005 O'CD * Oa.1:l m , ~ .. tJ o ,,";0 "' g?:J~ '" ~ "T1Cf.l-e' g b'" ma,. ~~~ g.~!e. : m m elCD3 go"O -". "2.3 CD tll ~Cil o5"~ ::fC iii' ".00 in:"5 2:~c. = m . 0 ."Ul g:r: JIBIT A m" s ~ ~" o ;:' m t-~~~'~''''b\','',~:>l'#j;l;JffJ~im&iffi!..'iMi'..:!i''R',;;''''~f-<<I~"';'''~'',i:i<:a;"",!!;",-:!i..">l:;11,",-~~~I1.t...leUf!'.t:rr.IIl';t:TY~~~' . ~=~=~.~~~-~.- ..": 0 CI 0 C " s: ". .~ "Ocr' --[- mr,-1 G""") :'i::= Z::::=-' I ':,j :-.!j Z(,:. ~Jr;-. CO Ccll ',) ~C=j ~'_ICJ -0 Zl;;:H :P-c' :::i: ~c5 .c...C) >'c ~ Om '"-I Z => ~ =< <=> ~ ''''"'''' H "__~' ,~',-u,_ " ",~.'=~_ ~ 0_ ,_ ",' ',", We ,~,.i - -""-,.-~.,,,-~..I ~.. ., . . United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko I - . ~'"~ ,- lIi,;lil1l\ti~iIIiii In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Joumal Patriot News 30.00 30.00 15.00 .50 1.50 25.66 6.50 15.00 15.00 4.27 20.25 20.00 465.35 384.33 $1032.86 paid by attorney Sworn and subscribed to before me This n~dayof ~ 2001, A.D. 9r~ {} ~~ Prothonotary So Answers: . r~l~'~~ R. Thomas Kline, Sheriff BY ~()~~ fj, R al Est te Deputy ,,:5 ':50 j6D \. ~ ~Df,- ~/J<t ~""(~ -~~'U,,,,,,,,,,-,I ."~_"K_,~ ~_ .,"_~~...~~, ~" ~ ~ ~ , "-,,.,",1 " -. . 'tl'<i'""~~" 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 ",r.",_ . ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON. PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 2. Name and address'of Defendarit'(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 Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card CarrieE. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 ,,,""_~_. _ L ~- _ ...! 1__""'- JlMli '-'-~ -"<;;!;j!~~",,-,,,_, .. 4. Name record: Name ~' and address of the last recorded holder of every mortgage of Address Plaintiff herein. See Caption above. United Credit Card Bank, NA, A National Bank 8550 United Plaza Blvd., Ste. 203, Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name' Address Real Estate Tax Dept. 13 N. Hanover Street, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street, Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other, person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 5, 2001 MARK J. UDREN & ASSOCIATES _~ ESQ Attorney for Plaintiff - .~ "~,-~ - ~ ~r'~~~w"!\&.ti;;oj;,;;,\",-;-, :. 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 a..- . " ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 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 $268,790.83, 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 PR~VENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (85~1 482-6900 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 - - hd:l..- "~ ~, -~__~<~."'''''''' .. . , . ..,- . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. AND YOU HAVE OTHER RIGHTS 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 j'."""""- ~" _ L . ~"., . ':l&IJ -~~"," .;. "''''-~r'''''''''''''''k''' .~ ,.. . . ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS.NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINuTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAr> OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. ~= " " " ~ "" ~ , ~,~~~ ~ ~~-"., -'':'' '<~" WRIT OF EXECuilON ~nd/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-1251 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due United Companies Landing Corporation PLAINTIFF(S) from Michael J. Janesko and E. Jade Janesko, Mortgagor, 3966 Enola Rd... Newville PA 17241. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at 3966 Enola Road, Newville PA 17241. (See attached legal dBscription.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any ",:' ',..debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) notlevied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Due Pro thy Other Costs $.50 $1. 00 Amount Due $268,790.83 Interest 6/6/01 - 9/5/01 $4,910.04 ($53.37/(hemj Atty's Comm % LL Atty Paid Plaintiff Paid $122.20 Date: June 12, 2001 CURTIS R. LONG Prot ono ary, Civil Division by: Deputy REQUESTING PARTY: Name Mark J. Udren, Esquire Address: Attorney for: Telephone: (856) 482 6900 Supreme Court IDNo, 04302 1040 N Kings Highway, Ste 500 Cherry Hill NJ 08034 Plaintiff t' ~ ", " H~~i1"i!~~iI~!!J~~iai-~;li.jjj~.;a~Il<IilC>lo)I;!'i';!i!:i<!\iiili~iil. ,"......,..-- 'lilIiI'" " - ~~iI!Ii~~gi}~ >~IJtlh.li . '- REAL ESTATE SALE No. 2<6 an --J u V\..Q.. /3, ~m I the sheriff levied upon the oeten03li Interest in the real propert" ~it!liltp,d in, Uorur H-aflkfoccLJW(). Gumbel'fand County, Pa..:i '; ,:umbered as: 3%{g,f:?!t~ 12ct. D!..wJVi.~ and more 1:,\ on Exhibit "A" filell this writ and by this refemnt,. fJate; <.. 1lJf1-L 13 r cJ. 00 I. h,-",:.,r.'Qifi d~-Fl, I".',"c" ~ Svuih JJ-ep ut;} StwVtb ~ c\\\A1~ . \ ,: ~, \~, <.: f\ \','\':' "", \' ' " : .' -' ':': 1\ \\\\\ III ~t to \(J. j'.v ,l,,\I'J , '-"^^I;\~() }.l.,,\\l~ ,;\~\ j,U ;1,f ~~\\0\\" ' ,--,. '" ,- .. -~ -~"',~. r......J 'CViJ c;;;J ~ (fi) r;;:;;J . REAL ESTATE SALE NO. 28 Wtit No, 2001-1251 Civil United Companies Lending Corporation VS. Michael J. Janesko and E. Jade Janesko Atty.: Mark J. Udren ALL TIiAT CERTAIN piece or par- cel of land. situate in Upper Frank- ford Township. Cumberland Coun- ty. Pennsylvania. more particularly bounded and described as follows. together with the improvements erect- ed thereon: BEGINNING at an iron pin at comer of land now or formerly of Harold T. Shoffner and land now or formerly of Ray A Orner (which iron pin is North 22 degrees 49 minutes 38 seconds 'Vest 881.57 feet from Pa. Route 944); thence along land now or formerly of Ray A Orner and through a 10.5 foot dirt lane. North 22 degrees 32 minutes 09 seconds West 864.29 feet to an iron pin; thence along lands now or formerly of Ray A. Orner. North 24 degrees 45 minutes 00 seconds West 1.993.20 feet to an iron pin at an existing post at the edge of Township Road T- 423; thence along the edge of Town- ship Road T -423. North 43 degrees 59 minutes 46 seconds West 32.51 feet to an iron pin at a tree and cor- ner of lands now or formerly of Leroy H. Raudabaugh; thence by lands now or formerly of Leroy H. Rauda- baugh and lands now or formerly of Marvin L, Ruth. South 77 degrees 07 minutes 16 seconds East 1.824- .37 feet to an iron pin at an existing post; thence still by lands of Marvin L. Ruth the following courses and distances; South 61 degrees 16 min- utes ,02 seconds East 375.4-7- feet to an iron pin at an existing post; South 14 degrees 45 minutes 12 seconds East 99.32 feet to an iron pin at an existing post; South 27 degrees 46 minutes 01 second East 324.81 feet to an iron pin at an ex- isting post; South 10 degrees 16 minutes 37 seconds East 213.45 feet to an iron pin at an existing post; South 21 degrees 15 minutes 43 seconds East 320.30 feet to an iron pin: South 29 degrees 55 min- utes 00 seconds East 511.50 feet to an iron pin at comer of lands now ' or formerly of Marvin L. Ruth and lands of Edgar E. Hoover; thence by lands now or formerly of Edgar E. Hoover and lands now or for- merly of Harold T. Shoffher. South 65 degrees 25 minutes 01 seconds West 1.705.08 feet to an iron pin at comer of lands now or fonnerly of Harold T. Shoffner and Ray A. Orner. the place of BEGINNING. CONTAINING 86.0677 acres and said description being in accordance with survey of Carl D. Bert. R.S.. dated February 20. 1975. TOGETIlER with the right of way from a private road or land extend- ing from southwestern comer of said tract of land over. through and across the lands now or formerly of Phoebe A. Warner to highway rO!J,te No. 944 and now as a means of ac- cess to and from tract of land. BEING known as 3966 Enola Road. Newville, PA. TAX ID NO, 43-04-0387-036. TItle to said premises is vested in Michael J. Janesko by deed from Maurice G. and Elizabeth B, HillIard. husband and wife. dated 2/18/ 1994 recorded 2/18/1994 In Deed Book 10 1 page 846. . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATE OF PENNSYL VANIA : SS. COUNTY OF CUMBERLAND : Roger M.Morgenthal, Esqnire, 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 Joumal on the following dates, VIZ: 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 of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. RO~ditor - SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 " NOTAAW,' LOIS E. SNYDER, NoIIIyNlllc CarliafeBom Cumbertand County My CoriImiseloII Expims MIn:h 5; 2005 . ~-~~I-- ~ 1'l", A~ ESTATE SALE N'o.21l ~~, :~~--Wfit No. 2001-1251 -, , r:l~ivilTerm- -. ,UmteaZompanles ,!1t1~~~~~~a_:~~~~ ';_ ~.~;-i ,~;:-,iJ~~~':"~~T;~ EALL THAT CERTAIN piece or parcel!)! 