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Home My WebLink About01-1814 FX - " . , , -L,,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 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. tJ/- /~ It/' &;J 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 'Jiling 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 mciney 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,T1IIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 . '" , AVISO "J " . -, " ..,' 0 "." '" ~ ~ "''^k ' 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 avisadoque 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 DEMAlIDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFOMo A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ASISTENCIA LEGAL, Cumberland County Bar Association, 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 "-", NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If YOll 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 ~~ , "-I" I' _. ,~, " I 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: Aegis Mortgage Corporation dba New American Financial Assignee: Mortgage Electronic Reg. Systems Recording Date: 4/27/00 Book: 643 Page: 170 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: 332 Old Stonehouse Road MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Monroe COUNTY: Cumberland DATE EXECUTED: 12/23/99 DATE RECORDED: 12/29/99 BOOK: 1589 PAGE: 687 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 be~ow, shall be immediately due. 1I .." '"I" ~' .,-,-, '" '. '\r 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by, failing_oL_ refusing to pay the,c 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 3/15/01: Principal of debt due and unpaid Interest at 8.00% from 9/1/00 to 3/15/00 (the per diem interest accruing on this debt is $16.32 and that sum should be added each day after 3/15/01) . $73,455.96 3,198.72 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.00 280.00 Escrow Overdraft/(Balance) {The monthly escrow on this account is $94.93 and that sum should be added on the first of each month after 3/15/01) , 237.58 Late ,Charges (monthly late charge of $25.48 should be added on the fifteenth of each month after 3/15/01) Pro Rata MIP/PMI Recording Fees Property Inspections/Preservation Other Fees 153.04 89.16 14.00 60.00 200.00 Attorneys Fees (anticipated and actual to 5% of principal) 3,672.RO TOTAL $81,611.26 7. The attorney's fee set forth above are in conformity with the mortgage documents and PerIrlsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the ~~. 'I'J ~ -I' ,-_, , , " &."1, 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 Mortgage is insured by the Federal Housing Administration ("FHA") and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $81,611.26 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, ESOU'RE MARK J. UDREN, & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 , { wM U " I ALL TRAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, THE TOWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: L SITUATE, LYING AND BEING IN COMMONWEALTH OF l,/ BEGINNING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE' OF CHURCH OR WATER STREET ; THENCE ALONG LANDS NOW OR FORHERLY OF A.S. BLACK AND DORORTHY I. BLACK, HIS WIFE, SOUTH 77 DEGREES 30 MINUTES WEST, 66.5 FEET TO AN IRON PIPE; THENCE BY THE SAME, NORTH 15 DEGREES 45 MINUTES WEST, 65 FEET TO AN IRON PIPE; THENCE BY THE SAME, NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A POINT IN THE CENTER OF SAID MAIN STREET; THENCE BY THE CENTER OF SAID MAIN STREET, SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 4,780 SQUARE FEET AND RAVING THEREON ERECTED A FRAME DWELLING HOUSE, BEING NUMBERED AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA. .' V F. R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is t!!.~_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 sub~ect to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. YJ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES -'''-:>,.",....'"'' ...;~.~ ,;> -r-'\ ,'~""'~J;,;-l>iIW,._;t;;l,",:-jd~<OIl\...jlli;~lll~,",---""",-"",~.,'h:",<{K-k"';"'~,"<-W';"";!."'Bc""''''~;1;l-'~ I"'lM"""""""-"m ""~_..~ ~"<~'."'i>"''iooI~!'!;j-" , ,-~ -'Ill! rr " ~ ~ ~ 9\~ ~ , I (. '^ ~~ (j ~ 0 \ \\ c c' ~ <" ~ ~ffi ::&: '~ =';"", ~ :;;-:,J ~, '1 ~ , W'> N W \J ~ ~ ~~~ OJ :<:::'---' PC' -if Z..) :J: )>'-- t:? c /" Z .J ::<l ,"-> .:.-4 ~\.> '.0 :n -< ~ ..IIt'I_.jl;JIJ~Ul~.~J!:iL~._,~.luj 'I'll'". , ,~."",G~_",,,," ~""?>,,lb 3U.,,~JJ _ "-"~',^,'i!?-""\fj.~~,"'"""",,~ '1~ 0 "" ~,~... ''',0 .~ ,,'~, ~,' " . "".-"" -'<.-0 it 1'1 - ~""''''" SHERIFF'S RETURN - REGULAR CASE NO: 2001-01814 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS GOODRICH DARRELL R STEVEN M WHISTLER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GOODRICH DARRELL R the DEFENDANT , at 1657:00 HOURS, on the 3rd day of April , 2001 at 322 OLD STONEHOUSE ROAD BOILING SPRINGS, PA 17007 by handing to DARRELL R. GOODRICH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.72 .00 10.00 .00 ' 31.72 So Answers: r~ rt~~~ R. Thomas Kline 04/04/2001 MARK J. UDREN h' 1,,!!3:: me t lS 0( 7 day of BY:~qU)~ Deputy Sheriff Sworn and Subscribed to before Of..\lJ ~f A.D. gr:- (2 }h/;L.~.IIg..si P 0 honotary -~ "o~ I;". I ,I " "~.....~,,, "'u.~'" ~ J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. kINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 : NO. 01-1814 civil 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 3/16/01 to 6/6/01 Late charges per Complaint From 4/15/01 to 6/6/01 Escrow payment per Complaint From 4/1/01 to 6/6/01 $81,611.26 1,354.56 50.96 284.79 TOTAL .$..8..3..301. 57 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 cop of which is attached hereto. Ma k J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED ~ DATE: . t~"p _,~ ~I (2H,-f;;;; J {:l-~ - I PRO PROTHY UDREN & ASSOCIATES ... .-. - I ITJ.lL.;L..l! 1.i~~~ht,;!;\j~1~~hll"1"1L~$-'I",>W'.\n""iid~',j"-' --'.;j, "",'I,,-;;,;,;!,,~,""'llili~lBtjil;\(:1\'.Ulff/lM!l6I1illiliMllii;;,it~~~~ , "~ - v?;ni~:~~~;fi~~~~I~~~~Z5';;,3~~:'~~1-!::;J)5~!;,,:1h~I;11,:;0;;,)~:,d:: ~~,l~ J,WJ_ flU" ,-\t :Kll!'-. <J _"..IT.-, ..J:, .",- .'^" , , ~, - ,~ ,- .. ',,",,,,,," . I. " '" (") 0 0 C. -n '<: '- ""'00,) c: -'n .-,,,,, ~. mr" 6.. _.----,ni Z--;--, ZC: W >-';:''"J ()~,?; ~;j~\ ?C) ~;,:. ;c',:!] ;?CI -~. '~~() ~ ['''1 ~O - S' >c. .,~ z: '~ j;J ~ 0" '< ,', ,,~>'"'-~~~ , "1 ''''1....._ -- .~" _.~-~ ~ "" I It ~ 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 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 DefendantCs) NO. 01-1814 Civil April 26, 2001 Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 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 CABO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAB DE ESTA NOTIFICACION, ELTRIBUNAL 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 OLLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIALEGAL LAWYER ~EFERRAL 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. .-. ~.,. " "~~~E.ffiJ.i$-"l'j!i<J~t,gMlfSifB."",;8"1_';' ~,,!,;i'i ol'41~1",j4"io!:'~'-'"','.'~,)'""; ,_<_,e,,_' ':;-,,_;, _ _ '_<_;_;k'"''''-tt'''i~,~:',!.!!iioi;ii2KM ..4:II~] W'~V"~~ lz~~,~;,;~;;~:,~~;"1:,",~1~,~~h?:~;~.uBl,'t1-M,J.;0i,,,>:~,.d;,fl,~,;\b-i_:'t';;,~l]",._:J::~""._,':,,~J,,:,,_JlJJJ, :d:".J:.,:UUll._"U", , .~" ~~_tml'llill,-Mil!!~~__5Ili.j-.iJ!i '- , u... .0"-"',', ",',~"'" __,,-,_, "__,_,,,,, ~ ~~,__ '2 :2.:~ .-0 63 r1J en Z:;:;'~ 2L.. ~7~~ r:;C ~C) ~O J?C ~ o - '- c:: :z " -k":, ... o -\"1 - ~~,?J '~--;l\:3 (~?iq\ ; -1", ',~;C) .:~- ,11 <:2\' "" ':2: w .",. :Y~ - ,- v:> 0' ~ , ,~. ~ - '-J It I...J ~ I , {. . hntL! ~ MARK J. UDREN << ASSOCIATES BY: MarkJ. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) NO. 01-1814 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OFD3 COUNTY OF CbJn~ SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Darrell R. Goodrich Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Over 18 As captioned above Unknown Sworn to and subscribed before me this tJl-~day of UtA..\'\.). . ' 200 I . ~j~ . a. .Pub,hC ,... ..... ....: JAcnll~1 "If ~ GRIESS. ANA JACQUElINE,AhG_ MYMIiICNOI?~~iIlU~L!Ci~1 ~I\'/_ , ommlsslOnJxplfes 417!Z003 ',"-,- I ' Name. G:C . .(4\ ~. Title: ~r bC")r~ Company: N\Q~ J \XtIt.a..n r:s~ .i<i~~~ifu1;&ll~~1.!"'i~.lili!ffqlliiE;&-'t~J\lli'~in::;J'''''-' cc-'" ,-,,~,:,"'_,_ ~;"",,,~l\t'l,-,-oiHI!~~' . ~~ . (::) ~ ~~rt~ ~ ..l::tJ \" ....... ~ r U ':1\ -p ~ J:- !,!j(L,. L,I~~J)iU~!L)~,\_114)J~l"!.IL~,~,?Jl!\LJill..LI ! IOJ .., ~.. -X~l-"""""-"'I"~.illdit1 iff.. '60:" ~J.~'_ ___,,<,",,',.'_'<.._ '.">"._"'",". _ " ~. "u '""'ill:l" o Q ~ -JCP, i-n\~: ~-~\< (I).:c,,, :;:.( {O:~, '.2'-' ~(I bO J?C':: -;Z; 2 -- (c''''';;' :;.2. ..- (.>-~' :::",,' --"~ ........... ~ , ", ~ i:J '::-1.\ :"1.? - - .,\' '~.-,Cl ,:~>)...) --~-~ :t; , '") --;;"~ /~t.} .!--cn S '~ '.,) (1' .. ,---,,~. ~~" '" -... ", ,. J~ ,~ ~~ " , ~" . i , 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 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Wells Fargo HOme Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. 01-1814 Civil TO: DARRELL R. GOODRICH 332 Old Stonehouse Road Boiling Springs, PA 17007 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. Esquire At this telephone number: 856-482-6900 ..... .,...L. II II -r-','-'- -,- ~' ,-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 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. 01-1814 Civil 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 3/16/01 to 6/6/01 Late charges per Complaint From 4/15/01 to 6/6/01 Escrow payment per Complaint From 4/1/01 to 6/6/01 $81,611.26 1,354.56 50.96 284.79 TOTAL $83.301. 57 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 cop which is attached hereto. UDREN & ASSOCIATES Mark J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE:_ tJ'" J.~ ;J.cr~1 , -= . . -~~ 1,1 ~I ,. 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 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 : NO. 01-1814 Civil Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $~ 301. 57 Interest From June 7. 2001 to Date of Sale September 5. 2001 Per diem @$16.32 1.485.12 (Costs to be added) $ MARK J. UDREN & ASSOCIATES Mark J. dren, ESQUIRE ATTORNEY FOR PLAINTIFF . -'. '",g;bj;tlN"t'!'lfJ!,"4!:<,,"E"'J""'~ 1iR!!",)j"-->lHIJ'=b,,,_ '"'"':i11~N___"", ;~W~ ,?",'~', 'b,~,._,~ , '!iJ:JlIIj' ~",>_,".tnM'~~<m~ "'~!MIt!~ ,"''-.J,~,",~i&f~ '" iilil. " - ~,. ~ 0 ~~~~ !..J ~ ~~ ~{q ~ ~ . . ~ 2 0 0 gd?v8 ,j . -:-... 1J $:: '-- 8 I . "m c:: <1 ~.t ~ -7~ '"f-G J -v rnn-f ~- Z..J..J "::iCf; zc c..:;. .... ~ W..!:;:: ~~2~ .... -(..c.. IV ,,~ , , , ~C:,; ~ S , , , . )>c- .'":iY ':;...?(~ ~ . r "-n r Z:C'1 0'" Pc -l . '~ . . .. "' z :.,:, ~ ..... - :< cr> fa~~.~ .. "'!;.~ ~"@;'l\\1$~LJ(",L,!L" P,jUJJ~:~n~'"L l'-1LCL'tlm_u, ",," ~ -., 1~,oc(:4r-.c_:~*J>;.;'._"JH,UL..,,,,;.,,.,,,,,"~.. ' d",..;, ,., "' ~-t'"-.",,, '''''",''~ " ~ .~ _~ "e """ ~ ~ ~ ~..~ ,. .., "It 1'I,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 ATTORNEY FOR PLAINTIFF Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 : NO. 01-1814 Civil 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: X An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MAR~UDREN & ASSOCIATES MarK J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ",1'J,~;,~d'L4H"-'~"""",,""-"'''~;,",,Ju''';~L<!ili.''''~.;l'''0~''''__M,--,~' '^~"';_"o.>~., '''"--''-''_',''~'''''''''L";<;iiJ,:;''!l&llilh.>Ii'''''(O~'~~~'''''''''~- ~.",< '~-'_'Jw.t!iWo"'-.-.",~OiitoiJli;..'lI" ttr~!i<7,,;J"~,~,,r,,~JL~"}~'~:fJJ."~1J:,4,,~~J;:'~~~~'~"b;:,'?kh1-~hl,~t.Q.,6:k,'OJ"2;,rLL%.-_,_ 'h:<'t)~%, ",~ ," <<', '.-. ~", ~ '-"~ ~ -',,- ~, -""......~(-h. -.'.'Il:il (') C s: um nl[TI Z::c ZC S2";; !;::C:: -- .J> .-. Zl; >(~) C Z =< a () 'n = :z -, (,JI"."'i ,:.::0 . ".err, ","'.'. -'':'''r' --:jt:.l -1-',-, <~:D --,,0 ()rn v :U -< ~)<:> -'~"" -J.) O'l . ~ - .J.'O ~~~ 1-.1---1.1 ",1.' U,Hfliltli.>'-: r ' 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 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : cumberland County : MORTGAGE FORECLOSURE Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 : NO. 01-1814 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s) : Name Address DARRELL R. GOODRICH 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE -~".- ~= 1.- - , ,.IJI ~~.,. -~ . 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, CARLISLE, PA 17013 13 N. HANOVER STREET, CARLISLE, PA 17013 Domestic Relations Section 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 332 Old Stonehouse Road, Boiling Springs, PA 17007 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 6, 2001 MARK J. UDREN & ASSOCIATES Ma~"dren. ESQ. Attorney for Plaintiff --., ':'ii!ll~~~~'1lffl-'illp*y~p;;jf.f.~1~'~ffi'IM",L-<~",,- ;'ni~ -~,...". -'~>,i,,;,;,,,j,!:.!.'lW~iIt~_:iJ~~M_l.ilL.li$~%t'IISiiJi.-1lIo1".~-"'I!t~~"r"'~-- ." ~~ jl),n!t('l,.~~,-.,.".",~U.J,ll~J;: IJ~L:."_;,,~,LP.J~.,.' J'~.~~.f_",,:-, !~~,A.,,,(, 'J,b ,.~;,,:'- i,>)'~r,_, "_. "0',"'-' =< ,,,-,, "<.'" ,," --,<,' - ".,....,~ - ~ 'Ii o c ,~ -00] nA\n: Z::r, ZC (j),~; -<:,< r-,----' ~~~ -=U :PC Z ~ ~" ~ "" '"'" "~ -~ CJ o -n ,- c:: ~,.:; ,.~~; (~3(~ ,"j-, '}~~ ~~ ~, ..... )> ::q -<; ,~ :::::-... ::n: r..., 0' r., -'~'~"""'^ '" "~_.~~ I~I~ ,- ~ -' ~'~.,-" r " MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 COURT OF COMMON PLEAS . CIVIL DIVISION : Cumberland County Plaintiff : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 : NO. 01-1814 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DARRELL R. GOODRICH 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house" (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $83,301.57, 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 HE ABLR TO PREVENT 'I'HIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take ~ediatQ 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 b~ 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 n~ed 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.) -""-'-W'" . ~= ~~ ~~ ~~ LI ~ 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 pot 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 WIIERE 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 ~~::~ ~ ,,; , . ;"~i~\$~-;i:i;,M.A.,,,~Y,'&~I$j.f,-1J''":t.iiicliIl!!in;bhW..k;-~il'l"lld'il:''-;';'''1 ;"",,,,",-<~'<L'r_H.!.':',~~i"!4-~~'-i'.."ii'Q;~~~lI~~~'lfi<~~~~~ - -!ila!_ e' ~, ~ ;imA:!)~~;rj",~H~B~l.U\!f.M~~l~"A~~Ft,~.d~_',.,i.i~:,~'\:U"'~ ~lJ;" J;l~~Ld;.'~if1-if!~~J,-<:.~.",; ~Y'" --~-"~"-;J "'H__ "','7_ "~,.,,' .~ -,c,. .' N_~' "--- ~_ v ..... 0 Cl C; C -" -~ S- L. "DO:: r- ,..- nl fT? -"'.. r"Yi ;II Z-rl ~ Jf:? c1J~ G: ~~ :...),.:..) :'--,"-e' J:;o> ;:-~:::Tl :>c:: ::~ r~j ::' Z) -7( .J -=Cl r-:-::.rn J>c:': ::::::j Z w >- =2 <T> ~ ~"'-- lie ,'1-_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 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01,-1814 Civil v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Darrell R. Goodrich has filed Bankruptcy in the Middle District of Pennsylvania on June 19,2001 Bankruptcy No. 01-03519. ~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff >,JMlif"~~jf'..>t!iW\,;""J~'""""":;~'M"',"ht1.~m;J.~#!it"~k~c;';"~,~..i<li"'",,,,,,,,,~':.>,~~;,,,*,,.d;"'liHii>~lfi!i&~~ ~$fu.'~,0"n~ws4~~~' _"-~ _~~~, "N~.~,,~_tm6J,~~A~;~~J.;.,~ _,l!7:d"1",<K~,~t;.Uo;,t~,~,, "',~_, ,~.A" ~y. ,~,-.~ 'C'f'_*, ."-~" " "~o,~'"!_ ,"~' -', ~- ,~., -" ,." " .""1''' " ~'.i!l' ~. ",- ',..,-! c S-;:' ;+ifi: ~.<' -;.... ;-:~~. (;5 > -<::. !;::: C~ 5f~. ...-~ -< . , .~ \..