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Home My WebLink About01-1383 FX ~ -~ "~~. . -!;l,.i"'~~~ - -",; ~ ..~ " , 1n__ ~~-"--- , MARK J. UDREN & ASSOCIATES BY: . Mark J. Udren, Esquire ATT~ I.D. NO. 04302 1040 N. KINSS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856~482-6900 ATTORNEY FOR PLAINTIFF u.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, .FL 32256 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Donald H. Bauer, Jr. Francisca Morillo Bauer 335 North Middlesex Road Carlisle, PA 17013 Defendant(s) : NO. tJ/- /3<60 ~~ 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 GO the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A";l' ONCE. IF YOU DO NOT HAVE A.LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 _ d~~u ~-~~_ ~_ _ L - I~ "~ :iJVUt__mlCjf,-, 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 demanday la notificacion. Hace falta ascentar una comparencia escrita oen persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de estademanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFIClNA CUYA DlRECCION 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 - -'", ., -~, . ~."~-(,, NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt 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 Bot 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 HilI, NJ 08034 (856) 482-6900 ~"_"~.~~,o ~..- ~~j ~ '~ J . Jc""'-'""tj-,.";.J ." 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Assignee: Recording EquiCredit Corporation of PA U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) Date: LODGED FOR RECORDING Book: Page: 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff aG 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: 335 North MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 10/27/98 DATE RECORDED: 11/5/98 BOOK: 1495 Middlesex Road Middlesex Township PAGE: 573 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 ~,.,~"- -~" ~., ~ - .",,~-, ~ " ,.1 ,"~. "- -' - ~, " ~~k"',,_ 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 3/1/01: Principal of debt due and unpaid Interest at 9.15% from 7/1/00 to 3/1/01 (the per diem interest accruing on this debt is $58.07 and that sum should be added each day after 3/1/01) $231,652.70 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 14,169.08 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 3/1/01) 0.00 Late Charges (monthly late charge of $95.30 should be added on the fifteenth of each month after 3/1/01) 857.70 Attorneys Fees (anticipated and actual to 5% of principal) 11,582.64 TOTAL $258,792.12 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the "'=, .oI."'~' ~ ,",'~ - . - .,,1. .. ~'",-- " " ^ MIJ~""~,.- mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $258,792.12 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. fil Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ra._~,,, I ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD, SAID IRON PIN BEING ON THE DIVIDING LINE BETWEEN LOTS NOS. 6D AND 7D; THENCE ALONG SAID DIVIDING LINE NORTH 68 DEGREES 12 MINUTES 30 SECONDS EAST, 425.00 FEET TO AN IRON PIN; THENCE SOUTH 21 DEGREES 47 MINUTES 30 SECONDS EAST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 7D AND8D. ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE SOUTH 68 DEGREES 12 MINUTES 30 SECONDS WEST, 425.00 FEET TO AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD; THENCE ALONG THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD NORTH 21 DEGREES 47 MINUTES 30 SECONDS WEST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 60 AND 70 ON SAID PLAN, THE PLACE OF BEGINNING. BEING LOT NO. 70 ON THE PRELIMINARY AND FINAL SUBDIVISION PLAN OF JOHN M. AND JANET D. KNAUB, RECORDED IN PLAN. BOOK 45, PAGE 146. T~,," ,C """'~I&"-_ - ," .~ ~ '^'i;~J:, DATE: January 16, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information ahout the nature ofthe default is provided hi the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (lIEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CRED{T COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agem:y. The name, address and phone number of'Consnmer Credit Counseling Agencies serving your County are listed at the end ofthis Notice. If you have any questions, YOII may call tbe Pennsylvania Housing Finance Agent:)' toll free at 1-800-342-2397. (persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Coun~eling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. . LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFlCACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGEl'!/CIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGmLE' PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 10f6 r=':-f;.'~ lc_. . ~--"lT A __ ~J "" -~ ~- " - ~~- , I.... . <-. .' j~l!lJ.""'ill'k';,- HOMEOWNER'S NAME(S): DONAI.D R. BAITRR, .m FRANc.TSCA MORll,I,ORAITRR 335 N. MIDDl ,RSRX ROAD C;\.RT.lSLR, PA 17013 8064029609 EQUlCRRDlT CORPORATION OF PA 11S RANK NAT'L ASSOCIATION:, f(k/. FIRST BANK NAT'{, ASSOCATION:, TR U1A DATED 03/01/99 (F.QCC ROMRRQJJlTV I,OAN TRIIST 1999..1) HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: YOU MAY BE ELIGmLKFOR FINANCIAl, ASSISTANCE WHICH CAN SA VR YOUR HOME FROM FORECI,OSUlJE AND HF.LP YOU MAKRFIJTTIRE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EME~GENCY M:ORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGffiLE FOR EM:ERGENCY MORTGAGE ASSISTANCE: . . IF YOUR DEFAULT HAS BEEN CAUSED BY cmCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF,MPORARY ST A Y OF FORECI,OSIJR'E - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time . you must arrange and attend a "face-to-face" meeting with one of the consumer credit cOUIl(leling agencies listed at the end of this Notice. TIDS MEETING MUST OCCIJR WITllIN THE NEXT (3Q) DAYS. IF YOU DO NOT APPLY FOR EMRRGENCYMORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TInS NOTICE . CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS llOWTO BRING YOUR MORTGAGE lIP TO DATE CONSUMER CREDIT COUNSEI,ING A~ENCmS - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, 811clresses and telc:phone numhers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgllge isin default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR M:ORTGAGE ASSISTANCE WILL BE DENIED. Page 2 of6 ---";,- ~- ""~,=,.,~",,"" ..~. J__ , .~ ~-4;dJi"-*,,,' 'AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TillS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fdedbankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAIJL T (Bring it up to date). NATIJRE OF THF, DEF AlJT,T - The MORTGAGE debt held by the above lender on your property located at: 335 N. Middlesex Road Carlisle, FA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HA VB NOT MADE MONTIIL Y MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $1 ,906.09 for August, 2000 through .Ianaury, 2001 '= $11,436.54 Monthly I,ate Charge of $95.30 for August, 2000 through .Ialluary, 2001 = $762.40 Other charges (explain/itemize): Escrow Advauce =$7,078.00 TOTAL AMOUNT PAST DUE: $19,276.94 B. YOU HA VB FAILED TO TAKE TIlE FOLLOWING ACTION (Do not use ifnot applicable): N/A HOW TO CIJRE THE DEFAUT,T- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PA.YINGTHE TOTAL AMOUNT PAST DUE TO THE LENDER, WIDCHIS $19,276.94, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WIDCH BECOME DUE DURING THE 1HIRTY (30) DAY PERIOD. PaymP.nts m1L~t he mAne-either by cac;h, CR!ilhiP.r'~ r:her.k, r.ertified check nr mon~ m-ner mAne payahle and !;ent to. Mark .1. Udren '& Associates 1040 N. King.. Highway, Sujte 500 Cherry Rill, N.J 08034 You can cure ~y other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use Ifnot applicable.) N/A IF YOU DO NOT CIJRE THE DEF AUT .T -- If you do not cure. the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortg,8,ge deht. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due .is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose npon your mortgaged property. Page 3 of6 ~. ~'. i'-~~'''''>'~''',,,,,,,,,,-OJ''~",''~' _~1 ~ -~ - ~~ '"'" ~-~~',;<,,,: 'IF TlTF. MORTGAGE IS FORECI.OSED IIPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Uyou cure the default within the THIRTY Po) DAY period, you will not be required to pay attorney's fees. OTHER I,ENDER REMEDIES The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. . RIGHT TO CURE TlTF. DEF Am.T PRIOR TO SHERIFF'S SAI.E - If you have not cured the default within the TIIIRTY (30) DAY period and foreclosure proceedings have begun, you .till have the right to cure the default ami prevent the sale at any time up to one hour hefore the Sheriff'. Sale You ml\Y do .0 hy ~yinf the tot;)] amount then pa~t nm:'!, ptlL~ any tate or othP.T' cha.t::ge.~ then nnf\ 1"P.~!::!nnahle attnmey'& fp.p.~ ann co.t. connected with the foreclo~ure .aleann any other cost. connected with the Sheriff'. Sale a. !