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HomeMy WebLinkAbout01-2313 FX , MARX J. UDREN & ASSOCXATES BY: Mark J. Udren, Esquire ATTY X.D. NO. 04302 1040 N. KXNGS HXGHWAY, SUXTE 500 CHERRY HXLL, NJ 08034 856-482-6900 ATTORNEY FOR PLAXNTXFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff -COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Geraldine E. Shultz Irvin L. Shultz 200 East Locust Street Mechanicsburg, PA 17055 Defendant(s) : NO. OJ - ;)2/J Ct~~l y~, COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or reliet requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. XF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFXCE SET FORTH BELOW TO FXND 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 ~;c~~,I'T r. ~ I " ~ , " " AVISO Le han demandado a usted en la corte, Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ASISTENCIALEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 ":W"l~~.,~,. ," I~I' "> ^ , - "_.~~'"~ ."'~~"" NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt ofthis Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is'valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not d1ispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the reqUired information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARKJ, UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 .""~ -"." I~--II , - ~.,,~- -- 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: Recording Option One Mortgage Corporation DBA H&R Block Mortgage Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Date: LODGED FOR RECORDING Book: Page: Assignor: Assignee: 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: 200 East Locust Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 6/24/99 DATE RECORDED: 7/13/99 BOOK: 1556 PAGE: 915 The legal description of the mortgaged premises is attached hereto and made part hereof. 4, Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. -'-~'P:-,.I - "1' ,~ . "'I 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. ,The following amounts are due on the said Mortgage as of 3/29/01: Principal of debt due and unpaid Interest at 9.5%* from 11/1/00 to 3/29/01 (the per diem interest accruing on this debt is $19.16 and that sum should be added each day after 3/29/01) $73,629.70 2,887.35 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $77.20 and that sum should be added on the first of each month after 3/29/01) (192.77) Late Charges (monthly late charge of $37.46 should be added on the fifteenth of each month after 3/29/01) 149.84 Corporate Advance Other :Fees 45.00 5.00 Attorneys :Fees (anticipated and actual to 5% of principal) 3.681.49 TOTAL $80,735.61 The Interest Rate and Per Diem are subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected * in the event of a third party purchaser at Sheriff's Sale. If the ",~~.~'f"t"'~" _, I rr!" ~'" "'='"~- mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $80,735.61 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 '-"O~~11! ~~i~' ,"~"",- , ~ rl , ~ .,,_ ""'""""""'c , il;jf.~"_I"_ ALL THAT CERTAIN PROPERTY SIroA'I'ED IN ,TIlE EORO OF MBCHllNICSBURG, IN TIlE comI'I'Y OF C1lMIlERLAND, Am) 'l'IIE COMMONllEAt.TH OF PENNSYLVANIA, BEING Dli:SCIUBEO AS FOLLOWS I PARCEL 17-23-0555-153 AND BEING MORE FOLLY DESCRIBED IN ~ DEED DATED 01/13/99, Am) RECOIlDED 01/14/99, l\MONG'l'IIE LAND llECOIlDS OF TIlE C01lN'1'Y AND STATE'SET FORTH ABOVB, IN DEED !lOOK 192, PAGE 828. ., ,~- ,1.11. - ~, ~~, e. February 02, 2001 OPTION ONE MORTGAGE CORPORATION Irvin L Shultz Geraldine E Shultz 200 E Locust Street Mechanicsburg, FA 17055 Homeowners Name: Irvin L Shultz Geraldine E Shultz Property Address: 200 E Locust Street, Mechanicsburg PA 17055 Loan Account No.: 178804-J Original Lender: Option One Mortgage Current LenderjServicer: Option One Mortgage Corporation . HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS , IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OP171 E}{~1iBIT A CORPORATE OFFICES":3 AOA .. IRVINE" CALIFORNIA g261a~2304" P.O. sox 57041 .. IRVINE.. CALIFORNIA 92e1S~7041 PHONE 800.326.1500" 949.784.6100" FAXLlNE 949.784.6032 ~ ........". -'i,l'.l! ~ '"~ - "II" ,. -.