13Jl(l, :~-.sI~uatc <''j~ :~~~~ ~r~~!:?rd ,Town~hJp, ~ml5etia~q,_;~ ~o~;.n1Y. ~~.n~~yh3nJa, more 0: p:rttWtliaily ooimded ann oe$Cnbed as fo]]ov>'~ ~"Wg'aher with the- Improwmcnts erecterllhercon:. ~:BEPlllNL.l\IG at an iron pin at comer oj' land 1!:,~~lOrt!iOrlY of Harold T, Shoff",~ and laod _ ..o,_-r _(QTmerly brRay A. Orner {which Iron pm 's:notlh~de~ees -19 minutes 38 seconJ:; \\-e\t ~r3:rJ\:,~J _UO,in:1'A:ROlllC '144); thence along :lima.:or f0l1llcrly of Ray A, OrTh:r and ~pWu,gh a 10.5 foOi dirt Ja~, north 22 degfCCs 32 ~p,18 ()9 .'iCCCOO~ \<-e,t 31H.~ f<:d to an Iron !o,pll'J!-ilicR(:e'aiong\1nd,~ no'h 'or formerly of Ray =A-;-,Omer, nanh 24 dCIll"~s 45 minllte~ 00 '-----li<<mnds west \ ,993.~ fc~t to an Iron pin at an ~5ting post at the ~dgc of Township ko3d T- ~; t,~.el)~e :Jlong t~ ooge of Town~hip Roa.d T. - ,J23. north 43 dl,...grO;:~ ~q minutes 46 .....~onds Wt,37,s1 f~t,to\lltlronpinatatreeamicl)rner _ 01 lands - now. (Ir' - formerly of LcRo~ H. ~.m:td,aOOllgh; thence by lm<l:, now or formerly of ~by H.. Raudabaugb and lands now or ~ ~rronerly of Marvin L. Ruth, south 77 degrl't:, 07 ;oi"Ifiiililtl5_1(5"seconds east 1.824.37 feet to ~m Iron piTla"t"au~"astingp:os{;Lihcnce still b~ IJnds of t:i".f:il:\'io L Ruth. the .followlllg cour;l"> :md ~!scanccs:' ..ou(h"ol~~~grees 16 minutes 01 ~5c.i~r375.47f<.'t.,(ll)an'ronplnatan ~5!ln.f' post; .wtiih.l4 acgrees 45 minuleli l~ -=--sec-onds ea~i-99,3.2"fcct_to an Jron pJD at an ~e.xisj.ing p<Kt; soutl1 27 lkgrecs -t6 minlltCS :01 8~6rfd. ell,l .3?~$1 ,fed to an \ton pin at an ttiiSii~ ~t: S{l~U:tn }O degrb.--s '16 r:ninUlc~ ~7 ------sccond:u,::a~( '2 lJ.45 -Jeet to an ITon pm at an ~~~Ulh 21 degrees 15 minutes ~3 ~d$ em;( 3;0.30 f<;)."( (O an iron pin; sOllth 29 ~~lC>.'S 5? minuk'S 00 .~omls C<l~t 5-1 1.5/) fc.('{ if tQJm ltOJ) pln ar C01'ller of lands nO\\l or formerly ~f.}"1arvin 1.. R"uth and lands of Edgar E. Hw.'<.'t; =O{fienc'c by lands now or formcrl~ of Edgar E. :: ~oo~er and lands now or formerly of Harold T. 'Sfioffner, south 65 degrees 2S minutes 01 ~-$.(ioo:ds__wesUA105.Q8 feet to an ITon pm at -.dlt@:( of lands now or forrtlCrly of HM.lld T. ~* ~.arid Ray A. Orn~'f, lhe place of L.~~lNG. , , ~ Q)ntaullng '86.06n acres and said &M:npuon ~- .\~, i'traccoroanee with :.urve~ of Cl.rl D. Ben. , ,;" dat&! February 20.1975. =-- getli~r wim.the' right->{)f.way from a prh'ate =--roau.J;!c land eMending ITem soUlhwestcm carner 01 s~ld ll'3Cl of land O\(."f, (hroueh and acros~ the _ -JilnP!> nolI:' or fOmk'lly of PtlO.:be A. Warner. 10 f J{jgbway Route ,No. <)4-J. and now as a ffie;Jns of ~-~.c.ess-to-'andTrom Ir3CI orland. IillElNG known as 3%6 Enl)\a Rood. N\:\vville, ~P!o;~ ' j,o~ (D NO, 43.04:<)387-036, ' ~n.E"(\l said prcini,i<I is \'eS{l'd III Mkhad 1. ~a~!:kQby ck'e4 fron(M.lU/iC<;' G. and Eliz.:ibl'l~ '-H.J:filliiWd,'nusoond and wire. d:ucd J/l8-JJ99-.J. reb)j'(ji.'d2J18/1994 JI) Ot.w Book lOt P:Jge 146. -qili!"l>~ ~'"" . . """'- o. I.. "I 1Jlhd ~.~ '.."'~i;ll.i.*~" : .. '. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 24th 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 the office for the Recording of Deeds in and for said County of Dauphin in Miscel70us Book "M", V;I~:~I~:~:~~' ........................................</t....................... ......................... COpy e thi 21st d of st 2001 A.D. S ALE #28 Notarial Seal Tony L. Russell, Notary Public HalTisburg. Do...., County My CGinmIsslon ElCIlir.. June 6. 2011! NARY PUBLIC Member, Pennsylvania Assoolalion ot -"My commission expires June 6, 2002 J CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 \. Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 382.83 1.50 384.33 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.................................................................... d ~ -C~~ .L~' ~'. ~ ,'. ~.._j ,c " -' ~'~ ,'. Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + to) .. t." Page 1 of2 Bankruptcy Docket Report 101-04746 (Harrisburg) JANESKO, MICHAEL J and JANESKO, ELLEN J Docket items entered between 0110111931 and 02/07/2002 Filing No. Docket Entry Date 08/31/0 ] ] VOLUNTARY PETITION under Chapter ]3 & Mailing Matrix [Disposed] [EOD 08/31/0]] [CR] 08/31/0 ] 2 . NOTICE ofintentto dismiss case unless missing documents are filed: due by 09/17/0] Re: Item # J. [Complied] [EOD 08/31/0]] [CR] 09119/0] 3 CORRESPONDENCE to Attorney allowing until September 26, 200] to file missing documents. Re: ltem#2. [EOD09/19/0]] [CA] 09/27/01 4 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. [EOD 09/28/01] [BR] 10/]8/0] 5 CERTIF]CATE of Mailing of Notice of34] Meeting. Objections to the plan are due ]5 days after meeting held. [EOD 10118/01] [CA] 341 meeting held. [EOD 11/20/01] [CA] . 11/19/0] 6 MOTION for relief from stay filed by EMC MORTGAGE CORPORATION. (pd., $75.00 Rec.#576248) [Disposed] [EOD 11/19/01] [SP] REQUESTfor admission [EOD 11/19/01] [SP] CERTIFICATE OF NON-CONCURRENCE [EOD 11/19/01] [SP] 11119/01 7 ORDER that answers aredue on 12110/0] Re: Item # 6. [Rescheduled] [EOD 11119/01] [SP] 11/20/0 I 8 341 meeting not held-to be rescheduled. [EOD 11/20/01] [CA] 11/30/0 I 9 CORRESPONDENCE from Movant requesting reissuance of Stay Order due to non-service. Re: Item # 7. [EOD 11/30/01] [SP] 11/30/0] 10 ORDER that answers aredue on 12/2Q/01 Re: Item # 6. [EOD ] ]/30/01] [SP] This entry cancels the previous due date. Re: Item # 7. [EOD 11/30/01] [SP] ]2/03/01 11 CERTIFICATE of service of notice of rescheduled 341 Meeting [EOD ]2/03/0]] [CA] ]2/07/0] ]2 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on 0]/1 0/02 at 02:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. ]7]08 [EOD ]2/07/0]] [SP] 12/07/0 I 13 CERTIFICATE of service Re: Item # 10. [EOD 12/07/01] [KZ] 01/02/02 14 MOTION for default judgment Re: Item # 6. [Disposed] [EOD 01/02/02] [SP] 01/02/02 15 ORDER granting default judgment Re: Item # 14. [EOD 01/02/02] [SP] ORDER granting relief from stay Re: Item # 6. [EOD 01/02/021 [SP] 01/09/02 16 MOTION to reconsider Order Re: Item # 15. [EOD 01110/02] [CG] 01/14/02 17 CORRESPONDENCE SETTING PHONE CONFERENCE on 02/05/02 at 10:30 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), TIllRD & WALNUT STS., HARRISBURG,PA. 17]08 Re: Item # 16. [EOD 01/]4/02] [CG] 01116/02 ]8 CORRESPONDENCE from Trustee re: hearing. No appearances for debtor. Case to be dismissed. Re: Item # ]2. [EOD 01/]6/02] [CG] http://pacer.pamb.uscourts.gov/cgi-binlfoxweb.el'e/npacer/nPacer?ExecThis=docket&pui... 02/07/2002 "',wt " k-"~ ~I ~ ..~ L Ie - ,> ~, ""-'~, Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 2 of2 " . '-~ 01118/02 19 341 meeting not held-to be dismissed. [BOD 01118/02] [CA] 01/22/02 20 ANSWER by EMC MORTGAGE CORPORATION Re: Item # 16. [EOD 01122/02] [CG] 02/04/02 21 ORDER dismissing case for Debtors'failure to appear a1341 Meeting and upon Trustee's Motion to Dismiss Re: Item # 1. [BOD 02/04/02] [CG] 02/06/02 22 FINAL REPORT of Ch. 13 Trustee Re: Item # 21. [BOD 02/06/02] [DR] Printed: 02/07/02 11: 13 :44 I PACER Service Center I I Transaction Receipt I I 02/07/200211:13:44 1 Ip ACER Login: IlmuOO11 IIClient Code: 1 IDescription: IIDocket IICase Number: 1112001-04746 1 IBiIlable Pages: 112 IICost: 110.14 1 ". Need help? Try the PACER User's Guide liiilPacer Service Center http://pacer.pamb.uscourts.gov/cgi-binlfoxweb.eJ{e/npacer/nPacer?ExecThis=docket&pui... 02/07/2002 ;,~>" "~'~':ij;i'lt ..- ~ ~>~ .'".- .,1 ~~~ "~""I,,,,,,K';,,,,.~l~, "' _"~ '0' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0'8034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. . . NO. 01-1251 Civil Term Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: ____A. In Assumpsit (Contract) ____B. In Trespass (Accident) ~c. In Mortgage Foreclosure ____D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: ~A. ____B. ____C. ____D. ____E. F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): ~A. ____B. C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendan is re ident of the Commonwealth of pennsylvania. Resident: ESQUIRE # as above :~.~"'S'_'.I;'''';<'.'C~~'''"JT&>h.iii'l;j,f}il'S,!j!l;;.iii@llill'i!ji,iJM!i*,~;;'Jiij"\c_"''''__~>"-",,-!e,,,";'1t~'''''i1''f,~~,,;:;,;i'B,~,--'II.'~~,iihi;~~"ffi'lil~;;j;,ilii~~\!,~~~_~-~ 0 0 0 C 1'0 -05: -n ::r. mea ,-" Zen ;u -- 7F";;,;" r ["'-- (5)> ::~:; E:; -< ;:~ kG " -,~? C~) )>c f~f~ z' :Jl: j;:O ~ C Z ::;I i:"', -,,: ~ry , C> -< ~" .'- .~'~" ,~-"- _~~J ,<-, I~ " -j '-'".'~t~/i MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HIL~, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, suite 200 Irving, T:lC 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Michael J, Janesko E. Jade Janesko, Mortgagor 3966 Enola. Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $268.790.83 Interest From June 6. 2001 to Date of Sale June 5. 2002 Per diem @$47.90 17.483.50 (Costs to be added) $ REN & ASSOCIATES , ESQUIRE LAINTIFF ,~"\A'd'~~'- , "'-~ ~I" ~-~ ~, ~ ~ = l~,t~iSl~Q MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N.KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ OB034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, ,TX 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) . . NO. 01-1251 Civil Term WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 3966 Enola Road Newville, PA 17241 SEE LEGAL DESCRIPTION ATTACHED Amount due . $268.790 83 Interest From June 6 to Date of Sale June Per diem @$47.90 2001 5. 2002 17.483.50 (Costs to be added) $ Prothonotary By Clerk Date ,~~.~.hrMf~;;*U"':\",,;',;'k,~,,,',o;",h';I<Ml~0ili%'il2iriilii"ii:ifc~,';C""',,, ,_ ",tLi;"",I",'l--""',;e,"'r'":d,A.~"d',:iW_!l~~rJW:...LiJliill8b:-iatl'!lW',!lr-lL~!j!t:j;"'~1IDIDj;Mll\$iiM_~iltl~",L .~-- ~~~ ",: COURT OF COMMON PLEAS NO. 01-1251 civil Term ~==================================== United Companies Lending Corporation vs. Michael J. Janesko E. Jade Janesko, Mortgagor ~==================================== WRIT OF EXECUTION ~==================================== REAL DEBT $ 268.790.83 INTEREST $ 17.4B3 50 from Jun~ 6. 2001 to Date of Sale June 5. 2002 Per diem @$47.90 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ PREMISES TO BE SOLD: 3966 Enola 0 d A ! 241 J. U en, QUIRE K J. UDREN & A SOCIATES 1040 NORTH KINGS H HWAY SUITE 500 CHERRY HILL, NJ 08034 (8S6) 482-6900 ~. , ") , .;, ,~I "~~~~"Jl"~~"o'. . . ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND PESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING ,AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 42 PEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944) ; THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDs NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN ,AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14. DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DE;GREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2(18/1994 IN DEED BOOK 101 PAGE 846. M".'';''o'~' ,",,' '~_!!tif~.w.!fJili!6;;~~"1-',\i~~,;,,",;,,:;;,,,'>ijUi\\!~'j,,!W~'0,W;V,,"~i,iBl~llIIiIll!lllr'-""'~o"~"~"~'~' ",k~~l.-." '~~ ~...,"'""~ ~ ~, - @ - () \ E;-". fb " I --.....J' ~ il \ \~ \ 0 C) r. ~ \ J c '" ~1-1 \ s: :x -- -0 (TJ :r.~ 'T\ 10 r-- rrlrn ::0 I, -...... Zr' -"t~t 1-J I: C' Zr:- I ~ i' (f)~ ~,~ Cf7 W i! U< -<.:.:.. ',:,:::~~ f:') Cv i; !<:CJ If' i\ -0 ''-0'- " () '" (.N -+:::-- Pc :x Q~~ 'b' " --,.. ......... '-.."'- 20 'f'0:-Cl ?' ~ <->( <?'\- 5>c w (Sri1 ~ 2 ~ C() t;; =2 w CI'. <:) ~, ~ -< ,[ " '3~""""'-~= ._.'. _,i-,;,"~ . ".ow IT lti,~oW,="--';;;"-""'~"'~{"' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . NO. 01-1251 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. & ASSOCIATES .~1t"';'C>"~\'i'1~~i1;~0~,,,,Lvi't.r.4ii*'fJR~~ill.>i'1'''''''-~,;,,,,,,. ,.."","",,,:.ro'~,,i'i>\'H-'!,"'W,~~'~~H-liil~' 'h;;'h~~~,~~Q",.<Mf,ovill~~~~f4!lt-=O".. o >;; "t1:s. men zIT! 2:::1:; we;:: ~-, -,'""- <c )S: ZO ~O J>c: z :::< o. J .. ". ." ,,' w o o '" ::J:: 0::.. :=0 J :-';:1 '";:fj ("" ,( ~() E~;B "/', )- Cyn :;;} 5;l -;: - v .::t1: C,j .. ^ 1"1 i 1 Q " r ,~aw ' Q'~ , ]. '" 1Il!!k:;,:~"!"~""",~..!d"""jf,,~, .# ... 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 - . NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 " t.-. 'C . -~-' ~ ",,' , :;-~,,<~,c.,,:!O,,';~if',,' .- ..., 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank N.A. A National Bank 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlise, PA 17013 Domestic Relations Section 1 Courthouse Square, Carlise, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 15, 2002 Ma J. Udren, ESQ. Attorney for Pl intiff "'" llfi" .' "~ .~I ~I. ~''''-",,'''''''''t,"k,"-,'~'', .r';~'.'tti~' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Jarresko, Mortgagor 3966 Enola Road Newville, PA 17241 . NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, 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 PREVRNT THTS SHERTFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~!;~ b .. I. - ~" 1 IIOlI '~-_'<",,--,..,;~,c"!', .-. ..... YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distr~bution 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 FlLADELFIA CUmberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 _ c'"" """,~"'",,.,,"; LI~~M\~,\';IIJiiMi&.i~iI'l:i,B'illic,",4-:,,,,,\.;",,\;'''')'i;hUi,C'"i''',",;,l;:a'''''i!,;il&:,''':~<iillw~..Mii!!\lik!:l~~~Il<*.<lli.tiiiiiBii!k__'''"^~~'._ "~'~~ ... .J. :,,- () a () c: N -~ -1"1 ~ffi ::J:: rr :F.>> 2.:r': ::0 ,J;! Zr-c, I ;"'1 rn"t:=, ';,-"-1 r:i"- , (Sl' :<c "1:) .....;--] 1.. ~J ::Pc ::J:: ;:r:i1 ZJ G~:: )>0 S'? c: Z ~'.'l :;J ,:,...) ;;> '-' :lJ , -< '~-" -,~,'" '-~. ~~~ -~~, .. .<.. - It ','c. .. ~~... I, ~ ~=----"~e"""L',,"~';;'P,i,' , I .J.!,. " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, 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 ABLF. '1'0 PREVENT THIS SHERIFF'S SAT,F. To prevent this Sheriff's Sale, you must take immediate a~tion: 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ ""~__ ~~,J .~ '" .~~ '1I>Ollilii",<'il.L"%lI_""""''''''''~''''~r__-1,''; 'j. t '. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU 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 1 ~ '. ~~ -"~ "",,,,,",-,-",.h:.l.",,,~_," ' A , ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN'EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE. ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, FA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. Ji<"~r";-~' ,~",,-,' .' 81 'iim.ifJ1P;~1~~'Jj;;;":!li']!!KW&~~.*;e:~!5ci'l;"'->~"'--A"""~":ll",;4,"=~,"""'i:i\"-'"iik~!l-R"i,;",1"'!.di}"-">"'lrhi6~~'T '"-~' """'~''''''''\ijilO1''''- ~..~ - ~ ~ I ~~ ~. .~ ~ ,~ ~ ~ " 'wlitii~'II~'.<J.'"" "",' .ell : ~'~T'rL\ (') 0 0 C N -'n $: ::tit =--::! ~tTJ :x:n mn; " ZX; :;;co iT' , ZC;:; I -",["'71 (f) "'" !C:J -<L ~=~l ~~ r:-'" ...-'l.._i -0 .~ ).">0 ::l: Z - t~:~ -(-' pj ~ C Z w b! ::;:I :0 ~ 0 -< ~ ll!; ',," :.' ~ . ,. . [gJ'"'"ir'-~-""'J..""--,,,-~...,,,,.-p, . United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30.00 30.00 1.00 6.90 15.00 1.66 $ 84.56 paid by attorney 3-18-02 Swom and subscribed to before me so~ ~ ~~t:~~ R. Thomas Kline, Sheriff 2002, A.D. ()'f'P , C'. ~.~ By0oclt;~J~ Real Estate Deputy This .;;Io!Y day of ~A./ Prothonotary I,OV CIe- 3s'"q~3 R.u.-, j.2 3M 5' '"'. ~ . ~~ ,,< ~~Uil'~~",,-'" ,.' '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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 - NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: ... Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 ,;jo><'l'lf- ". ,__ ,I --'. ...:, '~~2~ . \J". 4. Name and address of the la~t recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank N.A. A National Bank 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA.17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the prope~ty and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlise, PA 17013 Domestic Relations Section 1 Courthouse Square, Carlise, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true ~nd correct to. the best of my personal knowledge or information and belief. I understand that false 'statements herein are made subject to the penalties of 18.Pa.C.S. sec. 4904. relating to unsworn falsification to authorities. DATED: February 15, 2002 ( Ma J. Udren, ESQ. Attorney for PI intiff .~~Ioo:~... = - A 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ~, ~ ,I I.,. _, '!lhi:~I$" '. ~-~,,, ~ , ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-1251 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the pr~perty will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856)-482-6900. 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 rig~ts. The sooner you contact one, the 'more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ ,'~_ I __ J, _. ~ ~ , , " i b ~. ,~'. '"-!~.(j: t : YOU MAY STILLL BE A.BJ.E TO SA~OUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES T~ 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why ,the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale." YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 - ~,~ "" '< <-~.'"'~,~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND hAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32..51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVINL. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS .EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECDNDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR. FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY' FROM A PRIVATE ROAD Ol<. LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO; 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G.' AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. '\'~.,L, ~,.~ .> , ~ .' '. --., " Ie.,., ~ , "~'~" ,~---,,~ 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 United Companies Lending Corporation. MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3.966 Enola Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defenda.nt(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, . Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the prQperty will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY RF. ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immadia~e ac~ion: 1. The sale will ~e 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) <;.""' . ,~ ~ "'- , ' .0,,1 ~ ",', -- -=.. ""~""~- ," ~ : .- XO~Y STILL ~A~E TO SAVE YOU~ PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482.-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the'buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will oe ,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 aftd defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS P~PER 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 - ~-"~ , .~- - ~l, ~" - .".' , '~ ' - "''1'!',' ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINU~ES O~ SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423. NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DE;GREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1, 705 . 08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF' SAID TRACT OF LAND OVER, THROUGH AND ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A.WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. ',i.'i"""~"''''''~ I , -..' , , oL ~~~ > _ l.. I. ." ~ """"~l'" ""-"""'c.'.;-'-',,;,.",,...-, WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-1251 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORPORATION MACARTHUR RIDGE n, Plaintiff (s) From MICHAEL J. JANESKO AND E JADE JANESKO MORTGAGOR, 3966 ENOLA ROAD, NEWVILLE, PA 17241 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee( s) that: ( a) an attachment has been issued; (b) the garnishee( s) is enj oined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachmeut is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated, Amount Due $268,790.83 L.L. Interest FROM 6/6/01 TO DATE OF SALE 6/5/02 PER DIEM@$47.90-$17,483.50 Atty's Comm % Due Prothy $1.00 Atty Paid, $1,167.38 Other Costs Plaintiff Paid Date: MARCH 1, 2002 CURTIS R. LONG Prothonotary, Civil Division ~: ~(hp 2 7?d?/?~y,-r;bR7 REQUESTING PARTY: Name MARK J. UDREN, ESQ Address: 1040 N. KINGS mGHW AY, SIDTE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 _". ""'<""~,;Wi';;",",,,4.!lii!rl.~""I~i1llil\~>t;~~>'ilI1i~M11!!,"g111!!'UI~Ij;}\;j~*"dS;ilill1~~iilI.:ii$.!1:*,,*~.;!i&iF-''''''~-' ':' Real Estate Sale # :5 C) On March 12, 2002 the sherifflevied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, P A known and numbered as 3966 Enola Road, Newville and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2002 By: ~~ Real Estate Deputy (--~ CViJ eu:a ' ~ CW IiViI \f I hj V r\ "1 f S r~ r~~ :3 d "I ~_' ," l-j ZO, Hd i;T ZI 9 HUH Al~nL. , =8~no J.:llli311S 3111 ,,0 3~L:i.:lO ~ c "'",,, ~,_ _ ~,_ , .~,~ ",n ~'"h,_.. _" ,1. ,'" _" . ",_. . ~ . '-'- ~' '. WI~\.,IkH/ !!' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 - NO. 01-1251 Civil Term Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $268.790.83 Interest From June 6. 2001 26.617 36 to Date of Sale March 5. 2003 Per diem @$41.72 (Costs to be added) $ MARK J. UDREN & ASSOCIATES it[j~:'~'.G'~~"'~ ..,L'"i_~!it'~~---"~'''J1Il-,,:;;,..,,/,'-,,'''''a~::j,"-,,~jS;i,f!fr-n,'',.,..t-.lHli~-~ ,,,"...,,",,,,,""~~~"-' i~""'_~, " ,~,'. " " ,~.~ ~ "-.,,~-- ~~ -.- ". -'--lItimi,'iln, ' ~jj~1 ,"." \7~ , - e (") a .:::J ~ ,'>:> -'I'I '_J -ocn r" mG. " Z:::l! ZC , :1'"'; W"",' (..) C.J -<" r-::: t::~ ---""'i :<::'-.' ~~) ~r' ~~ . " (,~:I:' L(-~ :::';':() >c r::- eSin Z o-l =< "" 5; <.11 -< Sf> f-I~. , " 1 I --~ <1S<' '~ ~4"", < 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 United Companies Lending Corporation MacArthur Ridge,n 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 - - COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE . , ':::;:. Plaintiff . v. Michael J: Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 - - NO. 01-1251 Civil Term Defendant(s) WRIT OF EXECUTION TO THE SHERIFF OF CUmberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 3966 Enola Road Newville, PA 17241 SEE LEGAL DESCRIPTION ATTACHED Amount due $268 790 83 Interest From ,Tune 6. 2001 26 617 36 to Date of Sale Marr.h' S, 2003 Per diem @$41.72 (Costs to be added) $ Prothonotary By Clerk Date ~';'~~~ ). 'jJj,li!Il!!llit.,!l.ji*W$::,"~io>-~(~~,lliii,....",il!i'!!i:L,---,li'ii:C-&:~W-'I'-cli;;,hi;'hlm'*~;~,a';cl<.;J'ij~..1i~i.;'m"i-o--;j~_~~"'i~~~-...J"'~'.. ~~ ol!~ ,. ". COURT OF COMMON PLEAS NO, 01-1251 civil Term ------------------------------------- ------------------------------------- United Companies Lending Corporation vs. Michael J. Janesko E. Jade Janesko, Mortgagor ------------------------------------- ------------------------------------- WRIT OF EXECUTION ------------------------------------- ------------------------------------- REAL DEBT $ 268.790.83 INTEREST $ 26.617.36 from ,Tune Ii. 2001 to Date of Sale March 5. 2003 Per diem @$41. 72 COSTS PAID: PROTHY $ SHERIFF $ STATtJ'rORY $ COSTS DUE PROTHY. $ PREMISES TO BE SOLD: 3966 Enola Road Ne~' e, PA 17241 r J. Udren, ESQUIRE MARK J. & ASSOCIATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 (856) 482-6900 e'~~,,, "'.",,,"",",,'"'?'"''''''' ~.." "~,", ~."" _~, ^~, ""'",.-. ,~<,~.", L", . "~,,,,_ ~ .~l . _,;.J.. ',:! , , , I,'f", 'I ~" (") 0 ;;,::; C l'<o) "' , :;:: 0 "'Un,'i P1 1"11[T' n , "Tl Z:r_, . " Z r--- ,', F~ (j) ).'-;. 0'::' ""', ,--~ -<:2' ~l i r-r"l ~~ ::< .......- ,. ~Q -~ j>~ z:- ~ N ~ ~ (A -< I!l: ~~' .",~J if.......~..'.'i.. .' ,"",,' . :'l~; ~t . . J 1 ~ ~~iu,," I.~ .~ , ~ I..~ .. ~,~~' o. "...~-----'--" -,-~-_. .,-'-"'-- ALL THAT CERTAIN PIECE OR PARCEL OF LAND,' SITUATE_!~ UPPER FRANKFORD TOWNSHIP, ~- CUMBERLAND' COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS .ERECTED THEREON: . BE.GINNING AT AN IRON. PIN AT CORNER OF LAND NOW OR FORMERLY OF. HAROLD T. SHOFFNER AND IJUm NOW OR FORMERLY OF RAY A. OlmER(WHICH' IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA.. .ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF. RAY A. ORNER AND .THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 . MINUTES 09 SECONDS WEST a6~.29 FEET TO AN IRON PIN; THENCE ALONG '.. LANDS NOW OR FORMERLY OF RAY A.ORNER, NORTE24 . DEGREES .45 MINU'l'ES :;,. 00 SECONDS WES'1'1,993;20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423;THENCE ALONG THE EDGE OF TOWNSHIP ROADT-423, NORTH 43 PEGRElilS 59 MINtJ'rES 46 SECONDS WEST 32.51 tEET '".- . TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF . LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. .,;, .RAUDJffiAUGH AND LAND.S.NOW0R FORMERLY OF MARVIN L. RUTH,' SOUTH 77 . DEGRE~S 07 MINUTES 16 SECOl'mS EAST 1,824.37FEET'TO'AN IRON PIN AT . AN EXISTING POST; THENCE. STILL BY LANDS. OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; BOUTH 61 DEGREES. 16 MINUTES' 02 SECONDS EAST 375.47 FEET TO AN IRON PIN .AT AN EXISTING POST; SOUTH .14 . DEGREES 45 MINuTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT . . AN EXISTING POST; SOUTH 27'DEGREES '46 NINUTESOl SECOND EST 324..81. FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST '213.45 FEET' TO AN IRON PIN AT AN'EXISTING 'POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN . IRON PIN; SOoTa 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET . TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY. OF MARVIN L. RUTH AND LANDS OF EPGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E.: HOOVER '.AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER; SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER 'OF LANDS NOW OR FORMERLY OF HAROLD T. 'SHOFFNER.' AND RAYA. ORNER, THE PLACE OF BEGINNING. . . . . CONTAINING 86.0677 ACRES AND SAID DESCRIPTION: BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R; S _; DATED FEBRUARY 20, 1975. . TOGETHER' WITH THE .RIGHT . OF WAY . FROM' A . PRIVATK, ROAD OR' LAND' EXTENDING FROM' SOUTHWESTERN CORNER OF SAID TRACT .OF LAND . OVER , . TBEOUGH'AND ACROSS TEE LANDS NOW OR FORMERLY OF PHOEBE A. .'WARNER TO ..HIGHWAY ROUTE 'NO. . 