\pecified in writing hy the ]""deT ann hy performing any. other requirement. UnneT the mortgage. Curing your default in the maBner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSffil.E SHERIFF'S SAI,E DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE I.ENDER: Phone Number: Fax Number: Contact Person: EquiCredit Corporation of America 10401 Deerwood Park Bnulevard Me m..9-lI15-02-14 . .Iacksonville,FI. 32256 8001759-6380 904/457-4082 Jennifer House, En. 75968 Name ofl.enderIServicer: Address: EFFECT OF SHF.RIFF'S SAI.E - You should realize that a Sheriff's Sale will. end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSIJMPTION OF MORTGAGE - You _ mayor X may Bot (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and .costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of6 J...",,~"~, ~_~ ~ ~ ".j - - --~~ ~ .~~, ,,~, 'Ilikit), 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 informatiou, 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 collectadebt, and llI)Y informlltion obtained will be used for that purpose. LAW OFFICES OF MARKJ. UDREN Isl Mark J. Udren, Esquire 1040N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 Page 5 of6 ~:r" ' ~ ,,~ '-,.~-1:.1~- ". .~~ . "~^ .!~~~;"'''-- YOU MAY AI,SO HAVE THE RIGHT: . TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TInS DEBT. . TO HAVE TInS DEFAULT CURED BY ANY TIIIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE TIlE MORTGAGE RESTORED TO TIlE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE TIlE DEFAULT. (HOWEVER. YOU DO NOT HAVE TInS RIGHT TO CURE YOUR DEFAULT MORE TIIAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT TIlE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTIlER LA WSillT INSTITUTED UNDER TIlE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE LENDER. . TO SEEK PROTECTION UNDER TIlE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSEUNG AGENCIES SERVING YOUR COIJNTY (Fill in ali.t tif all Coun..eling Agencie.. Ii..ted in Appendix 4 FOR THE COUNTY in which the property i. located, u..;ng additiona(p4/te.. if np.ce....a,.y) CIlMRF.RLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Lingiestown Road Harrisburg, P A 171 02 (717) 541-1757 FAX (717) 541-4670 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 . Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-'l757 FAX (717) 234-2227 Urban Leagne of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Adams County Housing Anthority 139-143 Carlisle St. Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of6 j I ",'--"'i"~~~~s;i.._,<;>,d;sE.,,,'j-'S.h";~"J".ij:>,.;--,;;i<'-'Z.<~=--...r.;:-" LAW Oi'FICES MARKJ. UDREN & !lSSaCIATES 1040 N,KINGS HIGHWAY SUITE 500 CHERRY HilL, NJ 08034 *:.~ot5(j~ .. t." , i,:t:':,~~~~~,::; . :": ,:"," ::~~i~Tiii~fj :Jvfjkio~: :~:.:~: ~:;. .,', ,.""_o-;,=-~~~~_"_",,_,"~,,_,,,-~_, =~'-''':'''~''''''~''"--'' ~ln;1I @~:';,xi;c.1f:'~:~:~'~ """, .i:"{)../" . :.}.:.~ i_._.~u._,_ .,...._....,..-.lE 70no 1670 0010 9742 6789 -=t-^~ VY\~~ 35,=> f\.. Y)\ ~~ PO . C~ ~^ J1-C\~ '". '. .... '''','-.-'.:-.^",,~.. . ~',"'_ :'''-''''pk"=",,,,",.~~~;r_~ ___' ',.-., :;:~''-' ". .,.'tc:/.,:;~, rr '", 'I'- ...II U.S. Postal Service ' -CERTIFIED MAil RECEIPT (Domestic, Mat! Only; No {nsurance Coverage Provided} ru =r I'- 'rr C " r'I C C Certified Fee Return Receipt Fee (Endor~ment Required) Restricted Delivery Fee (Endorsement Required) Postmark Here 'C I"- Total Postage & Fees ...II r'I C 'c :C :1'- ~ !" , I DOH p )( P ?', i,; ~,;' '-I' _ '" m "'IE '" 11 c - , (, i. it!f ~f "r ~ " ~ t .. l' .. 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" I ~:. ~ ',','." . ......I'. !,{t~~l '.)r~.;'" -' . y., -'.. . .~ ....... .,;""?- . :j.; ~... /~:... ,I t,-t.' ~C.). :: ". :~~;;./...)' .....-"'.;...:;." .' L~' ,f:;:" ~1~ttf ~~~. g,~: 5: ~ ~"~,", '~~~ "--,',, ....;. ~I'" , ' LF" ;,,"C;, JO'" /1'1 ../'''. i ; .,i 'g ~p ;'j~ ."...... ,'1;: - ;;:-' ~ ,- ~' c .' ~ .. !": ~. 0 .. ~;- ~:~~~:I~, oi ~ . :' , (0' :'-:i _n E .~! " _~ i; ~~ ~-' ~': ,-,- , " -. ," ~: ",: [" i . I I \. " I' . :\<"':'.,. .,:,~b::' .: ~,--",,'. '..,. -,' "," '0 1\ t . f to ~ , ( \ I ',d .1 ,i I ~ ~ ~ o Of.' {-J.,. ... ...i..., or (t :rill >:g ~"'R: ll- g s:ah) U" ~.' f' s:11!1"'.."ll.....:...':... . .. .." l! ..!IL. ;:; . ifWiii;; :Ilii'. " l!. a~BU ':5o..i. 1r ~ 6 ~ ;1;': :> J.- Pl"3"- ",' -" ..iii [f- ...... 'li 0'.:"- ~..' 3 ~ ~ ::;, iii'!l.tiii~!, S:6" l:g..'....' ;~ S:gi ~F CD. '~:: "ll. ~ -g, ~ iil f\; "".1 -~ ~ - oJ . f' '" " DO p )( p I i ,n' ::;(jf rn ~ ut~ H: I ~j' ! I!!. ;:. ~ I!l. iil . - !!l. ~i i ~"' fa. l ~ i! ~r h ~~ -a- ~ ~ if - 0 .... ;: t . DODD n ~ ~tU ~ a. 11! il ~."'''- ~ '-~~.li/;\1,""""-1j-.,,, , 1 ! \ J' ~,.. . f \ .' ,~"""~" -......j,---~- , .ili''; "' ~,>- ~- -~~ U~*"_"" .. V F. R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Maj1j. Ud=n, ESQUIRll MARK J. UDREN & ASSOCIATES "" ' " ~_U~-il!i~f;:"!\~~',nr~:;:",~""t~i'>l!;b_;g,'fu~crlk~j!I~.*MlT~""",!'~,,,,"iah_'""G,~",_,;~"'l,!"";~";i1"!~;'$,_""t~~."", M ~-"'...""".= - . III <'V-,',,~' ~~...