~ ~.,.,. .. -- e. OPTION ONE Re: Loan No. 178804-1 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the, county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. MORTGAGE CORPORATION APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set fortholater in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. , YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED; AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the pennsylvania Housing Finance Agency of its decision on your application. OPl71 CORPORATe OFFICES" 3 ADA" IRVINE" CALIFORNIA 9:l!.618-2304.. P.O. BOX 57041 "IRVINE" CALIFORNIA 92619-7041 1:5:l,_,. PHONE 800.3.26.1500" 949.784.6100" FAXLlNE 949.784.8032 J_ ~- " l"'l' W~ , "" , ,~. e. Re: Loan No. 178804-1 OPTION ONE MORTGAGE CORPORATION ********************************************************************** NOTE: IF yOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply, for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 200 E Locust Street, Mechanicsburq PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: 1 MONTHS @ $ 701.53 2 MONTHS @ $ 701.53 $ 2104.59 (b) Previous late charges; $ 74.92 , (c) Other charges; Escrow, Inspection, NSF checks $ 0.00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2179.51 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $2179.51, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and send to: Overniqht Mail Address 3 Ada Irvine, Ca. 92618 Western Union Quick Collect Pay to: Option One Mortgage Corporation Code City: Option, Ca You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable. ) OP172 CORPORATE OFFICES.. 3 ADA" IRVINE.. CALIFORNIA 92618-2304" P.O. BOX 67041 .. IRVINE.. CALIFORNIA 92619-7041 !5:r,...,.=.,.", PHONE 800.326.1500" 949,784.6100" FAXLlNE 949.784.6032 0;:,1'!I '1""" ~""'T -, ~ ~~,~ -~~, ~, II I "r ~ 0 ~., _0__'. , e. . . OPTION ONE Re: Loan No. 178804-1 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to, pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortqaqed property. MORTGAGE CORPORATION IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property wall be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its at,torneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by ,the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. , OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writinqby the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OP173 COf\POAATE OFFICES" 3 ADA. IRVINE" CALIFORNIA 92618-2304" p.o. BOX 57041.. IRVINE" CALIFORNIA 92619~7041 t:5:r"_=,_,, PHONE 800.326.1500" 949.764.6100" FAXLINE 949.784.8032 ~,"4'~ ,~ ~- . '1" 1-, p ,,' , -- e. OPTION ONE MORTGAGE CORPORATION Re: Loan No. 178804-1 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Office hours: Option One Mortgage Corporation , 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-784-6032 Rushie Taylor x5769 Monday through Thursday 7:00 a.m. to 9:00 p.m. PST Friday 7:00 a.m. to 6:00 p.m. PST. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. , . ASSUMPTION OF MORTGAGE - You mayor X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 ~....--:-._", CORPORATE OFFICES" 3 ADA" IRVINE.. CALIFORNIA 92618_2304.. P.O. BOX fS;7041 .. IRVINe" CALIFORNIA 92619-7041L.:.( PHONE 800.326.1500 .. 949.784.6100 .. FAXLINE 949.784.6032 "~~~~,--..,"~--,.. ~ -~. "II.' , .,. , .' l'- IT1 CI cO ..0 postage $ "i II"' r'I Certified Fee .. lJ1 Postmari< IT1 Return Receipt Fee Here CI (Endorsement Required) CI Restricted Qellvery Fee CI (Endorsement Required) CI Total Postage & Fees $ IT1 lJ1 Sent To r'I , ,. >':"'1 ~~~::';J '~'''R'''''~~''; ~ Cl stieei;Ap1.