944 AND NOW AS A MEANS OF ACCESS TO AND FROM. TRACT OF LAND. I' BEI~G KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-q36 TITLE TO SAID PREMISES.IS VESTED IN MICHAEL J_ JANESKO BY DEED FROM .MAURICE G. AND ELIZABETH B.: HILLIARD, HUSBAND AND WIFE, DATED .2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE'846. . ", .',(. .~,~" " .' .."~~ . ~~li>l!iIilll1g1 ;M!I11~~G ~ kc<il:i,"i"",d;'\.t~1MI~UoliMl,lk"Jjl,",""~~i\;~~~ 1~"iIHrtt!Jd~~'.>ill;fu!~;JtH.~;l;~!",.,'~&~".\i.,:i\,.,;",l~'%M.;,~,l\i ~t: [ Jd\ I , --- ~ i?- 0<> ------.. ~ ".~"<~,,. ,.,,',~. -, ~ ~ --.J' 1 -- R.. -- Oy ="\\ _ 0-l___ --r-SJ'1 r?\ ~ ~ ~ ., <. ___on _" ~,~ ,.l u"'~ ",,~ ~ .~ . " - -- ~ LN~, ~~ ~' '''Q - ('U ~ o C ? \)&"': fT1r+: Z:J:.~ ZC ~~: ~..._, ~'--., =- ?Eo -, ,- .-.0 01'1' >~ ~ =<! ...- o 1'0 ~.::J jY) ,> I ','. ~.' c' -',"j 'T1 \-- "IJ n ~~ ~~n ~-?-.:(? 0" ~ :n -< <? 3 N U1 h "U'~~ ~ .1 . . ~: ~ ~== 'o.,~ ~.~, ~. ~~," '" ~"~ - , I", ~ .'~m<$'^~tl-'" ,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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Eriola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on March 5, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAT,F, TO prevent this Sheriff I s Sale', you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900 2. You may be able to stop the sale by filing a petition asking open the judgment, if the judgment was improperly entered. Court to postpone the sale for good cause. the Court to strike or You may also ask the 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . :~ . . ~~ ~ il. l~if,^-,i.,---- .' \YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHRRIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~'IT~F"~'lia~~cIfoli';{~~~1,\ll'1~(,,,,;<i,,,,,,:i;'!.''-,,,,i,~<'i.''^"'''~;"J",).,j~,."",,,,.d,~JJ:,;~~~..:.t~~!liMiI~~Mj;~~i:f";";' -~ '. ( (") c:> c:;) C N -,-, s: 0 -00::; 01 mrn " C' 27,' , -':;~~ Z~)> ~L-:' w ~~g !;2C: -0 Z~ :J: r;J (~) u )>0 t::- Orn c:: -l Z; "" ~ ::;: <.n , <.-, '" ,~," ,~'" - ,~ ,~, n'~ ~~ '^, " ,..., , ",' ~. . ,~ n~.' ,.k_. _'.~' .~ . I, i 'it'~~, 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 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 en, ESQUIRE FOR PLAINTIFF -'<' "'~tolill~%,;,-~~~~lIi'mi>iID\*~"'m,.:&L-,>,""~"I,'j<1h",,,-;,,'<,-j,,e;,,,",--j.'i"'t';,i'-""'!1it~fulj~mt~'~~Ull;! ~ " ,~~ ,~.~ , ~ ~ '~~~, ,~ ~ -' ~" '~ilIio~f""""'-"~~".-'- ~. -"~~'"~''''ii- 0 0 0 C \'-' ~,"! ? 0 ";'-0,., -Ul'r:: n"'I . ,::~ 7'/::' T11l" ,C"1 Z:I"~ ! ""-,0\ Z~, ,;,", GO ~'< ": ~:?~ ;:'~! ~~~ !2C) ---0 _,,:""---1 ~O ~.,~ '~~~ (~:~ =0 c- Orn >c -\ ~ N 35 Ul -< IT" =~_ ~L - ~~" '" ~ .' ~ ~,' ~ , ~ ~ ~'-.~""" ~, . ilo'II"I&"'..f,< .~~ J. UDREN & ASSOCIATES 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA l7241 . . NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.l United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA l724l 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 1724l 2. Name and address of Defendant(s) in the judgment: Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA l724l 3. Name and address of every lien on the real property to Name judgment creditor be sold: Address whose judgment is a record Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA l71l0 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 ,~ -~ . " '" , ~ '" '. '!~g .c 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank N.A. A National Bank 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlise, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlise, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and knowledge who sale: Name address of every other person of whom the plaintiff has has any interest in the property which may be affected by the Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 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: November 25, 2002 Udren, ESQ. f r Plaintiff ~",'4'r..- A ,"'~' ~ - ~^ -, ~' ~. "'~"'1.Y.'I""""'I>.'l'" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORP., NO 01-1251 Civil CIVIL ACTION - LAW MacARTHUR RIDGE 1I Plaintiff (s) From MICHAEL J. and E. JADE JANESKO, 3966 ENOLAROAD, NEWVILLE PA 17241. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 3966 ENOLA ROAD, NEWVILLE PA 17241 (SEE ATTACHED LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debtto or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $268,790.83 L.L. Interest FROM 6/6/01 TO 3/5/03 @ $41.72 per diem $26,617.36 Atty's Comm % Due Prothy $1.00 Atty Paid $1,267.12 Other Costs Plaintiff Paid Date: DECEMBER 3, 2002 CURTIS R. LONG (Seal) By: REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: 1040 N. KINGS HIGHWAY, SIDTE 500 CHERRY HILL NJ 08034 Attorney f9r: PLAINTIFF Telephone: (856) 482-6900 Supreme Court ill No. 47741 .~,. -~ . -" '. ~ ," " .'" '; , t" "~" .. " ..:ilI;>Mlloa,~,''''",''#i,",',,,,'' , . MARK J. UDRE~ & ASSOCIATES. BY: Mark J. Udren .' ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 , . ' "DefendanHs) : NO. 01-1251 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 thedate(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 s:i,gned 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". This Affidavit is made subject to t relating to unsworn falsification to set forth by Pa Rule C.P. All Notices were served within 3129. Pa.C.S. Section 4904 Dated: February 22, 2003 B Mark J. Udren, Esquire Attorney for Plaintiff ,"~,I A ,~".~ ~ '~ 1,1 '~.kJf."""",,:,.,~ 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISIO:N Cumberland County NO. 01-1251 civil Term v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) DATE: January 22, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): MICHAEL J. JANESKO & E. JADE JANESKO PROPERTY: 3966 Enola Road, Newville, PA 17241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County ,Sheriff's Sale on March 5, 2003, 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 "K o as,...::! "0'<> m- 0 iilo:2 ~ ~::: :=.5 0 e:; gf lI)E"Q. 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Gl~ :Ow e~ If! i li5~ !~'ii ~~ai.E8,! GlIlli,OOC/J , ~~E&l!:!= ~EG~,g~ iiS8~g'ii S'g"-;~a ].!!!.:C!o:ii ..l=.gglll~E :I,:g5~- Gl e-g8;~.5 J!!E:g"E~8 ~ go ~ II) & g!o~~~!: o15,:~mJ Hsp'" ';lIE~l!:! ~~~l~j .a,~ ~,g~~ .!~a."''ii 1-- ....::E '~ ~ -"",~,h,,", 1 ". ~ Q. Jj '" ,5 .~ ~ ~ - L\o ~cE= ~ " E ;; o 11. o m my y= .!!o 0._ _ 0 00 ~11. 1ltii E" ~ m Z> -.i Sg ~o:: ~ c .. l1. - C o l1. - .. III ... o ... .5 ... .. :t: ... ~ a. ~ ... ... '0 .. - .!!! a. E o U .. ... - .. '" :;; E ... ~ ... 0> 0> - ~ '" 2 .Q " ... ~ 0 , ... , "" " '" ;h 0:: >- 1l-" rn ~ , W 1-1 ' 'EE W - ... '" z <~ Z ~ ::;;:J ::;;O:J Z N 0< :Jzo <c 0 -, 0 0::0. U <cU ' e ~ 0 - N ::; - N '" ... It) '" ... '" 0> - - - o m y m _ 0:.... """ _ m ... ~~-g :!l M ... It):: ~c.. 'f"'" T"" ...... .....-' "CU)as "",'0 "" " ,,~ Q) E:gcn ~<Co ~'..J , ~' ~ .~~... '= . tt"!lii:l.illjflilE,h' " United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko, his wife In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 10:05 0' clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Michael Janesko, by making known unto E. Jade Janesko, wife of defendant, at 3966 Enola Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, beputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 10:05 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: E. Jade Janesko, by making known unto E. Jade Janesko, personally, at 3966 Enola Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2003 at 7:1.5 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above, entitled action, upon the property of Michael J. JaneskO and E. Jade Janesko located,at 3966 Enola Road, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Michael J. Janesko byregular mail to his last known address of3966 Enola Road, Newville, PA 17241. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being du1y sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice ofthe pendency of the action to one of the, within, named defendants, to wit: E. Jade J anesko by regular mail to her last known address of 3966 EnolaRoad, Newville, PA 17241. This letter was maiiedunder the date of January 13, 2003 and never ret~rned to the Sheriffs Office. This _ day of So Answers: ~ /~'~"'~-f~ ~ R. Thomas Kline, Sheriff Sworn and subscribed to before me 2003, A.D. Prothonotary mdGci~S JWU4J Real Estate eputy ,. r \ axHlBtTB I ..:J . :,-,-...,~ , '. '- ,-1_ , . ,I. 4rn""'~ ~. ~. . Y'""""",@,"", United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff s Costs: Docketing Poundage Surcharge Law Library Prothonotary Mileage Certified Mail Levy Posting Handbills Advertising Postpone Sale Law Journal Patriot News Share of Bills 30.00 270.00 30.00 1.00 13.80 3.10 15.00 15.00 15.00 20.00 446.75 375.25 25.21 $1260.11 paid by attorney 6/11/03 Sworn and subscribed to before me So Answers: This 1'16 daYOf~ ~~-..,,<~~ ~ R. Thomas Kline, Sheriff 2003, A.D. 