- " ((j) >:, ~ ~ ?D (:) ~ \~ (') '- c J $:. ::l!: .--1 -oeD , :1'" h;-.;.:D ~ OJ fl11-Tl 7J 'r-' .......... Z::tJ I "m ZC' ""'0 -So, uJ ." x: c " (fJ~: ..-} LN -< -. ~:::.l....) "'0 ~ c.: CJ 1:> x:tt {"'-., u... ~o -- ~~f5 ~l ~ \..JV \...N ~t' -0 ~ Om 0:' >c ~ Z ;:- -j ,) ~ -<. (::::> 0< I:::J ~ ,!,,!, n " . ~.~~ ~ ' . 0 ~~_. -' '"""~ A"",h"jui>",,',,",' \" SHERIFF'S RETURN - REGULAR ~ CASE NO: 2001-01383 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCAITION VS BAUER DONALD H JR ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAUER DONALD H JR the DEFENDANT , at 0019:55 HOURS, on the 13th day of March 2001 at 319 ACRE DRIVE CARLISLE, PA 17013 by handing to FRANCISCA BAUER 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 18.00 3.10 .00 10.00 .00 31.10 so;:~~~ R. Thomas Kline 03/14/2001 MARK J. UDREN Sworn and Subscribed to before By: me this .t.~,e:: day of ~~ A.D. ~, fl'Jt,.#i,," ~ othonotary . j"" , """"",._k "~- .... .. I" ~~~, -- ",.",,-.',...,,,,,,--,,,;,C . . . CASE NO: 2001-01383 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCAITION VS BAUER DONALD H JR ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAUER FRANCISCA MORILLO the DEFENDANT , at 0019:55 HOURS, on the 13th day of March 2001 at 319 ACRE DRIVE CARLISLE, PA 17013 by handing to FRANCISCA BAUER 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 So Answers: 6.00 .00 .00 10.00 .00 16.00 r~~~~~~ R. Thomas Kline 03/14/2001 MARK J. UDREN & ASSOCIATES '10""":. me this -<.4_ day of Sworn and Subscribed to before By: ~ ~J A.D. q , 1. a 711./Iltf;, J ~ p~othonotary I 9 .- --' > .- - , " MARK J. UDREN & ASSOCIATES ,~Y: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ~1M'iJ ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : .MORTGAGE FORECLOSURE v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) : NO. 01-1383 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 per Complaint From 3/2/01 to 6/4/01 Late charges per Complaint From 3/15/01 to 6/4/01 Escrow payment per Complaint From N/A to N/A $258,792.12 5,516.65 285.90 o 00 TOTAL $264.594 67 I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, a copy of addresses of the Plaintiff and that noti has been given in ich is a ached hereto. Udren, ESQUIRE ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED ~1/J.i.4 PRO PROTHY r< /0 DATE: L~ il.~()1 ~ ~~~N~fli!!lI,wiEt<!'"f.~dA:6'<\iIi"M'k~;4ij;;~;~..r.:w,;.',i;t',j,;;",,~'D-,%'I:'f,,~..;;Njt%ulci,-,,~~:i!;&,,*"~''''''~'"'"'''''''''''''''-'lf!(Jijij~rr'- 0< ill( ~, Il. rr---' , (") c:> c (.J .s:: " "Om r..... ..~! mHr c::: Z=r~ ;;::: f'h :T_} z~ r--. ciJ2> 1\0 ,::rn -<:"" :_:"];::1 f-:'~-- ~~~~; ;0:::0 :D. P 20 ::J::~ 5>0 \.J-----' - ---:.:~() c:: - c5rn :z -I ::! N :D. 0 :n -< _._n I I "-"'-; ~~~ . ~-, -" ""lI;l'!i~,'!fb," MARX J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. XINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 u.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) NO. 01~1383 civil AprilS, 2001 Donald ,H. Bauer, Jr. 319 Acre Drive Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. -UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE DATED: TO: 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 (J,O) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE . Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 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. =,,~--,~ I" d:~'iIi.\i\~;-i;' MAR~ J. UOREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856~482-6900 U.S. Bank National Association f/k/a First Bank National Association, TR ViA dated as of 3/1/99 (EQCC Home Equ~ty Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant{s) NO. 01-1383 civil AprilS, 2001 Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 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 DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN ~ERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION, SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "-= " ~ ., , , '- ' ~~'~;,o" 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 U.S. Bank National Association f/k/a First Bank National Association, TR utA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE : NO. 0\- \3"6?:> v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey COUNTY OF Camden 88 THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Donald H. Bauer, Jr. Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Francisca Morillo Bauer Over 18 As captioned above Unknown Name: Title Compa Mar J. Udren, Esquire Attorney for Plaintiff y: Mark J. Udren & Associates JAcQueUt4tA, ClItESS A Notary Public 01 New lelSey My ComllllSSien Expires 4/112003 - '" I '~ '"< ~ = H ~. _ I , C >.