- ::'c:::. (J ~ ~>;j~ ~) ::> (.'"> ::,,~~ ~, -<: "'" I" , Wells Fargo Home Mortgage, Inc. VS Darrell R. Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-1814 Civil Term _ rl ~:: 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 30,00 20.00 15,00 .50 LOO 25.66 3,90 15.00 15.00 1.73 2.56 . $130.35 paid by attorney 7/25/0 I ~~~ r ~,J3. ,~c: ~~". This g ~ day of ~ R, Thomas Kline, ~riff 2001, A.D. g~.. Q )u,tJ#- ;# BY~~ Pro 0 otary Real Estate Deputy Sworn and subscribed to before me 1.s1> ' Ck. 33 56'''1 ~ il/5;).t1 ~. ,,' . , 'luJ ' ,. "....~.~""'_._~; 8. , " ... ii 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 , I'! 'j; :" j' Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County i,1 I"~ I'; Plaintiff : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. 01-1814 civil ! " I AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling, Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s) : Name Address DARRELL R. GOODRICH 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE II.! ~ ""-I" _ ~I r' " ' 'u' U..tJi,lw .r ..... ~ 6. Name and address of every other pe~son 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, CARLISLE, PA 17013 13 N. HANOVER STREET, CARLISLE, PA 17013 Domestic Relations Section 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 332 Old Stonehouse Road, Boiling Springs, PA 17007 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 6, 2001 MARK J. UDREN & ASSOCIATES Ma~Udran, E'Q. Attorney for Plaintiff - ~ ll. - . 'I' J..L 1'1 I." ~ '... ,'. ,~b ~,'*~_ , MARK J. UDREN << ASSOCIATES BY: Mark J. Ud~en, Esquire ATTY I.D. NO. 0~302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. 01-1814 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DARRELL R. GOODRICH 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house, (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $83,301.57, 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 ABI,E TO PREVENT THIS SHERIFF'S SALE To prevent this Sh~riff'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, (SS6) 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,) - ~-- -"< ~--,~ I I ~"I J ~, , j,',G-J,,--. ,;~ ' , 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 FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ,I loJ - . / ALL ~HAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE ~OWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA. MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGI~ING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE OF CHURCH OR WATER STREET; THENCE ALONG LANDS NOW OR FORMERLY OF A.S. BLACK AND DORORTHY I. BLACK, HIS WIFE, SOUTH 77 DEGREES 30 MINUTES WEST. 66.5 FEET TO AN IRON PIPE; THENCE BY THE SAME, NORTH 15 DEGREES 4S MINUTES WEST, 6S FEET TO AN IRON PIPE; THENCE BY THE SAME. NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A POtNT IN THE CENTER OF SAID MAIN STREET; THENCE BY THE CENTER OF SAID MAIN STREll:T. SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT, THE PLACE OF BEGI~ING. CONTAINING 4,780 SQUARE FEET AND HAVING THEREON ERECTED A FRAME DWELLING HOUSE, BEING NUMBERED AS 332 OLD STONEHOUSE ROAD. BOILING SPRINGS, PA. BEING KNOWN AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 22-28-2401-015 PROPERTY ID# TITLE TO SAID PREMISES IS VESTED IN DARRELL R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAXINE A. KLINEDINST, NOW KNOWN AS MAXINE A. KLINEDINST FRY AND GUY FRY, HER HUSBAND DATED 12/23/99 AND RECORDED 12/29/99 IN DEED BOOK 213 PAGE 1132 . = "'.- '~"""f i! I J .1 ,L' ~ ~.~-, . WRIT OF EXECUTION and/or ATTACHMENT . COMMONWEALTH OF PENNSYLVANIA) \ COUNTY OF CUMBERLAND) NO, 01-1814 CIVIL 1lj}{ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Well s Fi'lr~o HOOle MOrtgage. INc. PLAINTlFF(S) from Darrell R. Goodrich, 332 Old Stonehouse Road, Boilinq Sprinqs, PA 17007 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell R.... r",g." 1 o....r.ri pr i on (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/are enjoined from paying any dllbtJo or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing ttier~of; (3) If property of the defendant(s) not levied upon an subjectlo attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above staied. Amount Due $83,301.57 from 6/7/01 to Y/~/Ol Interest P..r r1i"", @$lli ':\;> LL $.50 Ally's Comm Atty Paid Plaintiff Paid % Due Prothy Other Costs 51.00 $103.72 "by.:. Curtis R. Long Prothonotary, Civil Division ~~ -P7?-~~1~ Deputy Date: June 13, 2001 REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway, Cherry Hill, NJ 08034 Suite 500 Allorney for.: Telephone: Supreme Court ID No. Plaintiff 856-482-6900 04302 ""..,.";> '- ,...-.' r,. , c <_~ ,^,~ <~, .,~~~ i:;r~li'~~!iif'~!M'"--;O:;\;~~illfi!:R!&Wi~~jI;#.",Mk!;I..M,,;,:;'i'fi""'scl",":";-",.'i;",.n;:{"'fl';;"~Wll;/M;i~&~~ _lMiI!l!lt~'iii'<~o =~=..~_.~~~=-.~--,~ . REAL ESTATE SALE No. 4(, , , ";>1 ~/S. ::l.Q" i the snenft levied uJ}on the Oelenoal" interest in the real property ~itui!tp.r 'f /?'l1 "-'NJA.M, ~r"_ ~,., Cumberland County, Pcl" knn"',mbered as: 33.:Jd.J~ .H., l tv~~ ~ ~.~ and more fUll ",~c,'\'!(; on Exhibit "A" filed witt" this writ and by this reference incorporated herein. Date~,_ b: ~OOI Bv:f!;iIli:!4- 'V I N '1 ',~i 1.3 N ~!::1 d --, .~- ,,' 1 ! "rt :"'; 10. p~ Sl 9 pi Nfir AlNilC:". ,:jfifl:) .:I.:11~3HS 3H.. ~Q 3~1;l&O ~ JUkUl [,: i,W~~[J1L [("kD~m :..R<y"~..,.,.'-"_N".,,,<,,n,_,,,,",~,~.,,,.,.,. .,~'___N, "_~'~.' l. LJ..Il'hM" .,.;".",",...."., , ~, '" ~i ~ c:;;;1 c:va' ~ ~ ~ ~. ~.,"O ."~~ 'M "", '"""""""~ ~ . ~~L, ""'.. ~l" 1,'1 "~='-"'-." ~ ,",,'~,', ~1~hlliil:.H~j,i;"..,., 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. ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . Inc. . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) . NO. 01-1814 Civil PRAECIPE TO "ISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due $83.301.57 Interest From June 7, 2001 4.455 36 to Date of Sale March 6. 2002 Per diem @$16,32 (Costs to be added) $ MARK J. UDREN & ASSOCIATES ~n, ESQUIRE ATTORNEY FOR PLAINTIFF - ,.- - i,iltk1.i:<l'~ii;j.i;J~j'l!"~".il,'Flfi"","M"ji~~JZi;.,*",,<.0,l1'" J,~~~il'~,,'!ffiW,~ . ,~-""",,,,:, - """,~",'"","'il~~ ~'.IIII.I'hliIlil~""- ~ ~~C"Si:: 't'i1;hc,ti1lI!illil!, -' -~"""V'~~~ li.i.._ - "~, -~ " I ..... --- ~ tv Lv ~ ~ ,? 0 ~ 0 0 0 0 .... c ',] J ,.... C) VJ ~ () $: (:) i 0 !Jm n 'j'} ""'l ~ ~ n1rT' -< r':::" CY Z:ty Jm (> I ZC W -~: ~~) I (I).;..:.::. <::> "~: ~~} :::::- ~F! -<_c., ~ ~ r:,-, :::; f" "I :<~ i~5~~ '\J ~C) -:"'" "'::"{-, ?v ?- , ~ i2f2 )>c \9 ~ > ~ Z r..,..j =< :.:D - (j\ -< , , W ~ ~ If' _=~,w_.~,,,^~_,~=_ . -~..".".-<;.-..w.....,;,_"~~.."_"""""'~ ~~~ ~- ,~~........ ~cL~. ,.~~"~I J.I J ~~._~ 1lllltIIif"".~!..-_"""""""-<"'~!I!!:i!>ii!.~,.: 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 ATTORNEY FOR PLAINTIFF Plaintiff - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Wells Fargo Home Mortgage,Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . - NO. 01-1814 civil 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: X An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN & ASSOCIATES ren, ESQUIRE FO PLAINTIFF -. ~~.. ~, ~,. .. e__ ,~ , _~~_. _ ,l ]J t!!il!!L'~~jb",I:M~.,ii1fu~t.-w;,;-<I!,,,;,,"~.illcHi!,,,,{t";~I;ili;ln~j;;,A"";';"ili~~, '"-,-,,,,', "-"r--,,,~>IG' ;C",,,iJ" _~:~lM" l];!,li!J - E 1.' .lll'![lllj]HI~ lU .JJ~DL,",L~.LJ>>l~;}.~~~;:"."J,1;",C""~,~~"]o"J",,,,~_ .'~_~." ~ - '''--~ .",-".,,,," . ~, - ~'AWn () C <"" -om rnrn 2::1) zr Ci'J>' -<-' ~c:; )>r-" ~o ~c ~ 0' <::) ~ o ('") .-, w Cl .--i ;"~~~ ;.~(-? ----:.';() .(,:-,-, ~~~S C-~iT' J> ::D -< ;,?>" ~J> \.!:, ~) (T' _'w:-","' "'~~"""'~ 0'."""""'..........' '.' ".~,._,_. . ~- J~ d." ~ .