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Home My WebLink About01-2765 FX ,Mj~!5#-""li>'-=~I\<"- --. "~ . X"..l.."= _ ~~~ "~...- , ~~ ~"' IlIilil " -"....,.. _Jif~''''''''>ll''';.''''_,",'''~ 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 Wella Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) : NO. D1 - ;J.7t..5 Q,GI( ~~ COMPLAINT IN MORTGAGE FORECLOSURE yOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and. a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Asaociation 2 Liberty Avenue Carliale, Pa 17013-3387 717/249-3166 or 800/990-9108 ,~~ . .~, , . - ""~ ~~- ~ . ~-~- '''"'~'~'*~;-- 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 ON ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717/249-3611 or 800/990-9108 ,,,,,,,,- ~M_ ~~,L, ~' ~ ~ ~" ---; 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 ofthe 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 dispnte 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 fIrI1l 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..~. "'~ ~~- ~ _..-= -~> . '~~ ~-'. . ~--",. ~~"~~~. = -, ~ ~~M-;;g,~"i;-"':~~_"''''_J:_~" 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Atlantic Reginal Mortgage Corporation Assignments of Record to, Wells Fargo Home Mortgage Inc. Recording Date: 1/15/98 Book: 566 Page: 593 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) andmortgagor(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: 167 Old Town road MUNICIPALITY/TOWNSHIP/BOROUGH: South Middleton Township COUNTY: Cumberland DATE EXECUTED: 4/17/97 DATE RECORDED: 4/21/97 BOOK: 1376 PAGE: 241 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. ~'"",~-.,;"'1l'ilIdl'~ ' - . '~'~~IH ,-",~,". .J > ;tj..lllr"" -':.,.... '. - -...~-""'"~~'-.......,.~-_j~""I<iiIC '........~'ej,:l<'c''-'''''';-_-i,-'"!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 4/7/01: Principal of debt due and unpaid Interest at 8.5% from 9/1/00 to 4/7/01 (the per diem interest accruing on this debt is $17.19 and that sum should be added each day after 4/7/01) $72,810.09 Title Report 3,696.36 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $94.75 and that sum should be added on the first of each month after 4/7/01) 156.20 Late Charges (monthly late charge of $28.00 should be added on the fifteenth of each month after 4/7/01) 325.07 Non-Sufficient Funds Fees Other Fees suspense Balance Corporate Advance Attorneys Fees (anticipated and actual to 5% of principal) 80.00 30.00 (544.66) 155.00 3 640.50 TOTAL $80,878.56 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 "0"""'- "', ~-~ ~~ --.~.~. .. ..~~ ~ . -,".~~tlilll ~" - r """--w.,;,, '..;;. ~,~.,; ~" 'lQ'(~"fu."",,,,,,-,?,,.,-,. 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 $80,878.56 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. :JfJ;\ Mark J "<ire., ES~ MARK J. UDREN & ASSOCIATES Attorney for plaintiff Attorney I.D. No. 04302 ....:....~." .-. ~ -~. -.-~ j' vd......"_._~_ --'"~t''''''' _.lli-., "if., .,' ~/ rf ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A STONE CORNER ON THE SOUTHERN SIDE OF THE OLD TOWN ROAD, SAID CORNER BEING ON THE NORTHERN BOUNDARY LINE OF LARGER TRACT OF LAND OF WHICH THE WITIIIN DESCRIBED PREMISES WAS A PART, THENCE NORTH 57 DEGREES 15 MINUTES EAST, 158 FEET TO A STAKE ON THE NORTHERN SIDE OF SAID ROAD, THENCE BY LAND NOW OR FORMERLY OF LLOYD M. BRANDT AND RECROSSING SAID ROAD, SOUTH 41 DEGREES 15 MINUTES EAST, 150 FEET TO A STAKE, THENCE BY THE SAME, SOUTH 57 DEGREES 15 MINUTES WEST, 150 FEET TO A STAKE, THENCE BY THE SAME, NORTH 43 DEGREES 45 MINUTES WEST, 152 FEET TO THE PLACE OF BEGINNING. CONTAINING ,52 ACRES, MORE OR LESS, AND BEING IMPROVED WITH A TWO-STORY CINDER BLOCK AND WOOD FRAME COTTAGE. , ., .: I' .. ll. "' '"'"," . - ~< ~". '-L."