~~.: ~. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) l0401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) TO: DONALD H. BAUER, JR. 319 Acre Drive Carlisle, PA l7013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J Odren. Esquire At this telephone number: 856-482-6900 ..~ .~ - - , J'~ -, "--" -~__.'~~d .. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. N9. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National . Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) : NO. 01-1383 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 per Complaint From 3/2/01 to 6/4/01 Late charges per Complaint From 3/15/01 to 6/4/01 Escrow payment per Complaint From N/A to N/A $258,792.12 5,516.65 285.90 0.00 TOTAL $264.594 67 DAMAGES ARE HEREBY ASSESSED AS ,- (')..0 I addresGes of the Plaintiff and that noti has been given in ich is a ached hereto. I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, a copy of Udren, ESQUIRE ey for Plaintiff J;ND~TED .' C~ALv<l PRO PROTHY f(~~ DATE: ~~~ ~- . ,......, ,-' ~~ "" c~,~~ - <'~'2 ~' "" . . 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 u.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home. Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) TO: FRANCISCA MORILLO BAUER 319 Acre Drive Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicateq 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. Esquire At this telephone number: 8'16-482-6900 "'~~~ . " 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 .~-- i>l.i..~ ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 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 per Complaint From 3/2/0l to 6/4/01 Late charges per Complaint From 3/15/01 to 6/4/01 Escrow payment per Complaint From N/A to N/A $258,792.12 5,516.65 285.90 0.00 TOTAL $264.594 67 I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, a copy of addresses of the Plaintiff and that noti has been given in ich is a ached hereto. . Udren, ESQUIRE ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED ~ PRO PROTHY R~ DATE: {o -/2- -0\ ~ ....."xlf"'-,.,..iliiOilr lJ:A:Iili~~allll""" ~ii;OO~~ _ M~I.Millif:jh~:!diml!"i:i~~!i;:li!'~4i<i'~l.;i",,,,,-''''~l!'i'~'''''''ST'''''i,"Ji,~c","*,_i"'''~ ~Ji ~ ~ ~~~ ,Jl -~~ ~ ~\) ~ ;; ;:!) '\ "" .--...... [, ~ r- L J~ J-'- r ~ ?D n" o C <,:~ I~ <:G :;00- 7,,-J =0 >c ~ 11r" ~- ., . J C::Jo c_ ..~,.. ",,-- p...;' '".liT 21~~ Or"--l --1 ~ --.\) :f r '" ~ --\. \'-" 6- ...... :~ ~"", ~_;r." I" o >. --"~ - ~< - ..... ~"< , ~ . . ". '=~"-",-",,, '.! " . . MARK J. ULREN & 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 U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) : NO. 01-1383 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $264.594 67 Interest From June 5. 2001 to Date of Sale Septp-mber 5. 2001 Per diem @$58.07 5.342.44 (Costs to be added) $ Mar J. ATT RNEY - .."~" "-"""-" . ~ ~' "1iI .,J. " - ~~ "",,0 . n!<." ~, ~~;!,!L f' oil . 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 U.S. Bank National Association f/k/a First Bank National Association, TR U/A dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 Defendant(s) : NO. 01-1383 WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTYo To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the foliowing described property: 335 North Middlesex Road, Carlisle, PA 17013 SEE LEGAL DESCRIPTION ATTACHED ,Amount due $264.594 67 Interest From .June 5. 200] to Date of Sale September 5. 2001 Per diem @$5B.07 5.342 44 (Costs to be added) $ I'rothonotary By Clerk 'Date M~_IrJ~!)"..j"'Hi}h,,,,,~,,j@;;,(1,,~~~:i~rk~';:,j;l""'i,'&-h;--,,,;~'~k.,,,-,,WiliU''''d/,,,j''~',dW4li',.,,~~~'''' j;,' - '~";d"1ii;j; ,,~-~-' -...." "~-. II ~ --~ lIB'@' . , COURT OF COMMON PLEAS TERM 19 NO. 01-1383 ===================================== U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) vs. Donald H. Bauer, Jr. Francisca Morillo Bauer ===================================== WRIT OF EXECUTION ------------------------------------- ------------------------------------- REAL DEBT $ 264.594 67 INTEREST $ from JUnB 5. 2001 to Date of Sale September Per diem @$58.07 5.342 44 I ., I 'I ,I I' I , ! 5. 2001 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ TO BE SOLD: Middlesex Road A 17013 , Mark . Udren, ESQUIRE MARK J. UDREN & ASSOCIATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 (856) 482-6900 ,,1.,. ,~ "'''''. ' ".~. >'- [I t~~ , ." ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE ION MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD, SAID IRON PIN BEING IN THE DIVIDING LINE BETWEEN LOTS NOS. 6D AND 7D; THENCE ALONG SAID DIVIDING LINE NORTH 68 DEGREES 12 MINUTES 30 SECONDS EAST, 425.00 FEET TO AN IRON PIN; THENCE SOUTH 21 DEGREES 47 MINUTES 30 SECONDS EAST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 7D AND 8D ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE SOUTH 68 DEGREES 12 MINUTES 30 SECONDS WEST, 425.00 FEET TO AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD, THENCE ALONG THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD NORTH 21 DEGREES 47 MINUTES 30 SECONDS WEST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 6D AND 7D ON SAID PLAN, THE PLACE OF BEGINNING. BEING LOT NO. 7D ON THE PRELIMINARY AND FINAL SUBDIVISION PLAN OF JOHN M. AND JANET D. KNAUB, RECORDED IN PLAN BOOK 45, PAGE 146. BEING KNOWN AS 335 NORTH MIDDLESEX ROAD, CARLISLE, PA TAX ID NO. 21-05-0431-044 TITLE TO SAID PREMISES IS VESTED IN DONALD H. BAUER, JR. AND FRANCISCA MORILLO BAUER, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETIES BY DEED FROM DONALD H. BAUER, JR. AND FRANCISCA MORILLO BAUER, HUSBAND AND WIFE DATED 1/17/1994 AND RECORDED 1/25/1994 IN DEED BOOKT 36 PAGE 794. ~~~~~:~'H.!$iiM'''i'''I.!:~'~''~~Hlli;1"till!,u~~Jii;~:':i"!.W-!'::',"I,,,,,;'~~";';'~1:<:,:,;ji",-j,l~,.,;j;AW,_,...~,~.~~.l:IiI'!Il!.b!<~'l!Im-:-:" ~J!i~ r~ ?D "p J r . ('- 0 -... -. \,JJ ~ ~- cl ~ ~ ~ -:- <:1 ~ ~ -. c::: " ,-~ (') f; ""- -oeD nlf' Z::C Zr;;' ~i': r;o '<: ZC -0 )>c ~ A1.~_ C" Q l.- e: :;e -",', ~~~ \}:!. f'.) ,C'_'. \ ~~~! ~ ;iJ :::: :p>- -~ -'" N ,-- , ^. i,; i I I I I I " ~ ;;;'''-''''''''1. ,. ~,.,~.,~., ~~. ,~" ....,..~..' Iiioiorr" 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 ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle,PA 17013 : NO. 01-1383 Defendant (G) 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. dren, ESQUIRE FOR PLAINTIFF !li!~~~&I"'!li'!-'1i'I~:,-\:i'Jlt*,!..'l..~l1~.Mi,i:d~"""ili~~~;'";h"""jhl~0d~';j;W.,,",,;;;j,~,,;c!;>:c"iii;w';;1@l.~~~~Mili~IHIi~'~~r -=""~ -,~ ="""","",,'~...I" I;' !I [j ii " " Ii I; 0 c' c ;;::: 2:: -Om mr(; ~. Z::c; ~- ~. ZI}:: .,<, (J)_,' f'0 ':J 1.~: -<.c.', '. , !;=O '~'r'-. :t:w ~ '",j ~o " - -~ -.'i", ~'5~ (~ 50 c c5rn ~ ;'\) s;! ::0 -< "~.....,,..-.. ., ;lIjIiiIl10' F~' ,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 U.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank National Association f/k/a First Bank National Association, TR UtA ,dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1), Plaintiff in the above action, by its atto~ney, 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: 335 North Middlesex Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address DONALD H. BAUER, JR. 319 ACRE DRIVE, CARLISLE, PA 17013 FRANCISCA MORILLO BAUER 319 ACRE DRIVE, CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address. SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE ,~~,'- .".,~~".~.. ~."~"~~>-'~. ... ,.... ~~ . i_ ._.,~:~" _. ,'t 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. EQUICREDIT CORPORATION OF PA 525 PLYMOUTH ROAD, SUITE 301, PLYMOUTH MEETING, PA 19462 BENEFICIAL CONSUMER DISC CO D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA 419 STONEHEDGE DRIVE, SUITE 2, 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 335 North Middlesex Road, Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of l8 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 4, 2001 ark . Udren,ESQ. Attorney for Plaintiff !i.lllII~~id'jF.-'ii\LW;'M:1ktl!~if..-;t!it"!hl',~m!M'i1t"~~'!"":'~"'''')i1m;i~<-&1',..;,,":m..'_,,;o,1,OitJ'~,~1illJ~~~~_1 ,.",'~- 'n ~Irr ~ ."-"-".... o C ? ~.~. u[D rnrn Z.....-I 2r ~;~? ~o )0'0 2:0 :>c: ~ ~'-' , . <:) ~ ~ '..'..-' ::':J (...l. ~ ~?F~ b.' ::0 -< f'J ;:r.::.. ~. N _~=~_-"'''= "'" '.i!bI-" ""'~~~''''-,. ~ ~ , ~, , ,I ~~ ',' ""."........~ rt f "' ~'" "-'" >>: r t MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF u.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 . (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DONALD H. BAUER, JR. 319 Acre Drive Carlisle, PA 17013 Your house (real estate) at 335 North Middlesex Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10: 00 AM in the COMMISSIONER HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $264,594.67, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 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 .~ __, _. = ~- " " ~ ,. <'lir~~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 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 !lii;U!~lli_ifl>:li\I~'ij{;:F;L""'-'#<;-":"".'l!a.~11!l0,if.l!iii\2kli!f-%,~j;i;;i-i~'Mj'J"")"t,~~~h-ik",",'l,~>!e'~'J~":.Hl\i'-~~~l;!i~~"'~MO<-~llI'~ : ~:U"-' ~. "l,lfMl JiiOO~l!!ti ~ulliL ("") C ~ -0&"-1 tnrr "-77' Zt":' UJ_'"" _<~7 ~C; ~O --0 Pc: Z =< ("") c: <; -otr nlrl~ ~~, ~C ~8 >c: z =< " , ~"~N, -~ .