'tk, 0. "'rH';&<-', ~~~~~ Prothonotary Real E e Deputy I . "" tA<- t.f J I 70 ~ /39/D.3 ~ " i!OOlili j~" . '" , ~. ,,',- " .Oil.~, .' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D. NO. 04302 I 1040 N.KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 l'i56-482-6,900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE !T'~/ Plaintiff, v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address Michael J.Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every lien on the real property to Name judgment creditor be sold: Address whose judgment is a record Greenwood Trust Co., Novus PO Box 25010,Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 - j,' ]~.is,' . , 4.' Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. united Credit Card Bank N.A. A National Bank 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and property: Name I 'I't. address of every other person who has any record lien on the ~, Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlise, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlise, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and knowledge who sale: Name address of every other person of whom the plaintiff has has any interest in the property which may be affected by the Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 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: November 25, 2002 Udren, ESQ. f r Plaintiff ~~ - e' ~,.,' ,'J. _ ~, .:;~l,!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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 COURT OF COMMON PLEAS, : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE '\'~/ Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . NO. 01-1251 civil Term Defendant(s) NOTI~E OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Eriola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on March 5, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'1'l 1'lALE To prevent this Sheriff I s Sale', you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and ~easonable attorney's fees. To find out how much you must pay, you may call: (SS6) 482-6900 ' 2. You may be able to stop the sale by filing a petition asking open the judgment, if the judgment was improperly entered. Court to postpone the sale for good cause. the Court to strike or You may also ask the 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) Jiii'iiil' k- ~ 1,,- " ~~ " ~. J,~ ." 'M'V __ 1, YOU MAY Sa'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. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, youwiil re~ain 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 REFEImAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DELICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800~990-9108 ~"......, d'~,~ L L...-J.~~,~ ,:,',,""~',' .;,:~"! #f . ~" . . ALL THAT CERTAIN PIECE OR PARCEL OF LAND,' SITUATE' IN UPPER FRANKFORD TOWNSHIP,' CUMBERLAND' COUNTY, PENNSYLVANIA,- MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON:, , , BEGINNING -AT AN IRON PIN AT CORNER OF 'LAND NOW OR FORMERLY OF, HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAYA. OlrnER(WHICH' IRON PIN 'IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA.,ROUTE 944); 'THENCE ALONG LAND NOW OR FORMERLY OF,RAY A. ORNER ANIl ,THROUGH 11.,10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 .MINUTES 09 SECONDS WEST S64.29 FEET TO AN IRON PIN; THENCE ALONG ,LANDS NOW OR FORMERLY OF RAY A.ORNER, NORTH 24 ,DEGREES ,45 MINUTES :,', 00 SECONDS WEST 1,993;20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423;THENCE' ALONG THE EDGE OF TOWNSHIP ROAD 'I'-42'3 ,NORTH.43 DEGREES 59 MINUTES 46 SECONDS WEST 32 _ 51 tEET' ".: . TO AN IR0N PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF ,LEROY H.RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. "1.1 RAUDlffiAUqH AND LANDS NOW ElR FORMERLY OF MARVINL. RUTH,' SOUTH 77 DEGRE~S O?MlNUTES 16 SECONDS EAST 1,824.37 FEET TO 'AN IRON PIN AT ,ANEXIST:j:NG POST; THENCE -STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; smiTH 61 DEGREES 16 MINUTES '02 SECONDS EAST 375.47 FEET TO AN IRON' PIN ,AT AN EXISTING POST; SOUTH .14 ,DEGREES 45 MINUTES 12 SECONDS ~T 99.32 FEET TO AN IRbNPIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324,.81, FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DE;GREES 16 MINUTES 37 SECONDS EAST '213.45 FEET'TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES IS MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOuTH 29 DEGREES'55 MINUTES 00 SECONDS ,EAST 511,50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY, OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E., HoovER ',AND LANDS NOW OR FORMERLY OF HAROLD T . SHOFFNER; SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER ,OF LANDS NOW OR FORMERLY OF HAROLD T _SHOFFNER, AND RAYA. ORNER, THE PLACE OF BEGINNING. , , , , CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF ~ D. BERT, R ~ S .; DATED FEBRUARY. 20, 1975. ' TOGETHER' WITH TilE ,RIGHT ,OF WAY . FROM. A 'PRIVATE. ROAD OR' LAND' EXTENDING FROM' SOUTHWESTERN CORNER OF SAID TRACT ,OF LAND OVER" ,TIm, OUGH 'AND, ACROSS THE, LANDS NOW OR FORMERLY OF PHOEBE A. ,'WARNER TO . HIGHWAY ROtJTE 'NO. 944 AND NOW AS A MEANS 'OF ACCESS TO AND FROM, TRACT OF LAND. , ' BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-q36 TITLE TO SAID PREMISEs,rs VESTED IN MICHAEL J. JANESKO BY DEED FROM .MA.URICEG. AND ELIZABETH B.: HILLIARD, HUSBAND AND WIFE, DATED ,2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. lH"~',tI.ol~,., " " '\ : ~;-^"~'-) " l__"~~L L . ~,--j ,,~~~' , ~.~-~" l;oilMJll"~.k-'-<Wl",,:,,l;m,;';' ,. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) 'COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORP., NO 01-1251 Civil CIVIL ACTION - LAW MacARTHUR RIDGE II Plaintiff (s) From MICHAELJ. and E. JADE JANESKO, 3966 ENOLAROAD, NEWVILLE PA 17241. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 3966 ENOLAROAD, NEWVILLE PA 17241 (SEE ATTACHED LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachmeut is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $268,790.83 L.L. Interest FROM 6/6/01 TO 3/5103 @$41.72 per diem $26,617.36 Atty's Comm % Due Prothy $1.00 Atty Paid $1,267.12 Other Costs Plaintiff Paid Date: DECEMBER 3, 2002 CURTIS R. LONG (Seal) REQUESTING PARTY: NameMARKJ. UDREN,ESQ. Address: 1040 N. KINGS IDGHWAY, SmTE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856) 482-6900 Supreme Court ill No. 47741 ;,."",j'i!"+,;""J;i!,-i:,~8"""",!h!J,".f."".cl-,*"J>~b>M,~m,~~'>~",,ilii"";,'1ciB.,,",''',B~k:lli!,~i\);Idi'o,",,~Mlk!!I_~~.u~~<~ Real Estate Sale # 43 On December 9,2002 the sherifflevied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, P A known and numbered as 3966 Enola Rd., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 9,2002 By:--.J tclzf kf ~ Real Estate Deputy ~ ~ ~ ~ , ~~, M1 " --! ,"".'. : ',,'- -.., :'::.~ -<-n ." ~~:--BEAl::I:~:n:~'-U:-::SA'LI:: -NO",-43- WrIt No. 2001.1251 , , Civil Term ~o=c-----unlt.d Companies "-, - 'Lending Corp. vs ~: :1Mlchael J. Janesko ~ -<and E. Jade Janesko ~=-:- ' ,Atty: !!Iar!r-J, Udren .---c '_- DESCRIPTION ~tHAT-CESTAL~,piece or, partel of land, ~ate' in trpifer- Frankford Township, ,CUmberland, County, Pennsylvania, more pJttiG:ulady_,bounded and described a5 follows, wgeiher with the improvements erected thereon: B1:GINNnm -at an iron pin at comer of land now --or foffiierly of Harold T. Shoffner and 13Jld now ~mnnerry of "Ray A. Orner (which iron pin i~ :Ncirth 22 degrees 49 minutes 38 seconds West -'381.57 feet from PA Route 944); thence along - JancLoQw or fonncrly of Ray A. Orner and _ 'fhroIfgn'il rU.5 foot dirt lane, North 22 degrees 32 minutes, 09. seconds West 864.29 feet to an iron pili; tlience along lands now or fonnerly of Ray A. Omer, North 24 degrees 45 minutes 00 -;$econds West 1,993.20 feet to an iron pin at an ~i5ting pool a.t \he edge of Township Road T- ,423; thence a1o~g the edge of Township Road T- -n, NorQt4~ degrees S9 minute~46 seconds. West ~:Z::.l~~t to an irclll pin at a tree and. comer of =----lant'tnow or fonneO' of LeRoy H. Raudabaugh, - lhence.