~'" ~~I~" = O^~ "_'" " "'''''',",,,"",~j5'' MARK J. UDREN << ASSOCIATES 'BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage,Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Plaintiff . : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . . NO. 01-1814 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE-3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Darrell R. Goodrich 332. Old Stonehouse Road, Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE: 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ~~omJ~ "~."- . =~iIIIllWl " ~ .,-, ' -, ~ 1",,- ,I,uk' '"'"" '" .'~.~ _.4I!x~,,'~ 5. Name and address of every other person who has any record lien on the fJroperty: 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, 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 332 Old Stonehouse Road, Boiling Springs, PA 17007 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: October 24, 2001 UDREN & ASSOCIATES ark J. U , ESQ. Attorney for Plaintiff ,~j;!ll~j-,\ii(,ld,;,lf;-r'.:&2,..'1!f.ri;i"-M6!dcIL.<o,1t'k;t,"w_><,,,);O,,;,,t,,~,~.,,~'l,.,_.' (Y:i-,:~-;~;-'i,-,,,,,,);,,,,,-,,-,~,,,,,.,$!~~>nlW.~;l>l!~~<:i~~!l<Dili"~"""""'"'"-~~- J2~b~~~~';U~tJ,~-ill4g~+.t,~_:.~._~,~>Q,')'~~~~{,lk:_~t"JJ.U1L "~,~"'~_,."_,-. ~, -~;"-, -, '" ~..,,~ o C <>:. -uti:: rnrr; z::c --;T r~' t?i ~;~: ;:,;~, ,<:;c.; ~~; .;.-~c L. =<! o , ''-<,;j , - C.i -n Cl n =--t W o ~-~ -c-_ ;'---;'1r~ "l t:J (-:I " ;~:';~~ Ofn ,-I ~".." ~:'j =< := :J-i: \.D c..' V' ~ -d""~~,,,,",,-=,,~' ,~. lIi:lii ""lj. II ...,J,=laJ ~ " ~._ ~ ' .L..."......~" ~ ~lIilj,i'llIljjilllio<i"'g.i'Mi'~~'-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 Wells Fargo Home Mortgage,Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Plaintiff : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . . NO. 01-1814 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10: 00 AM in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $83,301.57, 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 immedia~e ac~ion: 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 '~',"""il><<""'~~" ,,~ ~....,-_.~. ,~ " . .,. l=_~ ~~. .~"'~ .~"",~ -...1 ~.'l!l~~'lO"- . . YOU MAY STILL BE ABT.E 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, Dr ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOllR 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 Dr 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 Dr 800-990-9108 .~ i. .~ ;a. ").':::.; i!i"""'!LL4i.~Id..~.<iISlt,,!ili!i,a;R'dl"$lf~.;;;n;hl',;:;""_*<i--<'r""'''''''''"' "",_,~,~""""<"';H.""""'.-'d,"'r'"",,",~.,,,,;;$",,,",lilllll~Iii.!&!"'l!'~""""'" ".";'''",'~>!$lll~''''~'''-'''' ,~-,"a >-'.~ ~"'" ,,' ~~~h ~"~" ~ 11 J.: - ,_,,_U.., . J JJJ':':~U~W::.~.~:"t'n_'~: J1X(Ul~_~.~"J~,~ _D1":Jl;!LJL~m....",.),,,.~," ,.,~~~.- .."-!,~',.,~",,,,,',~, ."~_''"_~, "" <.. _ =',,~,,_= 0 C:} r' C " ";"1 s:: c::> .- -cc::: ,', ntrT' ~, Z::'T~I z: r ~ ~~: (;:1 r::::.(~.; ~~; ;;::;:11> _,;.C" -~ '-0 ,-, :z: ,:."" ~ en .'.~= ~" ,~ . ~-"~ ,~ 1-' '1_'1. ,,< '"--,. -j ,,',", ~ <, ~";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 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1814 Civil v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Darrell R. Goodrich has filed Chapter 7 Bankruptcy in the Middle District of Pennsylvania on October 15, 2001, Bankruptcy Case No. 01-03519.. ~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff '-,l~>W'.!i:I'.;;;I;]i>%\M':iIl2i,.ml,;l;:;)M,"M""';;~f*,~tk,""".f,":"~iHL~s.r~"I';;;:""c,w.;:",>\---i'~M.~"WJ<>~1OOi!~tt.~"'.O<."";h'il:.i&.<lI'.' ~U~~ ;,Jh.,iM"pJ~J~jJ;J,;>,:,J1L.rtUJi"',"'1'J'1,iIbtt;Jq_,~!~'~c:,t..,":>:w;,:,, ""J 1,:,,!l~~ ",. 0'",0, ".'" ^,"" , ,.' " 'e_'_," '_<", ,0., -ti,.-~- ,.~~~tiai'd'i . - 'L g <::> 0 N -n ;<;: '- ::J "003 :po f'~ ~\ ;.::: ~rn z ::0 N -"....rn Zr;;: ~.f5Q ~z N U('-- ,<0 = ::;2 -T~ ~O 3 ~~~ -0 'E O' ' )>0 .-j ~ r:- )> -< (J1 3.! . .-. ~'- "~ ....,--, )!'~ ... Wells Fargo Home Mortgage, Inc, VS Darrell R, Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1814 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 Ddren. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30,00 20,00 15,00 1.00 24,20 13,00 15.00 15.00 2.66 $ 135.86 paid by attorney 3-07 -02 Sworn and subscribed to before me So Answers: This Nt... dayof .~ ~~ :-~ ~--q? CM R. Thomas Kline, ~~ 2001, A.D. /...,_ (I Yruk<-,,~~ \'_C':A-fh. BY \hcLu -.JfY~' Prothonotary Real Estde Deputy I,W Lk.. 3:'-P'f;;J..J !!3-u, /J, ::/ g J.O ,",,,,'-is''" !:fI--',,"I~"~~~T~~~." """~, ~ , .....'_,....1..,__"','" II . "'-" "~~~.,,~~~- ';'..; 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 Plaintiff . . COURT OF COMMON PLEAS. : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE .Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 , . NO. 01-1814 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE'3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s): Name Address Darrell R. Goodrich 332. Old Stonehouse Road, Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ,+ Ci,s&~~'~ ,.!~- --~. ,~ " ."' ~~ ",,~__ . _.J n '~ h I ~"~..J~J ,] .~~..~. ~'IlIIlj!-;~"t.l\ci"""" 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, 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 332 Old Stonehouse Road, Boiling Springs, PA 17007 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: October 24, 2001 UDREN & ASSOCIATES ark J. U ; ESQ. Attorney for Plaintiff ",","",';'" ...."'"""".~""' """,.c~,,,,-~,",,,,,".~"'-'. ~ . .- "~ j ~ ~~ ,"".l". .+,-11 ~- - 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 Plaintiff " : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Wells Fargo Home Mortgage,Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . "NO. 01-1814 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10: 00 AM in the cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $83,301.57, 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 BF: ABLE 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: (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 xo 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 - ""','--' ' "'" ~ '""." ""W:JOP"" ...1oIIl .1...-. - - . ".,J.."_.__.,_~" .......IJ... -= -"I!IIIJm!lflii;"i"I';lilll:lbloll;ill~_"".;."~,,,,,,,,,,,,,,,,,_,,,, .YOU MAY STILL BE ABLE TO SAYE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE pLACE. 1. Jf 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. ~he 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. Jf 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 HEI<P. 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 """''''--~.,'''".~'". ~.,', ',," ___J ...._ ~"=~.1~_~1.J .. >_~br.",,,,,,,j,.I,,,,,,, /" I.' I ALL TRAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND COMMO~TH OF PENNSYLVANIA, MORE FARTICULARLY DESCRIBED AS FOLLOWS: : 'II', ; 'I ;: . 'I' i~ "! :![ ,I' I ;1 il :1 ,I ii!', .. 1 .: I 11 II i' ! BEGINNING AT A POINT IN THE CENTER OF MAIN STREET, SAID FaINT BEING 58 FEET FROM THE BUILDING LINE OF CHURCH OR WATER STREET; THENCE ALONG LANDS NOW OR FORMERLY OF A.S. BLACK AND DOROR!aY I. BLACK, HIS WIFE, SOUTH 77 DEGREES 30 MINUTES WEST, 66.5 FEET TO AN IRON FIFE; THENCE BY THE SAME, NORTH 15 DEGREES 45 MINUTES WEST, 65 FEET .TO AN IRON FIFE; THENC~ BY THE SAME, NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A FaINT IN THE CENTE:tl. OF SAID MAIN STREET; THENCE BY THE CENTER OF SAID MAIN STREET, SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT, THE FLACE OF BEGINNING. CONTAINING 4,780 SQUARE FEET AND RAVING THEREON ERECTED A FRAME DWELLING HOUSE, BEING NUMBERED AS 33~ OLD STONEHOUSE ROAO, BOILING SPRINGS, PA. " . .': BEING KNOWN AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 PROPERTY ID# 22-28-2401-015 TITLE TO SAID PREMISES IS VESTED IN DARRELL R. GOODRICH, SINGLE INDNIDUAL BY DEED FROM MAXINE A. KLINEDINST, NOW KNOWN AS MAXINE A. KLINEDINST FRY' AND GUY FRY, HER HUSBAND DATED 12/23/99 AND RECORDED 12/29/99 IN DEED BOOK 213. PAGE 1132 "'""-~~~'",.., ... _l. ,1..1 ~""~ -~"~~ =" ,. ., t'), . f ALL TEAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE. LYING AND BEING IN THE TOWNSHIP OF MONROE IN THE COu.