~ i!il2n:?",,"~ ~' Z 902 037 073 Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 January 1, 2001 Wendy S. Arnold 167 Old Town Road Gardners P A 17324 62963 T 1 100 1139/685Ac:t91 RE: Wells Fargo Home Mortgage, Inc. Loan Number 6296311 Mortgagor(s): Thomas R. Ford Wendy S. Arnold Mortgaged Premises: 167 Old Town Road- Gardner" PA 17324 , ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortl!;au:e on your home is in default. and the lender intends to foreclose. Specific information about the namre of the default is provided in the attached pa!!es. - The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the ptoeram works. , To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice withvou when you meet with the Coumelin!! Aliencv. The name, address and phone number of Consumer Credit Counselinu: Agencies serving vour County are listed at the end of this Notice. If vou have anv Questions. vou mav call the Pennsvlvania Housing Finance Agenev toll free at 1-800-342-2397. (Persons with impaired headn!! can call (717) 780-1869). This Nonce contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NOCOMPRENDE EL CONTINDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTI LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRffiA. PUEDES SER ELEGffiLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL VAR SU CASA DE LA PERDlDA DEL DERECHO A REDIMIR SU Hll'OTECA. EXHIBIT Po , , -, "' , .1 ,~ ,"'.- Ii". iai~~~,..!-" Wells Fargo Home P.O. Box 1225 Charlotte, NC 28201-122 Z '102 037 072 ._~- January 1, 2001 Thomas R. Ford 167 Old Town Road Gardners P A 17324 6296311 I001138/685Ac191 RE: Wells Fargo Home Mortgage, Inc. Loan Number 6296311 Mortgagor(s): Mortgaged Premises: Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 , ACT 91 NOTICE' TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort~a~e on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice exPlains how the proe:ram works. To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DA YS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counseline: Ae:encv. The name, address and phone number of Consumer Credit Counselil12 Ae:encies servine: your County are listed at the end of this Notice. If vou have anv auestions, yOU mav call the Pennsvlvania Housine: Finance Ae:encv toll free at 1-800-342-2397. (Persons with impaired hearin~ can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICAOON OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCTA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL l'UEDE SAL V AR SU CASA DE LA l'ERDlDA DEL DERECHO A REDlMLR SU Hll'OTECA. _o"'~iIIII '0' ~.~.' ~_.I .._ , lIlil... -..~ "~"","" -"-"'''~ " ~!,,;"""""""""':,,:m:,'i4~~.r HOMEOWNER'S NAME(S): Thomas R. FOTd Wendy ~ Arnold PROPERTY ADDRESS: 167 Old Town Road Gardners, PA 17324 6296311 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VB 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. . , TEMP~RARY STAY OF FOREfaL~URE - Under the Act, you are entitled to a temporary stay of forec osure On your mortgage or t ir~ (30) days from the date of this Notice. Durmg that time you must arrange and attend a "face-to-face" meetin with one of the cOnsumer credit counsclin agencies listed at the end of this Notice. U~ DAY~. If YOU DO NOT APPLY fOR EMERGENCY MORTGAGE ASSISTANCK YOU __ST ER NG YOUR MORTGAGE {!PTO DATE TliRP.ART OETHI~ NOTICE CAI LED '''HOW TO C1IRE YOIIR MORTGM;E IWFAIIl T", EXPI,AINS HOW TO BRINe; YOlIR MORTGAGE UP TO DATE. CONSUMER CREDIT fOU~SEL~C1 AGENCIES -- If you meet with one of the cOnsumer credit counseling agencies liste at t e end 0 this notice, tn. lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers f d i na ed c n IImer credit cOllnse in a en I S for the coun 'in which th r er is r n i i is only necessary to sc e u e one ace-to-face meeting. dvise your lender immediately of your intentions. API' F R RT A E I TA -- Your mortgage is in defallltforthe reasons set art later in this Notice (see 0 owing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have die right to apr>lY for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a cOlllI>leted Homeowner's Emergency ASSistance Program ~pplicqtion with one of the designatea cO!lsumer c~edit counseli!lg ~gencies listed at the end of thiS NotIce. Only consumer cred,t counsehng agencIes have apphcatlons for the progra!" and they will assist you in s)lbmitting a cOryJ-plete apphcation to ~he. Pen!,sylvania Housing Fmanee Agency . Your apphcatlOn MUST be f,led or postmarked wlthm thIrty (30) days of your face-to-face meeting. YOU Ml!SI FILE YOUR APPLICA nON PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SETFORTH IN THIS LElTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. _,iiIio"'......""'