- ~ ,^ ..,~ . I: I' I 'Ii ~::::.' r::= "~,"" ~ , .,.,,!t3 ::~;~~) . 'T, ;;:'::;:-"j ~~~(; ,~) s! :0 -< r',.> > ::r: N r" (,-::.> >= ~~ .hi r"'-.) :,~y~ ,~~~ -:=::;m ,-, "" -'" :u -< N r..:l .~ ~""-~" "~'^~~"ili:.> ~~ -- ~ - , - ~I~!tf",,;, ~ 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 U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FRANCISCA MORILLO BAUER 319 Acre Drive Carlisle, PA 17013 Your house (real estate) at 335 North Middlesex Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at lO: 00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $264,594.67, 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 ARLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take imm&diate gction: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: 1856\-482-6900 mortgagee the back payment, late To 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.) ~~tr~~. " ,~ l~ . I~~ ~h' ~U...~ii..;.i" YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. ~. 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 (~O) 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 ~7013-3387 717-249-3166 or 800-990-9~08 ASSOCIATION DE LICENCIDADOS DE FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-.3387 7~7-249-3~66 or 800-990-9108 iiI~~~~\J,~I~Dfl;ti@ii:i:;t~'iji"'!'ij~!li>lMf'imffi.\~t-l1;'iilJ,.Ni~bi-,Jj'l",:o"#fhf,' "'f~,,,;,~;j;t':!L';f!,~.~~~ ,,_.<-. __ ., ~'.""'"",""",_ ~~-' ,~o. ,,0' " - '"'1"I!iJ~"<~-'_.~ ".,""'..-U -_d:l~" ',~.., .- <." 0 (:) Q c <;: ~ -oOC c= " nlf'T1 :;;r.: , Z:::l ,"r_ zr- , ~~~, r.....:;,- ,,),- ~C; ::::."" >~;(~) ;P>O -i!.>. ~~</; Z~> ~~ >=::111 ,j Z -I ;'0 )> =< rV ~ ,,~. '" -. . ,I II II ,> :1 ., Ii 'i :1 :1 . . II I 1 11 I I .1 I ~ '-..';.' ,.. \ US Bank N.A., flkJa First Bank N.A., TR U/ A dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) VS Donald H. Bauer, Jr. and Francisca Morillo Bauer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1383 Civil Term , " ~"'-"ti!!6;liil!:fe" R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Law Library Prothonotary Surcharge Share of Bills Certified Mail Poundage $30.00 .50 1.00 30.00 25.66 2.30 1.79 $91.25 paid by attorney 7/25/01 Sworn and subscribed to before me so~~ ~ F_ ;I. ~ #..." R. Thomas Kline, Sheriff By~Jwa4 R al Esta e Deputy This J..u{ day of Q" twr- 2001, A.D. gta~ (]. ~~ Pro 0 otary 6V \. ck. 335r;'1 ~ f/5/?? h ~ ... ~< ~, ~ 'I ~~. ~-" ~. , " ~. ."".'" . ,J$, ~ ~ '. 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 U.s. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. ,Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 :NO. 01-1383 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank National Association f/k/a First Bank National Association, TR utA ,dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1), 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: 335 North Middlesex Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address DONALD H. BAUER, JR. 319 ACRE DRIVE, CARLISLE, PA 17013 FRANCISCA MORILLO BAUER 319 ACRE DRIVE, CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address, SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE ""lI!l .- ~', ,""-~~"_.--,~ "~~ " ~~ ~ oL,~. ~ ^. ,,',' .'''''"~~-''~~~''''~;<' .. 4. Name and address of the last recorded holder of every mortgage of record: Name Addre~S Plaintiff herein. See Caption above. EQUICREDIT CORPORATION OF PA 525 PLYMOUTH ROAD, SUITE 301, PLYMOUTH MEETING, PA 19462 BENEFICIAL CONSUMER DISC CO D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA 419 STONEHEDGE DRIVE, SUITE 2, 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 335 North Middlesex Road, Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 4, 2001 ark . Udren,ESQ. Attorney for plaintiff ""--'"" ~. ,=>b~ ~~. .. ,,'. " ~ ~ ~~'<;"" '1li~M-,~:1,!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 U.S. Bank National Association f/k/a First Bank National Association, TR U/A dated aG of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA l7013 : NO. 01-1383 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FRANCISCA MORILLO BAUER 319 Acre Drive Carlisle, PA 17013 Your house (real estate) at 335 North Middlesex Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10: 00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $264,594.67, obtained by Pla~ntiff 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 yon MAY BE ART,F, TO PREVENT THTS 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: {8561-482-69DD 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.) ......., -~. -....,. . "." ._~~~ . ~ ./ me, " \ 