&TY OF CUMBERLAND AND COMMONWEALTH OF PENnSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE OF CHURCH OR WATER STREET; THENCE ALONG LANDS NOW OR FORMERLY OF A.S, BLACK AND DOROll.THY I. BLACK, HIS WIFE, SOUTR 77 DEGREES 30 MINUTES WEST, 66.5 FEET TO AN Ill.ON PIPE; THENCE BY THE SAME, NOll.TH 15 DEGREES 45 MINUTES WEST, 65 FEET .TO AN IRON PIPE; THENC~ BY THE SAME, NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A POINT IN THE CENTER OF SAID MAIN STREET; THENCE BY THE CENTEll. OF SAID MAIN STREET, SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 4,780 SQUARE FEET AND RAVING THEREON ,ERECTED A FRAME DWELLING HOUSE, BEI~G NUMBERED AS 332 OLD STONEHOUSE. ROAD, BOILING SPRINGS, PA. .' . BEING KNOWN AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 - 22-28-2401-015 PROPERTY ID# TITLE TO SAID PREMISES IS VESTED IN DARRELL R. GOODRICH, SINGLE INDNIDUAL BY DEED FROM MAXINE A. KLINEDINST, NOW KNOWN AS MAXINE A, KLINEDINST FRY' AND GUY FRY, HER. HUSBAND DATED 12123199 AND RECORDED 12/29/99 IN DEED BOOK 213 PAGE 1132 ~'~"~_Olli.~ , 'I" j ilj . ill. 'I, .,i :\ :! . , ii, ,[ i, ,I I ri: [ I II ;1 i' ..,:: - - - I~"", __I' I.-J ~ ,;". ~.... ...4.' .. .:.."'" .," "'" WRIT OF EXECUTION and/or ATTACHMENT , ,. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-1814 CIVIL 1~ TERM CIVIL ACTION, LAW - TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due We11s Fargo Hm\e MortSla96. Inc. PLAINTIFF(S) from T1arrRll R. Goodrich. 332 Old Stonehouse Road, Boiling Sprinqs, PA 17007 ., DEFENDANT(S) (1) You are directed to levy upon the property of the delendant(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 notKy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjpined 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) 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/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $83,301.57 from 6/7/01 to date of sale 3/6/02 Interest JJt'L J';'""" @$16.J2 (;4,155.36 Atty's Comm % AttyPaid $177.07 Plaintnf Paid L.L. Due Prothy Other Costs '7) 00 Date: October 30, 2001 Curtis R. Long Prothonotary, Civil Division AO/nt7. 2, 7p52I2~~') '--b.y . Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Altorney lor: Plaintiff Telephone: 856-482-6900 Supreme Court 1D No. 04302 .' " ., .. ..," l:..'l...;t :lf~~ftM:IJ:JMlii~,,,,,~;,!;,:"""-::!"~'"~'AK,;:!i:';eI:--(,,j})i",'i':'":ii,-',+J'::,ii,,,lt,t -,;";",:;',,-,', " "y_;,',i ,,," ,i";,n",,,~";;,:;n~;m~"r_)jM~Iil'll "'1'____dl<ill;.~_J."WtWWiOfi~icill~~~I~iliru\';;;JJIJDlr4' ""~ 'REAL ESTATE SALE NO.2-I On November 0 1, 2001, the sherifflevied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, known and numbered as 332 Old Stonehouse Road, Boiling Springs, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 01, 2001 By. Q'Vl1, , );,'.I-#!-_ Real ~D~~ \ (~ CViJ c:u:v t:::::I <W ~. j',[, - I," " I !-'- -",-: I ~ (1; I! IF. 130 ~ All"': Jjl{I:'i< , ,'-t;) . '. .:;: ;;UO "~~L!l\!,,;t:~t~4}~~:;,,~.~. ",-",,~~-J;!'~J~~~WJd!h-,H},~~\<<#~I.,~Jotli,~{"J'!~~"'__~'A"~~~~,;,.L"" :_.ttj,t8,R1Jtr~"" ""_,,,,,,}!t.,,,y,., ",," " ,J~"~ '. '.""',"_" _~ , m, ,~., '~~ "",,,,,,,, ~, ~..,/,....._~~~ - " ~' 1 I, . ,'"-:.I ~,,~, ," ~ ~, ';= ,'~; MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) NQ. 01-1814 civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $83,301.57 Interest From 6/7/01 to Date of Sale September 4, 2002 Per diem @$16,32 7.425.60 (Costs to be added) $ ~ N & ASSOCIATES ESQUIRE INTIFF -,-----------'-------'- ~j;~&ltd_lUJ&'.J;M,i!<1~__<.,j -;'j.;,A#.li"'oliH"",ili,l!;U"-",.'M';;1i;'<-"'-'i.'",,,,>!;.'~i,~~,i,'~"L," ",,''''c.'_'<-?-~ '-:_l",'d'll'-:,}&'<g!'6iii~'III*lliflilllft"'-''''' -~"" ~h ~, .''-',;.m1J~-'~ <',,,,~.->~ :" t,;' ,- ~oi-- ' ~ , ~= .' ~ <.u (') C) n ,--_,.J ~ -0 ?l "- t.:; ..... -IQ. C 0..) ",'1 1- "'<l. ~ II} :-O~ w w ~.: X ~ ~ ....... -0':-":; 0 - h nln':.~ ).:::1"" :-. ~ 0 Q C ~ ~ . Z~' ,~ '1 0 c C D t.u ~ () ~~~ 1'.7 iT; I' ;'-~ 0 0- c., f ,.0 ~ ~ () ~~) ~ , I I g:C; ~. " ~ f?f! p.-.. ::r: js1~ --..' ) -.J ~ (;) ;;;:C,,:, '2 () ~ ~ P l' ~ ~ ~ ~ , ~ C -, ~ , Z :;;<> CI) ~ r'0 :0 , ':::: ,l;;:)~ <J1 -< ~ ~ , , ... .;: , , ,~ ,l:U~HIIL. ~. v ~,~."v,,<;'C ",~""~,",,,",,"""'_,~,~ ,'. __~, ".-.r, " _ ,,_"' ~ !lL ,> -- i LJ '-"-'- 0'" " J"^,,," WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1814 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From DARRELL R. GOODRICH, 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, P A 17007 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to 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 attachment 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 $83,301.57 L.L. Interest FROM 6/7/01 TO DATE OF SALE SEPTEMBER 4, 2002 - PER DIEM @$16.32 - $7,425.60 Atty's Comm % Due Prothy $.100 Atty Paid $397.43 Other Costs Plaintiff Paid Date: MAY 29,2002 CURTIS R. LONG Prothonotary, Civil Division ,,-By: ~o/>O 0 _ 2 . 7tzrJ?J?/YI~1J~ REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Addre~s: 1040 N. KINGS ffiGHW AY, SUITE 500 CHERRY ffiLL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ill No. 04302 ~.aI"'~''''''~ .~ ~~ 'I - 1 '-1'1 ~. ~y;' MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 , . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . - NO. 01-1814 civil 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: X An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ASSOCIATES SQUIRE INTIFF ;~~o!M\ll!lllM~ii'!!l<.ffi""""'''fli,,,M;q~"-::liki!;t"r'"'''<!I,S::';;JjtliH''~>'''' .l',~-; ,"A">.ii;;,'Mi-A,,,~"U'iA>;;"'il.&~ii!ll!iiii ,Jtl,\tL__;,~,"",~~U:I[,"~"Ulj.,!IlJJILol., __ """"""""~"""'-"'':n~,ItJJ,,,.-',,''1''t1!''',;'}''''r')'j=;;;<;!'7':-<,:,,,.,h5,.., ,"'," ." ,,,"~ ,~" __, ,,, ~"~" ~<", ",=,^- ,." -llLC_;,~'J;l!liliilfjfl ~'~ -"'=~ ~. "w,"." "- 0 0 Ci C N < 'I -o;;y:: ::ll: IT} IT' :J;~ ~iL' -< ~n 1') ;---~ en !~ \.0 _-,~' :~~J ;:s:c. .ccC KC) ~ -T, ~~C'- (~~~ Z J ~C) .,Pc: 0 C')i-n Z -I -" J'V d;'; -< (J1 -'J -< I "'~"~.. 'VI" -- . ,..:...... ~. - ~~~JJ.... , 'I J 'Hii' "",~""r;.~l\f.:' Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m,gsDktType) + ") Bankruptcy Docket Report 1 01-03519 (Harrisburg) Page 1 of2 GOODRICH, DARRELL R Docket items entered between 01/01/1931 and 05/10/2002 Filing No. Docket Entry View Date document 06/19/01 1 VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Plan and Summary None [EOD 06/19/01] [CA] 06/19/01 2 MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR [Disposed] [EOD None 06/20/01] [B W] 06/20/01 3 ORDER to pay trustee, Re: Item # 2, [EOD 06/20/01] [BW] None 07/16/01 4 CERTIFICATE of Mailing of Notice of341 Meeting, Objections to the plan are due 15 days after None meeting held, [EOD 07/16/0[] [CA] . 