-by lands now or fonnerl)' of LeRoy ft. Raudabaugh_and .lands now, or fonnerl)' of =M"afVin L. Ru~li, South 77 degree$ 07 minutes 16 ~ '-~lrds East ],824.37 feeJ to. an ,iron pin at an -- existing post; thence stllfb)> lands, of Mlll"Ilin L. Ruthlliefollowing courses and distances; South - 61 degrees 16 minlltes 02 seconds East 375,47 feet to an iron pin at an ell.isting post; South 14 degrees 45 minutes 12 second~ East 99.32 feet to ~ an Tron}lm at an existiqutOst; South 27 degrees - 46 minutes 01 secord East 324.81 feet to an iron pin at an exi~~).ost; SQu.tA JO dezrees 16 ~:tn1nutes37seeooosEast213.45feettoaniron prn at an ell.isting post; South 21 degrees 15 ~ liIin,utes 43 SCt.~nds East 320.30 feet to an iron .QiR; South 29 degrees 55 minutes DO seconds East.5J.l.50feet to an Iron pin at corner of lands now or fonnerly of Marvin 1. Ruth and lands of E<lg:ar:,E. Hoover; thence by lands now or rormeriY'orE<lgar E. Hoo~'er and lands now or fOIillerlyofHaroldT. Shoffner, Soulh 65 degrees -,---25 minutes 01 seconds West 1,705.08 feet to an jiQ.n pin at corner of lands now or fonnerly of ffifulrrSlWffner llIld Ray A. Orner, the place -ilf1\EGlNNlNG. ,_ CONTAINING 86.0677 acres and said lEci?ttOll being in a<:oordance with survey of CilrllJ, Bert, RS" dated February 20, ] 915, 'l'Q(jETHER with the right-of.way from a private wd_orland exte:lwng from Southwestern corner of said tract of !and 9ver, tlJrough and across the tJ.!1ds ,pow or fonnl;:'Jy of Phoebe A. Warner to flfghway Route No. 914 and now as a means of accesslO and from tract 'bf land. --:BEING KNOWN as 3966 &ola Road, Newville, --PA, ~'IJ11LTO SAID PREMISES ]S VESTED IN MicbaelJ.J~o by ,deed from Mauric~ G. anti ~ Sizabcth B. Hilliard, husband 3l1d wife~ dated 11 ~ r8iW9~ recorded 2118fl994 in Deed Book tOl ....:.P-age~~,__ _n' _ ~._ ~,_,'_ o~,~"'~,='-----_, -..., -~ I~ > ~,( , " "l "~, ,,~,.;~," ',~ ,"~" ""IIi} THE P A 'fRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market S1reet, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactiy as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of January and the 4th and 11th day(s} of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #43 NotilriaISeal Tarry L Russell, NotaIy Public Crty Of HarriSburg, Dauphin County My Commission Expires June 6, 2006 Member. Pennsylvania Associa1ion Of Notaries NOT R PUBLIC My commission expires June 6, 2006 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y 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 $ 373.20 1.75 375.25 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.................................................................... i~ ,"Ii i ~ I L ~ ." RNL JilSIJ'A<1'E SilLE NO. 43 Writ No. 2001-1251 CivU United Companies Lending Corporation vs. Michael J. Janesko and E. Jade Janesko Atly.: Mark J. Udren ALL THAT CERTAIN piece or par- cel of land-:t....s ~.ituate in Upper Frank- ford Town~p. Cwnberland Coun- ly. PetmSylVanla. more particularly boundedlltnd described as follows. together with the improvements erected thereon: BEGINNING at an iron pin at corner of land now or formerly of Harold T. Shoffner and lands now or formerly of Ray A Orner (which Iron pin is North 22 degrees 49 mln- utes 38 seconds West 881.57 feet from Pa. Route 944); thence along land now or formerly of Ray A. Orner and through a 10.5 foot dirt lane, North 22 degrees 32' niinutes 09 seconds West 864.29 feet to an iron pin; thence along lands now or for- merly of Ray A. Orner. North 24 degrees 45 minutes 00 seconds West 1. 993. 20 feet to an iron pin at an existing post at the edge of Town- ship Road T-423; thence along the edge of Township Road T-423. North 43 degrees 59 minutes 46 seconds West 32.51 feet to an iron pin at a tree and corner of lands now or for~ merly of Leroy H. Raudabaugh; thence by lands now or formerly of Leroy H. Raudabaugh and lands now or fonnerly of Marvin L. Ruth, South 77 degrees 07 minutes 16 seconds East 1.824.37 feet to an iron pin at an existing post; thence still by lands of Marvin L. Ruth the follow- ing courses and distances; South 61 degrees 16 minutes 02 seconds East 375:47 feet to an iron pin at an existing post: South 14 degrees 45 minutes 12 seconds East 99.32 feet to an iron pin at an existing post; South 27 degrees 46 minutes 01 second East 324.i.H feet to an iron pin at an existing post; South 10 degrees 16 minutes 37 seconds East 213.45 feet to an iron pin at an existing post; South 21 degrees 15 minutes 43 seconds East 320.30 feet to an iron pin; South 29 de- grees 55 minutes 00 seconds East 511.50 feet to an iron pin at corner of lands now or formerly of Marvin L. Ruth and lands of Edgar E, Hoo- ver; thence by la;n.ds noW or for- merly of Edgar E. Hoover and lands now or formerly of Harold T. Shoffner, South 65 degrees 25 min- utes 01 seconds West 1,705.08 feet to an iron pin at comer of lands now or formerly of Harold T. Shoffner and. Ray A. Orner. the place of be- ginning. CONTAINING 86.0677 acres and said description being in accordance with survey of Carl D. Bert. R.S.. dated February 20. 1975. TOGETHER with the right of way from a private road or land extend- ing from southwestern comer of said tract of land over, through and across the lands nOW or formerly of Phoebe A. Warner to Highway Route No. 944 and noW as a means of ac- cess to and from tract of land. BEING KNOWN AS 3966 ENOLA ROAD. NEWVILLE. PA. TAX lD NO. 43-04-0387-036. TITLE: TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD. HUS- BAND AND WIFE. DATED '},/18/ 1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE: 846. "'''','' ~jf'iliila't',(J:.. .. .;.~' ;__",1,...,."'... "~-' '~I <~ . ' " ,,,,-,,, '"'r,~~f.,.. ... - PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: JANUARY 31, FEBRUARY 7,14,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. WORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 duv , NOTAR , LOIS e. eNYDERl Nolal1, PubIlc c.">!ll1l1$ illl'ro, C!!fl1llilllMd County My ~ ElqllI83 March 5, 2005 ~"~=,.- '.- ~ it" ~ . ,~ . 'V" 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) " '.,~I, ,,~~" ...~,.~"--~'. l.''', .~ ,'~' > ";,";''';.i~",,Il#!L' i ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 Civil Term SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Michael J. Janesko & Ellen J. Janesko has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on August 31, 2001, Bankruptcy Case No. 01-04746. -;h Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ~ijjj~"""">l6",i;1,l;!!Ri1~,,",,",-,N"',;;W!""',",ii~~ilm~;j:;~~#ih~<\;&;,g,~li<I:'~;"'''~*Wl::JI'iiEj)'~ '"-'t"""" ," , ~< L ",' ',"--'. "~~ 'jjjlil~iilillIiiilrAlllif~,o>~_~~~~,J .v" -- ",-I I K'Ii 0 C;) C :5,~ CJ -ou! r, mlr c, z::c' , zr; (j)",,~' LJ: ;:S <- C -U :< ~C> '. ' "=0 i;~ ::::) FC :z; .....-: U1 5:) =< ~ -< - ~ ,~,=~'- ~~ i I -'"- o';t~;~,,: " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ~TTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 - NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road,Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address E. Jade Janesko, Mortgagor 3966 Enola Road,Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturdays Market 3751 E. HBG Pike, Middletown, PA 17057 Greenwood Trust Co. P.O. Box 25010, Newark, NJ 19726-0010 Novus Services Inc. P.O. Box 25010, Newark, NJ 19726-0010 Discover Card P.O. Box 25010, Newark, NJ 19726-0010 ~~~', "M,l ~ ,,,- I _~ , "" ~, , , ~' . ~, , r, ,. '.,,,,,... '~~l;;d~ ,. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. United Credit Card Bank, NA 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 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: August 7, 2003 ':t-.io!ti~~F~J;! 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ,- I I', .~~, - lif::.~'~~j\ ,''1 . ~, '" ATTORNEY FOR PLAINTIFF - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-1251 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $268.790.83 vi Interest From 6/6/01 to Date ot Sale December 10, 2003 Per diem @$42.42 (Costs to be added) 38.941. 56 $ MARK J. UDREN & ASSOCIATES "", . ~~I;;;~,'""'ill~'~""lgl";\",;,,,;t~,'~,,t1t&"'i1:HlttT.\''-'''''''''''''~'i!""""",':,",i","~,:}",J"-"ho.c,",~"";:'oili~,^"'-"~~~~~~~:.MO!JL'<iI[~~'\lI<~b~-iil;M!~<l~d' "'t~' ,. '0 7'\J ~ r ~~ ~ - - " 6"- ~~ ~ T- t ~ (::\ ~lf; , I , $l..., i<.)oJ \ - --. .~ ~ ~-- ?~ ~ "- \)-" C<l _ ~I ...... - CJ., _I' ~ ~'<?1,.D E)' ~ ~ ~ ~ ,-~,~,~ I 'fQ. ~ .......r\ c..l\ ."1 ~ '~B f! -F OC~ ;:::; 0 _ '-_ -1-1 <..-,.. ~n -CJ tf ;t1 qJ'C; ~"O ?-'" zr Ci?~:, .-<'; r:: ~~ $~-' ~~ ~ -'~ N o "~:e '\ 3-J;" ~:;(~J -,.--' '-;-, :, -n e,J/-=s 8rn s1 j:J -< "'""-:;; ~~,.;,. '-"='-'=~'~' _.~~- .-1',- , ~' ~ , "'....,...."~'''S'''"''''-''"''''''.' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . - NO. 01-1251 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES i:Z~' - h.<_' i-,,~~L ,,~ ,~ ""'n''-''~ "~'::il~%" ~ ~ 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 United companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Michael J. Janesko 3966 Enola Road,Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address E. Jade Janesko, Mortgagor 3966 Enola Road,Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturdays Market 3751 E. HBG Pike, Middletown, PA 17057 Greenwood Trust Co. P.O. Box 25010, Newark, NJ 19726-0010 Novus Services Inc. P.O. Box 25010, Newark, NJ 19726-0010 Discover ca.rd P.O. Box 25010, Newark, NJ 19726-0010 ~~~,. , , -," - 1';'"""""1"",'.".;. . 4. Name and address of the last recorded holder of every mortgage of record: Name Address \ Plaintiff herein. See Caption above. United Credit Card Bank, NA 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the properCY and whose interest m~y be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 CommonwealCh of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 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: August 7, 2003 !cid;~;J;'--_Ji:;!J\!ilI~ti:<;;-," ,i,.,fK';'\Jjl<jit~~d!i';,""'~'dilii&j>;,r,i~""-hr:"-J ",jiUj','-, "^... ~, --. ~, . ~ ." "'.~, '~'- \;'d'"'.,',i~',;,,'~I,~,->1,."'."-'.i.1~i<!'iNI',,~!li)--,,~~~~r&ifu!1'!liiif;,jIo'...~~iihiii.1.>l...olih~i!t;llll!l~~~" -..~ "" . . ( 0 c:) ,; ~r, '" -Lf) -0 r ;-11 --r; rn C;- "'-;:] "r ;::.--: z l- e/J (;:::) ) , -< t': ~: j Sd r..:: ~- :--~" ,{- -~,j '"- ( ',"3(:; z -"'" to":: )> (~: ('~5rn 2:: c-l ::::> l~" -~ :TI -( Iv -< - ":: ,;= b '.... _. ~~."'-. "~~ , """", J__~ ~,<:.:.r . ~ ~ ~ '-"""""!'<""-"lti',"W"","",." 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABT,R TO PREVRNT THTS SHERIFF'S SAT,R To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) I'~ ~ ~. ,. , J'", .=~ '"", "'!<&'~"~"-,""I':' . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUll. 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 ~'Iiht~i~litl)h:&~',*;.k 1'-,-p_"ji,':'!",-ili:\r.;0ji!~"f-;j{;;:J:;'~;-"'!~l::r;''''-'''~t,,,,,,, " ;t,h'^,1iili"'"j',"~,~i!~,0.".",<*,~,~~:~",,,.,;J;.<:,!IEi~.~1tiru~~,lIoWm;;;ts~~~~....l\;Ii;i,[iriil\l!!l~;!~"~1l@~~-~ ',", (") 0 0 C (.;,,; ,] ~~ [f) ""tJ-fr; '-" rnfT: ''0 " Z-y-; P Z . .c,; ", (0 " <:::) (~' -< (:) (;::: L ~ ~: :.B / c. ~ '--I Z. ,- C) ::c; " t~m C ;_-1 Z ~ :::> :);l.; :0 ~,,'" f'0 -< l!! ,r-..J, ,"- ,~' ~ " '''''~''''A'' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-1251 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORPORATION, Plaintiff (s) From MICIlAEL J. JANESKO AND E. JADE JANESKO (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee( s) that: ( a) an attachment has been issued; (b) the garnishee( s) is enj oined from paying any debt to or for the accoWlt of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is fOWld in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $268,790.83 LL Interest FROM 6/6/01 TO DATE OF SALE 12/10/03 - PER DIEM @$42.42 - $38,941.56 Atty's Comm % Due Prothy $1.00 Atty Paid $2542.23 Other Costs Plaintiff Paid Date: SEPTEMBER 10, 2003 CURTIS R. LONG (Seal) Proth02 ~ Bv: Q~ . .2. 7?zrA....~J'.r Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS IDGHWAY, SIDTE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 , .~. '~ . t - " United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko ,.J In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251Civil Term ';,,,--,,,,",\, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff's Costs: Docketing Poundage Advertising Mileage Levy Surcharge Prothonotary Share of Bills 30.00 479.74 15.00 6.21 15.00 30.00 1.00 28.90 $ 605.85 paid by attorney 10/10/03 Sworn and subscribed to before me so~ ,... n" ,~--,:>. :~~A This~dayof LYe...~ . ~ C) - R. Thomas Kline, Sheriff 2003, A.D. '(" (1 ~,'tlpr ,j BYV Prothonotary Real Es T /triJ Ck 'I.) '-(<is ~ /lJ3~(...Y ;""~ ' >'f~~ ~ ~. ~ =,~ "'"'> "<: f' 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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $268,790.83, 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 MAYBE ABLE TO PREVENT THI S SHERIFF'S SAIJE To prevent this Sheriff1s Sale, you must take 1mmed1ate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. mortgagee the back payment, late To find out how much you must pay, 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) lU'J ,~ . ~ ~ i. '.~M.' ":t&:_';;',i' j' YOU MAY STILL BE ABLE TO SAVE YOUR PRO?ERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled, to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER 1'0 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 ,'u ._~J _I.o~'~,_ ""' ,;... <" k~~ '~~ ~" ~'--<\ililmi1"",'!m;!.4i,^ '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 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 . . NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the proper~y will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ARI,E TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s Sale, you must take immediate action! 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856)-482-6900 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. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ',:",,~ " ~ ~ ~ .......' ~ ....", ~ """",_I.~",,,,.,,,, -'001~~,*"'< , YOU MAY STLLL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THR SHERIFF'S SALE DOES TAKE P~CE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. YOU may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find 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 ~he 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 YOUl!. 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 ~~ , -"" ", ',", v ~~ ~ __,~ '1>liL TEA:J:' Cllll.:J:'Am PJ:BCB Oll. PAll.CEL OJ' LlUlD, S:t'1"l1A'rB: Dl tIPPER l!'RAND'ORDTOWlI'SHJ:P, , ~ COllH'n', PBNKSnV1olttA, XOll.B PAll.'l'J:CULARLY B01Jl.mED Al'Il) llBSCll.J:BED AS FOLLOWS, :J:'OGE'l'HBll. WJ:'l'EI mE DlPll.ovm!:El<ITS Bll.BC:J:'ED THEll.EoN: . ' BEGJ:ll1IDl'G A:J:' AN nON PDl.Ar CORNEll. OJ' LlUlD NOW Oll. ,J'OIlHERLY ,OJ' HAll.OLD T. SHOl!'l!'llD: Al'Il) LANll NOW Oll. FOll.HBRLY OJ' ll.AY A. 0RNEll. 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HILLIARD, ,HUSBAND AND WIFE DATED 2/18/94 RECORDED 2/18/94 BOOK 101 PAGE 846. 00...:_1 I ~ ,I. .~, ,J ' .~ ,c , ~ ,j~ ". \,~,' 1; WRIT OF EXECUTION andlor ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1251 Civil CIVIL ACTION - LAW " \, l, TO THE SHERIFF OF CUMBERLAND COUNTY; To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORPORATION, Plaintiff (s) From MICHAEL J. JANESKO AND E. JADE JANESKO (I ) You are directed to levy upon the property of the ,defendant (s land to sell SEE LEGAL DESCRIPTION. '\ ~;~ l (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enj oined as above stated. Amount Due $268,790.83 L.L. Interest FROM 6/6/01 TO DATE OF SALE 12110/03 - PER DIEM @$42.42 - $38,941.56 Atty's Comm % Due Prothy $1.00 Atty Paid $2542.23 Other Costs Plaintiff Paid Date: SEPTEMBER 10, 2003 CURTIS R. LONG (Seal) Prothonotary <5,y: ~~ tJ . e. ~AAi''l.o ,-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS mGHW AY, SmTE 500 CHERRY mLL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ill No. 04302 I " , . ",'~"",,--,,,,,,",,~, {it,'"-4,,,,"~#I'iJ;,lj.ji<id:;(~!"Ji>,~h""bi~",;"'{.be~.j,!,",,;&\i,,:~...-'i;iiiib:ii!i'M'l~!,~~.~--';'fuA_;ctj;-o.Jl~'iiiAr~~"I.l;t~IR[;A"'(,iMk",'~U,b~C'~~-~~-~~_.l1J If ,j r "if '~l ii, , -~r ~! :'+' ,f ,Ii' Real Estate Sale # 67 On September 15,2003 the sherifflevied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, P A Known and numbered as 3966 Eno1a Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 15,2003 By: JH 1:1I1A~ +1/"1 Real E;tM; D;~~ {"=j LVi] c::u:u = ZW IM:i;J VI1fOlAStHI.3d ~l --I :-" . i ,.' ( bO, Hd st E I' d3S AJ.Nn0() :J" ,'-~;.':J'3rinO ~~11l3HS 3"" ,,0 3:J1.::l30 ~LX '~,'" ,^,",'.. ,"_H~' ~,._,~-'~_ .,","~,~. ^.~.,,~~,~.'~,n, ~__,~~~. I, ~ ""--~~ ~ ~"- . ~ ~~~'" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF United Companies Lending Corporation Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Michael J. Janesko E. Jade Janesko', Mortgagor Defendant . NO. 01-1251 civil Term PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. ~ Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff DATED: October 12. 2004 ,~;;~" ~"""'~~~jgj~~';ffi;~...~t',m>;;",jo:;i-",Mlf.~l'il.i1-,,~'€.~,"-..~,::~~iB~~ll!ilIlI ~ ",-,' ,,^e> "- ." .~ , ~. ~., ^ "f . 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