~""'.~". ~~""""'"~-'~~ ,... " ~J - ""~.. ~~, . , . ~ ~ :'IliiM~ --- ~1~'Uia!iIIl.ldilill'1IiW!!ili;i'm~~"'!t""~,!""',g,-~~: 001138/685 AGE~CY ~~TI~N - Available funds for ~~erge.n'1: mortgage assistance are very limited. They will be dls. urs~ y t e Agency un~er the elIgIbIlIty cntena establIshed by the Act. Toe Pennsylvania Ho~smg Fma.nce Agency lias SIxty (60) d.ays to .make a decision after it receives your apphcation. Durl!lg that tIme, no foreclosure proc.eedmgs wIll be pursued against you if you have met the time reqUIrement" set forth ahove. You wIll be notIfted directly by fhe Pennsylvania Housing finance Agency of its decision on your application. . NOTE: IF YOU ARE CURRENTI Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY~]HE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES Ol'lLY 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). NATlIRE OF THE DEFAlILT - - The MORTGAGE debt held by the above lender on your property located at: 1 f.7 Old TOlMTl RO:lcl (;:-lrf~nf'r~ P A 1 Tl?4 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followinr: amounts are now past due: Octnht'r [000 ~ J::ml1~ry J001 ,lJlJ /:;R7 hR Late Char es $238.67 $2.509.95 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION r ~OW l:f{ CURE THE DEFAlILl:- - You may cure the default within THIRTY (30) DAYS of the ate of t is Ilotice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,509.95, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. pa;rments must be made either bv cash. cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: IF Y U aT CEDE A T - - If you do not cure the default within THIRTY (30) DAYS o t e ate 0 t is Notice, e en er IUten s to exercise its ri hts to accelerate the mor a ,e debt. This means that the entire outstan mg a ance 0 t IS e t WI e conSI ere ue Imme late y an you may lose the chaIlce to pay the mortgage in monthly installments. . If full payment of the total amount past duc is not made wlthm THIRTY (30) DAYS, the lender also mtcnds to mstruct Its attorneys to start legal action to foreclose upon vour mortl!aeed propertv. IF THE M~RTGAGE I~ ~OREr.Lq,SED lI~N - - The mortgaged property will be sold by the Sheriff to pay 0 t e mortgage e t. If the ender re ers your case to Its attorneys, out you cure the delinquency belore the lender begins legal p'roceedings againstyoll, YOIl 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 attornev's fees actually mcurred by the lender even If tIley ~xceed'$50.00. Any attorney's fees will be added to the ~rr:ount you owe the lender, whi~h may also include other reasonable costs. If vou cure the default wlthm the THIRTY /30l DA Y pennd. vou will not be reauired to pav attornev's tees. OTHER TENDER RFMFnTFS - - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. '~L,' -'~.!Ifi!.!.l1 ~. . . .~ ~~-'l-"" """_""",,,,,,,,,;i=l':;'~g, 001138/685 EARLIFST l'OSSTRLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale ?f the .mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of cOJ,U"se, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO C.ONTACTTHf I.FNDF.R, Name of Lender: Address: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 Tanisha Rohinson Phone Numher: Fax Number: Contact Person: , EFFECT OF SHERIFF'S SAI.F. -- 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 _ may not 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 SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF 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 ~AR ~1~filiRt5~~01tr~~S~~UrJL~Elt~HllrAIA~'Th,;(k.fI<&t~P~ ~~~ HAVE 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. ~ . .~ ... ~l' ~ ",L....J... ~ ~ _ J , , Ritl.'