08/16/0 [ 5 341 meeting held, [EOD 08/[6/01] [CA] . None 08/22/01 6 OBJECTION to Plan by Trustee, [Disposed] [EOD 08/22/01] [BW] None 09/04/01 7 OBJECTION to plan by WELLS FARGO HOME MORTGAGE, mc, Re: Item # 1. [Disposed] None [EOD 09/04/01] [BW] 09/05/01 8 CORRESPONDENCE SETIING HEARING on 11/16/01 at 10:00 A,M, at FED.BLDG" BKRPTCY None CTRM,(3RD FLR.), THIRD & WALNUT STS" HARRISBURG,PA. 17108 Re: Item # 7. . [Reschedu[ed] [EOD 09/05/0[] [BW] 09/07/0 [ 9 MOTION for relief from stay filed by WELLS FARGO HOME MORTGAGE, INC, (fee pd. $75.00, None rec. #573801-CA) [Disposed] [EOD 09/07/01] [BW] REQUEST for admission [EOD 09/07/01] [BW] CERTIFICATE OF NON-CONCURRENCE [EOD09/07/01] [BW] 09/10/01 10 ORDER that answers aredue on 10/01/01 Re: Item # 9, [EOD 09/10/01] [BW] None 09/07/01 11 Amendment to Schedu[e(s): lAND J. Re: Item # 1. [EOD 09/10/01] [CR] None 09/14/01 12 CERTIFICATE of service Re: Item # 10. [EOD 09/14/01] [Je] None 09/17/01 13 Praecipe/WithdrawRe: Item#7, [EOD09/17/01] [BW] None APPROVED by the court. Re: Item # 7, [EOD 09/17/01] [BW] . This entry cancels the previous due date. Re: Item # 8. [EOD 09/17/01] [BW] 10/01/01 14 MOTION for default judgment Re: Item # 9, [Disposed] [EOD 10/01/01] [BW] None 10/02/01 15 ORDER granting default judgment Re: Item # 14. [EOD 10/02/01] [BW] None ORDER granting relief from stay Re: Item # 9, [EOD 10/02/01] [BW] 10/15/01 16 MOTION to convert from chapter 13 to chapter 7 filed by Debtor (fee pd. $15.00, rec. #575034-CR) None (requested Original signatures) (received original signature) Re: Item # 1. [Disposed] [EOD 10/15/01] [BW] 10/15/01 17 CERTIFICATE of service Re: Item # 16, [EOD 10/15/01] [BW] None 10/[5/01 18 DEBTOR(S) affidavit of disbursement of Trustee funds upon Dismissal and/or Conversion prior to None confIrmation, [EOD 10/16/01] [BW] . 10/15/01 19 Amendment to Schedu[e(s): I & J Re: Item # 1. [EOD 10/16/01] [KZ] None 10/15/01 20 Debtor's Statement of Intentions [EOD 10/16/01] [KZ] . None http://pacer.pamb.uscourts.gov/cgi-bin/foxweb.exe/npacer/nPacer?ExecThis=docket&puid=O 1 021 04720... 05/10/2002 'J_~~~'~ _.J~~",:".~-"""",.,, ~'<lI--!:iJ_' ~ -~'"_._-~,_.~ ". ',~~. '. ",I Ji.~ I....J '~ " ..-~~ Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 2 of2 10/16/01 21 ORDER directing Trustee to file Final Report:due on 11/15/01 [EOD 10/16101] [BW] None 10/16/01 22 ORDER converting chapter 13 to chapter 7 Re: Item # 16, [BOD 10/16/01] [BW] None ALL FURTHERENTRlES ARE UNDER CHAPTER 7 [EOD 10/16/01] [BW] This entry disposes of motion. Re: Item # 6. [BOD 10/16/01] [BW] 11/13/01 23 CERTIFICATE OF MAILING of notice of341 meeting. [EOD 11/13101] [KZ] None 12/05/01 24 Amendment to Schedule(s):F, Re: Item # 1. [EOD 12/06/01] [BR] None FEE PAID Receipt #576875, $20,00, Re: Item # 25, [EOD 12/07/01] [CA] 12/06/01 25 NOTICE TO DEBTOR(S) OF DEFECTIVE AMENDMENT Request $20,00 fee, due by 12/21/01 None Re: Item # 24, [Complied] [EOD 12/06/01] [BR] 12/06/01 26 341 meeting held, [BOD 12/06/01] [KZ] None 12/06/01 27 FINAL REPORT of Trustee in No Asset Case [BOD 12/06/01] [KZ] None 12112/0 I 28 FINAL REPORT ofCh. 13 Trustee Re: Item # 21. [BOD 12/12/01] [NP] None 01/08/02 29 MOTION to terminate wage attachment. Re: Item # 2. [Disposed] [BOD 01/09/02] [DR] Doc #29 PDF (J ~ 01109/02 30 ORDER terminating wage attachment Re: Item # 29. [BOD 01109/02] [DR] Doc #30 PDF (1 . ~ 02115/02 31 DISCHARGE ofDebtor(s). Certificate of Mailing, [BOD 02/15/02] [DR] None 02/15/02 32 FINAL Decree. Certificate of Service. [EOD 02/15/02] [DR] . None 04/18/02 33 FINAL REPORT ofCh, 13 Trustee Re: Item # 21. [EOD 04/18/02] [DR] None Printed: 05/10/02 12:14:11 I PACER Service Center I I Transaction Receipt I I 05/10/200212:14:11 I Ip ACER Login: IlmuOO11 II Client Code: I IDescription: IIDocket IICase Number: 1112001-03519 I IBillable Pages: 113 IICost: 110,21 I 't-Nee~ ~elp? Try the PACER User's Guide liiiPacer Service Center http://pas;er,pamb.uscourts,gov/cgi-bin/foxweb,exe/npacer/nPacer?ExecThis=docket&puid=O 1 021 04720... 05/10/2002 ~~~ ~. ,~. .~ I" j '11I ..... MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) . . NO. 01-1814 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007. 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Monroe Township 1220 Boiling Springs,Mechanicburg, PA 17055 .- ~ II. 1,1 ~.,-, ~"'~ "~,"o.t,,&;;,{,,; 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 332 Old Stonehouse Road Boiling Springs, PA 17007 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 statem~nts herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn f s~ ication to authorities. \. a k J. Udren, SQ. ttorney for Pla'ntiff DATED: May 14, 2002 '-.. 'll!iilit!~"-"'-~~Ji,1",~,:lfi;l"F-,'J,-;S,,,,,,,'"F'~",,,,,,li,,,,,~,,,,,,;r>31'.-li2:i;"".;isl',,")',,"" '",',2,''',~ :''''..i',t.1''''c,'''''WCa;#,;","".,.Il~'~'~'~'~ .~~~~~~~*""~ ~'.,. ~'~ ~moi- - -~ ''1?~r.~o,',;~, ~",'Jl!~Jjr;~;I1-, V' _lC~,,, "",;!ll,fJJ" "~_~ J -,j~~ I,)U" ]Jv.~",;~ ,_",L~~,,,o',~ JJl-, t-t~;'r<'~,__""",,"J___ - _ .,~, ,<-~ ,,_ ",: o c: :s: -Qti~ nl rr~ ~~~' ?c; i~ 6 ...~ :-", '.." ,--~,,,,," ',.. ,""f"o-",~,~'''' ".. ',,',,"',I,~,' ~"',' ,., """",,__o,_,,~_ ~,_<....",. 'c~'~,~= ~,. o 1'0 > ::~'/tI- ,"'" 1') \JJ - .I C') ~-r1 ~ ..-, '..::IJ i'~r 'Jtl1 ~-~}j~, ;;;,~ ...-/ -\ -;~ :J:l --< C2 N ()l _~J .~- - ~ .. _:l."~~" ....."" .."'-' ~ '.1.,"" I-.J. - ~"". ~l!.!iL' -~' \ MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF , Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . NO. 01-l8l4 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA l7007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 4, 2002, at lO:OO AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $83,30l.57, 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 SAl,E 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. 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 I' j 1'1 """"""'!ftrlIIii~~-<J-~ \ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF I S SALE DOES TAKE PLACE .r? ,-;"".., , 1, If the Sheriff's Sale is not stopped, highest bidder. You may find out the price bid by , your property will be sold to the 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 r.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 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 f>ii!i;~iili1lt1f1iffiifM.,h,,,,,,J'J".lcU;;!i:d;",,,-,o""'H,;!i:-;;)~,,,f'!<i'_~",l,6.L"''''",;'-,""H""~;,,,"5;i. ~ ":",~,'''C",",,,~,,-~,~~~~iIi<'--''; "'..,~" ,,,-~,.:,Ji~tl_,,,,~_;,,~~~t<,,,l,,, :.JJ,:.L ,.rtQI.;,).Lj:<:"""",l~~l~]1"C__"""",, , .LJJ:J","_,,,. ,?~, ,'~,,', ",z~.,,~,~,v":n!",U'__,"','" ;_, '.,-,' . ,~, ~",,~~,","--' -~'''m-,eMi~tri -' ".~ ~"'"'t'rj::'r ,~ ,_~,~hr"", ""~~' J 0 a 0 C 1''0 "11 ;;:: 3l: .-, "T) err OJ [;-! :c.r- i~~~ .t.:::" ,-< -;;",- '" ,., rn ~, ~~~. ill i5 c-' ~ '~) r ~ ~,.J ---i C) ::t::',,, ""-ll ("--", - ., ~~? ?S ..-;::.... ;-", )> ~~ Ej Z'jrn /......) .i;! =2 en :D -< - ~ ____;""""~Jb._",'_",~"..,"'^"',',<...:J...o"_._c...",;,~L_'_~'d,"'__"",,"","'''''''''_'';,,,,,,,",~_liiIllilllIllOO~~,,,~'u"."',o',,_" ~.I~ ~.-.' - ~ ~~,l....'=-W~;,;_.llo.oUI_~i""IiIl"''''''''''''_'''.,~"")i;l'J~;''~~''j,,,,",,,",,,..,",,,;, MARK 'J. UDREN << ASSOCIATES tBY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) : NO. 01-1814 civil 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". This Affidavit is made subject to the relating to unsworn falsification to set forth by Pa Rule C.P. All Notices were served within 3129. 18 Pa.C.S. Section 4904 Dated: August 12, 2002 & ASSOCIATES BY Mark J. Udren, Esquire Attorney for Plaintiff -- =~.'. ,.. ~ ,~ - 1'1 , '~~ ' "'l,t,," MARK J. UDREN << ASSOCIATES f BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) NO. 01-1814 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007. 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Darrell R. Goodrich 1225 Peffer Road, Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Monroe Township 1220 Boiling Springs,Mechanicburg, PA 17055 .....',. ~ .' ~ "'1,1- .- ,~~'. '" .( 'liiImlilliiiik,>,i 6. 'Name and address of every other person who has any record interest in f 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 332 Old Stonehouse Road Boiling Springs, PA 17007 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 ade subject to the penalties of 18 Pa.C.S. sec. 4904 relating to uns alsification to authorities. UDREN & ASSOCIATES DATED: August 12, 2002 Mark ren, Esquire Attorney for Plaintiff ",j,'h'-"'''''''_-"",-"" ~~, _ ~" ,~".. ~ I~.,l .~ ~ '~ L ,~ , ~ .