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 THJ:S PAPE~ TO YOUR LAWYE~ AT ONCE. J:F YOU DO NOT HAVE A LAWYE~ O~ CANNOT AFFORD ONE, GO TO O~ TELEPHONE THE OFFlCE LJ:STED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER ~EFERRAL SE~VJ:CE 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"'" - ""-"" .; >'M:lL<"~"'-_~ " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF U.S. Bank National Association f/k/a First Bank National Association, TR UtA dated as of 3/1/99 (EQCC Home Equity Loan Trust 1999-1) 10401 Deerwood Park Blvd. Jacksonville, FL 32256 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Donald H. Bauer, Jr. Francisca Morillo Bauer 319 Acre Drive Carlisle, PA 17013 : NO. 01-1383 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DONALD H. BAUER, JR. 319 Acre Drive Carlisle, PA 17013 Your house (real estate) at 335 North Middlesex Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10: 00 AM in the COMMISSIONER HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $264,594.67, 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'fl flALE To prevent this Sheriff's Sale, you must take immediate action: l. 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.) ,"- ~~-l ~,. .. ~-,,~.. =-~ .,j ~~~~"" :'" '~"J~;.J" J~,~",\ k' YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN TF 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 ""~-""h~"'"'-_"""""'-" -"-,, ---.-"'a""~~~'--"" _<.. :.... . I '.~ ~. ~= ,~ ~1!We' ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE ION MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD, SAID IRON PIN BEING IN THE DIVIDING LINE BETWEEN LOTS NOS. 6D AND 7D; THENCE ALONG SAID DIVIDING LINE NORTH 68 DEGREES 12 MINUTES 30 SECONDS EAST, 425.00 FEET TO AN IRON PIN; THENCE SOUTH 21 DEGREES 47 MINUTES 30 SECONDS EAST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 7D AND 8D ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE SOUTH 68 DEGREES 12 MINUTES 30 SECONDS WEST, 425.00 FEET TO AN IRON PIN ON THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD, THENCE ALONG THE EASTERN DEDICATED RIGHT-OF-WAY LINE OF NORTH MIDDLESEX ROAD NORTH 21 DEGREES 47 MINUTES 30 SECONDS WEST, 200.00 FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LOTS NOS. 6D AND 7D ON SAID PLAN, THE PLACE OF BEGINNING. BEING LOT NO. 7D ON THE PRELIMINARY AND FINAL SUBDIVISION PLAN OF JOHN M. AND JANET D. KNAUB, RECORDED IN PLAN BOOK 45, PAGE 146. BEING KNOWN AS 335 NORTH MIDDLESEX ROAD, CARLISLE, PA TAX ID NO. 21-05-0431-044 TITLE TO SAID PREMISES IS VESTED IN DONALD H. BAUER, JR. AND FRANCISCA MORILLO BAUER, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETIES BY DEED FROM DONALD H. BAUER, JR. AND FRANCISCA MORILLO BAUER, HUSBAND AND WIFE DATED 1/17/1994 AND RECORDED 1/25/1994 IN DEED BOOKT 36 PAGE 794. "- 'J '_.' " '-,,' ~'''_L> ,,". ',~ ' '-'"i . . . " .~' -il . WRitdFEXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-1383 CIVIL 19 CIVIL ACTION - LAW "':"'1; TO THESHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U. S. Bank. N.A., f/k/a First Bank N.A., TR U/A dated as of 3/1/99 (EQCC) Heme Equity Loan Trust 1999-1) PLAINTIFF(S) from '..Ibnald H. Bauer, Jr. and Francisca Morillo Bauer, 319 Acre Dr., Carlisle PA 17013. DEFENDANT(S) Real estate located at (1) You are directed to levy upon the property of the defendant(s) and to sell 335 N. Middlesex Road, Carlisle PA 17013. (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 nomy 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 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 nomy him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $264,594.67 6/5/01 - 9/5/01 $5,342.44 Interest (:;is!:!. 0 I/Cllem) Ally's Comm % LL $.50 $1.00 Due Prothy Other Costs Ally Paid Plaintiff Paid $119.10 Date: June 12, 2001 CURTIS R. LONG by .~.~ Jh=;~" Deputy REQUESTING PARTY: Name Mark J. Udren, Esquire Address: 1040 N Kings Highway, Ste 500 Cherry Hill NJ 08034 Attorney for: Plaintiff Telephone: (856) 482 6900 Supreme Court 10 No. 04302 iifj~!i!i1lilIil@)<~!:IW~~,ik,~"h,"~i"",L",;;;"m,;~ID.;'!~w.c."~',;.t~l!Mt~,iil!d!a'fii''';{-''Wi;;i.'<'-l!)&clli:>i;~j'-Ml~~M~>>~V"~L.m<J::lllr,,~~~"'-~ < '.-""'u'.-q"mllTl. "~" . . REAL ESTATE SALE N(J~,jq I II ~ ~ ~ c::-;p Gi......... c) ~ _ . , d LL/I....L I 3/ ;) 0 D I the sheriff levied upon the l1etendam~, interest in the real property ~ituated in f1~FJrfiA~'I:> Cumberland County, Pa lUll!'" >!;rlQ numbered as: 335171J1M fl!~Jt., td _ (~ and mors,."cribed on Exhibit "A" filed with this writ and by this refer"n",'''orated herein. l~te: J k"'-L /~,;;:; Cf) / By: ClGk. ~ ~ !II! .'~" ~,~ .-..~~ . . ., "_... . ~ "..