~iio:;.orpiilioi-N;;'--.~-_.._--_."'.---------_.-________O.M..___ CI CI l'- ci,y,"sia;e:Zi.o;";;...----n_----..----..-------.-----..------........----..... PS Form 3800, May 2000 See Reverse for Instructions " A)' , i\Y'{ &~~ lhtt- ~. "PI','I f' I I , . i' ,:r ... ::l cO ..0 II"' r'I lJ1 Postage $ Certified Fee Return Receipt Fee Postmari< (Endorsement ReqUired) He", Restricted Delivery Fee " (Endorsement Required) Total Postage & Fees $ Sent To IT1 CI CI CI CI IT1 lJ1 r'I CI Si;e;;:'Ai,-i.No.;,;i:;;o"iiox'No:.--..-......--------..---.--..-.....---.. CI t:J cii;:stai6:.zIP+,,----------------------"------------------------------- l'- PS Form 3800, May 2000 See Reverse for InstructIons ~ ~vot~th btWlark J .U8re'1 "P4 1788 C)t-+I ~ ~~-"~ V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. ,The undersigned understands that this statement herein is made, subj ect to the penal ties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities, Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES -""'_"""f1O"'<W~,~,. __~ II ~ - " -'~ ~-~.. ~ ,,-" , ~ <'~"" - , ~iiJj! ^ ~._"~1IIlI ...... ....... c- oot ~ r!!l'''~II!I..._",~""",,, " -""'r' ~~ > "~e'-_~~'_~_ ,~~, "'~'4"__,_,~,~~ (J ~i fj ~ ~ .t ~ 2 -iQ. ~ h, g8- , I Ff!~ ~ ,,,t .~,-,~~~"-- C:' L__ ~i -< -,'1,' ::- J L~, ~_.) "<, ,- '" " 'It <'-~ ",- C\ · ll:) " :~( 'I''f',,"'''' ,~ ,,,_..!lI!~!~-~OY-Pii!'''''''';r , ~;w~~~ ,:N'f"~~'",~!,'cei'?'l!!ll;'t;mjOOi'iVH"'~"!i!!IWi!fi_'!Rmi"(k " H:"""~W;'''''.WiT' MARK J. ODREN & ASSOCiATES BY: Mar~ J. Udren, Esquire ATTY i.D. NO. 04302 1040 N. KiNGS HiGHWAY, SUiTE 500 CHERRY HiLL, NJ 08034 856-482-6900 ATTORNEY FOR PLAiNTiFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P,O. BO:l{ 57038 Irvine, CA 92619-7038 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 01-2313 v. Geraldine E. Shultz Irvin L. Shultz 200 East Locust Street Mechanicsburg, PA 17055 Defendant(s) PRAECiPE TO DiSCONTiNUE WiTHOUT PREJUDiCE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. 4~ !/~ ............. Mark J. Udren, Esquire Mark J. Udren & Associates Attorney for Plaintiff DATED: aeptemher 2], 200] ~'"'''''7 ,~ ~", _ c". I I ,,~ - ~. ~ , ~,~- -~, ~~ "" ..., " <~. ,." ~, - ""~>-, - c, ~'. '%_~,,_.."_ ,..C" & ~ -~-~~-,," ,~ .~ .,,~~~C~jC~""""tl\'lfi'fll1!1~~%JAI:"IM'ji''';''L''~~~f'''''''-'''' ""'-'ic-,,"""""""""'''''' "-,,;>,> ", o ~~ -:](', [9~' 2?:~;'-~ ~-<.' t>C ~" .~- ~i:s~ ~,~< .~..< .._~.. ..,,- -,~ ., "~_'n~", ,_,,,,, ,".,,,j ~ :~~ j-.,"' J,"--;' LC-' . " ~~-" \' "" 'iim;~lf'l<fl'!!!"'"~>:'-'!liJIil,.,.~)WI!"'l'~n~-H'I!!<'i~',"I",~!ip",,!!!,,",;,"t-'i';l;T,j'r1ji ...... SHERIFF'S RETURN - REGULAR CASE NO: 2001-02313 P , COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS SHULTZ GERALDINE A CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHULTZ GERALDINE E the DEFENDANT at 1241:00 HOURS, on the 2nd day of May , 2001 at 200 EAST LOCUST ST MECHANICSBURG, PA 17055 by handing to GERALDINE SHULTZ a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: ~_/ ~.1 R. Thomas Kline Sworn and Subscribed to before 05/02/2001 MARJ J UDREN", ~, By: ;;?/~ Deputy Sheriff me this .<,~d day of ~'" ,;)00 fA. D . (lrLO.~ ~ Ip othonotary , '~ _ _T . _' '_ , _ _,mo""I' I' ~ I , ~' ..... SHERIFF'S RETURN - REGULAR CASE NO: 2001-02313 P , COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS SHULTZ GERALDINE A CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHULTZ IRVIN L the DEFENDANT , at 1241:00 HOURS, on the 2nd day of May , 2001 at 200 EAST LOCUST ST MECHANICSBURG, PA 17055 by handing to GERALDINE SHULTZ, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So AnSW?~~ R. Thomas Kline me this .::/3-<4 day of 05/02/2001 , ~, MARK J UDREN BY:~~ Deputy Sneriff Sworn and Subscribed to before =z:; ~ A.D. '-t' )L..D~,,,,J~ rothonotary ;;;~" ~",.,.- -. -~- ~"(' , . I': I '. -~ -,.