__ _""""--..:""~"'''''''''''_~''', 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 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. Ol-l8l4 civil Darrell 332 Old Boiling v. R. Goodrich Stonehouse Road Springs, PA l7007 Defendant(s) DATE: June 5, 2002 TO: ALL PARTIES. IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Darrell R. Goodrich PROPERTY: 332 Old Stonehouse Road, Boiling Springs, PA l7007 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 4. 2002, at lO:OO AM, at the Commissioners Hearing Room, 2nd Fl, 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 specifiedoy the Sheriff not later that 30 days. after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within lO days after the filing of the schedule. :,';,Jc, "'--~"""-~d~"""~~t&.l,b"""-"=",...."",-,""",,,,,U.>,~~'^"~ _~, ~"..u.~' gj == ." 15:5 O~ M ~6:E ~ 01= ~.5 0 e~ m IV E'5.. "'~ a ,,-au E2m ,gctll: :~~ st::"O <Bat ~~ ... IV ~ (ij .e mf:Ls> ~ urn .Q l:~ .Q 5.5~-; ~~.E:e ~.~ 'C'ffi- C/l .0::: e-~~ &.~:::. :s:-g&:i co-s.s-s .:.=: C/l'-'- O1m ~ '6J$ $ ~ ~ ",oDD"grn uo:: co.!: :J:U 0; o .9- 'C B ~1ii QlQl"'::E 0:::C/l8C/l E:C ~ 13 .a ffi_ 5. m Ql.c:...)( ~ 0::, e.5 W tl D~DD r1. .E -0 I!! Ql'C -g ]!eo!E g>>~o'ii a::.5uu M M I!! -0 DODD ~ o u it; o ;; a 0- -0 C rn .. I!! Iii C/) w ~~ ~ gs a;: (I)(I):r: 0 W(I)S:2o-' ()<l:IoZ Li:od(l)l.()..i LLZc.9W...J Owzt::i; Stl:025l>- <l: ' tl: ...J::;lZ 0::: '0 w -'... 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"' CO "- CO en ~ ~ ~ ~ ~ ~ , ';i':'~-'c..,,:\.'" l"/s{; .-::c,";", ;':;..-w..~':'i. <,,;:,' w,-~,,::'~,C"" "", c . . . \ ~ i~~HJ~~ rN ';';;; S 2' I ::: Ib,"~~1Lzo OINni 0 p 1;\ ~_AI-1' :r: I~ lnV1SOdsn I~J ":~'ly" "-.0.0 ;:,. g~~7."~' ^~~_~., ,. <( 0.. ~ " .J:l u .2 '" ~ u " :2 . c: :2 '" c: ~ " e"' c:"' 00 :2~ T. ",Il. , t"., '~" -""" ..~". ~.~Y JU \':~ ~\ rot ,~\~ , \ . .i. ~~ I. or : , Ii. IV I) '~,~., ,. (,: '" ,'.- I \~ -1: ~ ']:'): '\ '"" , !~~,j;~~.' . "~'h,,""";'_""'~ w' ,'... M . U o 0:.... '0-1:..([. ~ ~ .0 .em E,., ".e ..:-g .!!!1ij ~:::i c '" a. - c '0 a. m III .. o .l< .E /'") :t ,,~ e:- m ::l ~ .Q Q) u.. ..: "- co '" E .. o u.. C/) a. , . Wells Fargo Home Mortgage, Inc, VS Darrell R. Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-1814 Civil Tenn- Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2002 at 9:10 o'clock AM, she 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: Darrell R. Goodrich, by making known unto Darrell R, Goodrich personally, at 1225 Peffer Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and c~rrect copy of the same, Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2002 at 9:30 o'clock A.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 Darrell R. Goodrich located at 332 Old Stonehouse Road, Boiling Springs, Pennsylvania, according to law. . R, Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency ofthe action to one of the within named defendants to wit: Darrell R. Goodrich, by regular mail to his last known address of332 Old Stonehouse Road, Boiling Springs, P A 17007, This letter was mailed under the date of July 10, 2002 and never returned to the Sheriff's Office, . This _ day of ?~:-<~ R. Thomas Kline, Sheriff BY~~WU4, Real Esta ~ eputy Sworn and subscribed to before me 2002, A.D, Prothonotary 00.... - ,..~ ''!:'::' ;.i1!~~.:>.:,.;k,-'<i',,,-",,- to-' cir,tJ!jj;;;~l<o,",i'~1. L,-,:<i2,will.;~~'.uld~~-"","6""',"j"~' "-"','''r,:, "",!,"~~l';"-'b'S",l;,;r,.t~~~_ n ill!' 1 -"""1"'-'""-'_~!lil f{, ~~AJl!JiJJ.ll!Mli!Ililll~"__Ji"~J. "UJIIJ;JJLiLiL,lJL,UJ:lillQ,tlJtL, '"" """","",''W_, - - ~--",._-~ ~, ~.....~", ~~ . ' 0 <:::) 0 c: N -n ~ r.n ,...; -ace ,..., ~ !:pfTl -0 fil'~ ~_ ::0 I -TIm LC- ::::~~6 ~~2~' Ul ~C~ v -r;-r\ e'-~j :J!,;. ;.'"):n "',,0 j;t~ N 6rn -I Z :J1 55 :-.< (T> -< ~ ""~ ,1 " ,I 1l,J -~ ~ '~'>~~"M; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Wells Fargo Home Mtg Inc is the grantee the same having been sold to said grantee on the 4th day of Sept A.D" 2002, under and by virtue of a writ Execution issued on the 29th day ofMav, A.D" 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 1814, at the suit of Wells Fargo Home Mtg Inc against Darrell R Goodrich is duly recorded in Sheriffs Deed Book No. 253, Page 3689. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this .:<~ day of ~ , A.D. 2002 ~ (3, 1 ~ d", <d:<}{ j , ecorder of Deeds "-,,, Otedo, 0umllerIInd CaunIy, CruIlIr& PA Mv CammIsIian ElqIlrea IIle FIlII McIndiIJ'oI.1l1l.'lIOIMl ~-"'-- ...L.w " ,- , ~" L I 'J n_~ '.~"ll!4,~'. . . Wells Fargo Home Mortgage, Inc, VS Darrell R Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-1814 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2002 at 9:10 o'clock AM, she 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: Darrell R Goodrich, by making known unto Darrell R Goodrich personally, at 1225 Peffer Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 9,2002 at 9:30 o'clock A.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 Darrell R. Goodrich located at 332 Old Stonehouse Road, Boiling Springs, Pennsylvania, according to law. R Thomas Kline, Sheriff, who being duly sworn according to law says 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: Darrell R Goodrich, by regular mail to his last known address of 332 Old Stonehouse Road, Boiling Springs, P A 17007. This letter was mailed under the date of July 10, 2002 and never returned to the Sheriff s Office, R Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4,2002 at 10:00 o'clock A.M, He sold the same for the sum of$LOO to Attorney Mark Ddren for Wells Fargo Home Mortgage, Inc. It being the highest bid and the best price received for the same Wells Fargo Home Mortgage, Inc. of One Home Campus, DesMoines, IA 50328, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $689,63, it being costs. Sheriff s Costs: Docketing Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy $30.00 13.52 15.00 15.00 30,00 10,00 LOO 8.28 2.28 15.00 ~ _.~ " > ,~~ . I. .,AJ - ;, '~ " ,>i'.-Mll'~~~".i,;", Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 20,00 256.1 0 193,75 25,20 25.00 29.50 $ 689.63 paid by attorney 9/19/02 Sworn and subscribed to before me ?J~4'< ~ R Thomas Kline, Shifnff . This 9 ~ day of (Of~~ 2002, A.D.~-,-f1 ~# r thonotary By.Jod:Jj~:d~ Real Estate Deputy ~ uO~? 3D. tf'J \. 0 'i:a,~.3 u><. ~ ootlO? - . I. '" :~ . . .. - " fii' ~ MAEK J.,UDREN << ASSOCIATES BY: Mar~ J. Udren, Esquire ATTY ~.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC.28217 . , Plaintiff v, . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant(s) . . NO. 01-1814 Civil AFFIDAVIT PURSU~~T TO RULE 3129.1 Well~ Fargo Home Mortgage, Inc., Plaintiff ~n 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007. 1. Name and address of Owner(s) or reputed Owner(s) : 'Name Address Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Monroe Township 1220 Boiling Springs, Mechanicburg ,-PA 17055 - M' ,,' IJJ , . ~"'~ ,. ~.l.' .~ /. i I 6. Name and address of every other person who has any record interest in , the prop~rty 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 332 Old Stonehouse Road Boiling Springs, FA 17007 I yerify 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 f Sl ication to authorities. \ \ k J. Udren, SQ. ttorney for Pla'ntiff DATED: May 14, 2002 . ~. ., ~ - .., I'J -,,~~ .' ~il_Ji:iliit~0 MARK J. JJDREN & ASSOCIATES BY: Mar~ J.Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORliEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 , . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland county: : MORTGAGE FORECLOSURE Plaintiff v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . NO. 01-1814 Civil Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darrell R.Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 4, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $83,301.57, 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 immedia~e actiont 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 ~ ~ 1-" '" .~.~" ~'.- :;;'~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 OllT 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 .. ,'I I" LJ .' .~ ,a .~~ '.'. .. ALL 1'llAT CERTAIN TRACT OR PA:RCELOF LAND AND PREltISES, SITUATE. LYDlG AND BEING IN . '!'BE. TOWNSHIP OF .MON1l.0E IN '!'BE cOl1lln OF C1lHBERLAND AND COHIWNWEAL'!'B OF PEmlSYLVlINIA. MORE PA:RfiC1JLA:RLY ElESClI.IBED AS.. FOLLOWS, BEGnlNING AT..A POINT IN TEE CENTER OF MAIN STREET, SAID POIN'.!' llEING.58 ll'lmT ncm THE l;lUILDING LINE OF Cllll'll.Cl1: OR .WATER STREET; TBENCE ALONG LANDS lIlOW OR FOliMERLY OF A. S. BLACK.AND DORORTB:Y I. BLACK,. IUS W:IFE, SOll'I'li 77 DEGllEES 3'0 m....,.,:lSS WEST, II 6.5 FEET '1'0 AN IlI.l1IIPInl .'l'BENCE BY'l'Bl!! SAKE, NOlI.'l'B 15 DEG:REES 45 lUlIUTES WEST, 65 FEET TO AN nON PIPEr'l'BENCE BY 'l'Bl!! SAKE, NORTH 7.0 DlilGUJ!iS 30 HImlTES lllAST, 6'1.8 FEft TO A po:iN'.!' Dl 'l'Bl!! .CENTER OF SAID MAIN STREET I '1'.lmNCE BY TEE CENTER OF SAID MAD! STlI.EET, SOUT!! 1-6 DEGlI.EES 45 MINUTES EAST, 73 ll'lmT TO A POIN'.!', 'l'Bl!! PLAClS OF BEGnlNING. Cl1IITJl.INING4,780 SQUARE FEft AND HAVING 'l'BE.REON ERECTED A FRAXE DWELLING BOUSE, BEINO NUI!l:BERED AS 332 OLD STONEEOUSE ROAD, BOILINO SPRINGS, PA. BEING KNOWN AS: 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 PROPERTY ID NO.: # 22-28-2401-015 TITLE TO SAID PREMISES IS VESTED IN DARRELL R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAXINE A. KLINEDINST DATED 12/23/99 RECORDED 12/29/99 BOOK 213 PAGE 1132. - " . , 'L.iJ J ~,J '1_~:< WRIT OF EXECUTION andlor ATTACHMENT ".COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1814 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From DARRELL R. GOODRICH, 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, P A 17007 (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 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 hirnlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $83,301.57 L.L. Interest FROM 6/7/01 TO DATE OF SALE SEPTEMBER 4, 2002 - PER DIEM@$16.32-$7,425.60 Arty's Conun % Due Prothy $.100 Arty Paid $397.43 Other Costs Plaintiff Paid Date: MAY 29, 2002 CURTIS R. LONG Prothonotary, Civil Division -Bv: a~o f? 7rf/l~?J~ REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 ~4"'" ";'~~"iki!MJa(ll~ '_~00-t.d'M,!,j,j;I3,j;",'#;;;'''''-a!1&""".t''''";:".,,c';;',~'~;' ""',J,"i"~"""'I,h;'''''I"",,,,,,,,,i",,-,..hh\~li!ll':fM[j..i<IiBllil.~~>l.~X&fi!","';""-;~~~_"Ml!llli!!jl!lliillll.lilll~~~:r fIdbn ~ =:, Pdt ~ ,., . . Real Estate Sale # 33 On May 30, 2002 the sherifflevied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as 332 Old Stonehouse Road, Boiling Springs, and-more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 30, 2002 By: CJOII&lCNq. ~wJ ~ ,r I : . ""Jd 'r-i'l:J :,!t: :]0 9 Jhl:bD (SJl Jr- , ib!b l.lJL" '.s;,j) n r AlIW u.c.. h' JAilib:',.>,- . .:il:it($l'i~:__ ',',:IL j),r;'j(j; -=-';'-i;,:;t.;.iW ;;/1b~t; ~'""C""'?c~="""".,,,,,,~ ,,~ _,"~ "~"''''''. _~<_ ~,,,,,,,,,,,,,,Il,~''''" ,,'''';:'~-/,_''''_'' ,-,,;.~,",__<>'"'~~','" <~c ,-",,-<>," _",.7.'''___1_'-',,'__"'''''.''"'' ='~,"'," __ __ ;''Q' "..,' ",'" _,", __,~. _",.. ~ ~~ .. ''',' ". ,,~O ~. REAL ESTATE SALE NO. 33 Writ No, 2001-1814 Civil Wells Fargo Home Mortgage. Ine, vs, Darrell R. Goodrich Atty., Mark Udren ALL THAT CERTAIN tract or par- cel of land and premises, situate, ly- ing and being in the Township of Monroe in the County of Cumberland and Commonweath of Pennsylvania, more -ParticUlarly described as fol- lows: BEGINNING at a point in the cen- ter of MWn Street. said point being 58 feet from the building line of Church or Water Street; thence along lands now or formerly of AS. Black and Dorothy I. Black. his wife. South 77 degrees 30 minutes West. 66.5 feet to an iron pipe; thence by the same. North 15 de- gree'3 45 minutes West. 65 feet to an iron pipe; thence by the same. North 70 degrees 30 minutes East. 61.8 feet to a point in the center of said Main Street; thence the center of said Main Street, South 16 de- grees 45 minutes East. 73 feet to a point, the place of beginning, CONTAINING 4.780 square feet and having thereon erected a frame dwelling house. being numbered as 332 Old Stonehouse Road, Bolling Sprin~s. PA. BEING KNOWN AS, 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007. PROPER'IY ill NO" #22-28-2401- 015, TITLE TO SAID PREMISES IS VESTED IN Darrell R. Goodrich, single individual by Deed from Maxine A. Klinedinst dated 12/23/ 99 recorded 12/29/99 Book 213 Page 1132. - "' ^'"o "~, '\iit1>,; '~I ", ;..l' -.-''".'h,-.k ,. ~ '. ,"', PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2, 9, 2002 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)lacf.) and character of publication are true, ~~ R ger M. Morgenthal, Editor SWORN TO AND SUBSCRlBED before me this 9 day of AUGUST. 2002 ~'i'i, '. NOrM LOISE.~PubIIc CIrII8Ie Boro, CIIn Counly ... . My C.AM IlIbn EllpinIs MlIl:h 5. 2006 ~ > .. '" 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 Frank J. Epler being duly sworn according to iaw, deposes and says: PUBLICATION COpy SALE#33 REAl. ESTATE SALE ti;;:33u 'Writ No. 2001-1814 . Clvll Term Wells Fargo Home Mortgage, Inc. vs Darrell R. Goodrich . ,....AIty: Mark Udren DESCRII'TION ALL THAT CERTAIN tractor or parcel of land ~ and prerriises, situate, lying and being in the ' Towm.uip'., of Monroe in ,the County of: Cumberland and Commonwealth ofPelillsv]vania I morepartiCii1arlydel>cribedasfoI1ows:' ' .BEG~"NING at a point in the center of Main Street, sa:id point being 58 feet from the building ,Hne,of Churchor Water Street; thence along lands now or formerly of A,S, Black and Dorothy l. Black, his, wit!::, south 77 degrees 30 minutes west,. 66,5, feet to an iron pipe; thenc~ by the . s'ame, nntth 15 degrees 45 minutes west, 65 feet I -to an ir6n,pipe; thence by the ~ame, north 70 degrees'30'irijnilleseas~ 61,8 feet to a point in the ~~ro~~'!aMainStreel;th~lcebyth~cc~terof Publisher's Receipt for Advertising Cost 81UU Mam Street, south 16 degree~ 4:1 rmnutes ' ..",7Jfeitloapoin\ilieplaceofBEGINNlNG, !" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general CO~1'AINING 4,780 sq"'" leet and having 't f th f 'd t' d bl' t' t d rt'f' th t th h the~n erected a frame dwelling house, being ge reCelp 0 e a oresal no Ice an pu Ica Ion cos s an ce lIes a e same aye numoered' :a.~' 332 Old Stonehouse Rorid, Boiting : Springs,PA. BEING known as; 332 Old Stonehouse Road, BojTmgSpri:ngs,PA 17007. PROPERTY ill NO.: #'..2-28-2401-015. TrItE TO'SAID PREMISES L~ vested in Darrell R, Goodrich, singh~ individual, by deed from MUffle A, Klinedinst d.1red 12123199, worded " .E.!J-9199,Book213Pas;eI132. ): That he is the Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The 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 23rd and 30th day(s) of July and the 6th day(s) of August 2002, 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 knowiedge 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 subsequentiy 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, ~ ~ ~~,..2d.......'..n.......'.....,......,.....,..,.....,......... Sworn to and subscribed b m i 14th day Of~st A,D, Notanal Seal . .' T eny L, Russell, Notar;Pubhc / /, .,?' iV>/ D" #' City Of HarrisbUrg, Dauphin County .-~ M Commission Expires June 6,2006, NOTARY PUBLIC Mem~r.pennsytvaniaAssOCiatiOnOfNotanes My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA, 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO" Dr, For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 192,00 1.75 193,75 By,..,......,..,.....................,...............,....".......... ~ ~:-:;~, ";,_.