~~,'tA;I! APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY eccs of Western Pennsylvania, Inc. ;WOO Linglestown Road Harrisburg, P ^ 171 02 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, P A 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the .Capital Region 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 r The Pennsvlvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. . - "","',,,,':' ~ ~ ,~ -.....~, '_.el>~ -'TI ~- ~~ ~~~. ~ "l""~ - r .J, -~,i' -"l"""'~ot"""ilii.;;aitl:tr.' J ^ " '" , . V E RTF I CAT TON Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that , this statement h$rein is m<;l.de .subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. \.. M Mark J Udren, MARK J. UDREN --- ESQUIRE & ASSOCIATES :ii/.:l~~~~~I91.~:l'it~.,-;i!...b:,:;.'tijmti.<'':<':~\\tik",~'';j;>l;iI,"",,,ti'.M1lih';,('fi4,~h,'-,'1-'.; l.\'/'k,~'J_;'M,~~"'~~Miil>iil&il!;['I18LUf,iJll\l!il!l~:H~Il~'-I;"''''....."",~,--~~Ilj;iiijgj>~"""~ .. ~" ~, ~~ ~ ",,,~<, ~_",_,e.U_,~ ~,~,~=.~,,,,,,,_,,,,,_,~ ',_~~ _..____,,,"~",.,,__~,'~~.,,,,'""c""'<<.,. _=_~__"".~, = III ~--. w j ~ -iQ N (::l <- "< .() C) C) ,--, It:. ~ ;.,-' ~ C ,1 ;:0'- - 8 Ii) rOC, -;JC:.' :~\" CY ~~~U -< ~ ) &))~:; , ........ I .-J -<: ",~:- "'~l "- p! VJ ~C) ~_,_J ff \J -,-' '-1-, "- !f- -!.::~() ::J!;'; ~~ ~~1 PJ ;../-c) [..) (Y ",t )>- ~/ ~ c: --.-oj :z ''':> ~ I!... =< flo,J -< ~ "\) ~ - '^ . ~ _. .~ r ~ ,=~.,~- "-,-"-,,,, I. ,,= , '. ~~ 1Il~~'-~ .......,""..;J.i,' ~ -';":rrf~-,,~,.j~ ~ 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 civil Term Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 4/8/01 to 6/14/01 Late charges per Complaint From 4/15/01 to 6/14/01 Escrow payment per Complaint From 5/1/01 to 6/14/01 $80,878.56 1,168.92 56.00 189.50 TOTAL $82.292.98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy which is attached hereto. MARK J. S Mark Ud en, ESQUIRE Attor ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDA' TED ~. DATE: P,.A9 iD :JDDI ()A4k J K.~ I PRO PROTHY - ."'" "- -"I " ~ ~~ - . ~.~ilIlIIIl ""~ -~ _, ~ _' .' ... . .-1. .ol;l1Ji~ "' - ~"-'-ij;\Mjik, ~ 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTORNEY FOR PLAINTIFF 1 COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) I~ 01-2765 civil Term DATED: TO: June 1, 2001 Thomas R. Ford 167 Old Town Road Gardners, Pa 17324 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 800/990-9180 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGAnO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9180 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. ~ = _., <'~r_ Illiii;QIlilf"'" ,liij', "-.",~~~ "'~'Wi1!lilJ;roM~:: MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HIL~, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) NO. 01-2765 Civil Term DATED: TO: June 1, 2001 Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 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 800/990-9180 NOTIFICACION. IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAB DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DlNERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFIClNA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9180 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. ~,'" ." ". =~ .~~. 1-,- . ,-. .\Wtf""i~"""'-"-""""~o.rt . ........ 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) NO. 01-2765 Civil Term AFFIDAVJT OF NON-MILITARY SERVICE , STATE OF 5S COUNTY OF 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 tnat,: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: Thomas R. Ford Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Wendy S. Arnold Over 18 As captioned above Unknown sworn to and,sub~q:ibed before me th~s ,LI... 'day o ;J1 , 2001. Name: S~~ Title: ~~. or 9L~-tz;,. . Compan : ('f\a.0"l/.- I{). QoU.a..n L Q-'S ~ i~~;Wil~~:iIi';'r-'''''djJ,Aib-.ii.!frl:i",-'''~lllilil!!~,jikffilk;;11:j~~~;,'fr,~;'''*'''''''W~~;V.",.iG.!~~~;;M:lIWl,..- .-~- i.:~;~~,~.:i~il""''''''lM - , ~~ ,~=,~-~ ~~--._~ ~ ~ -~~ ~~" ~ ~~ ~ ~ l ~ ...~ ~ J","",,_, _^ , ~ ,.~ ~~ ~r ~~ -t.... - ,,- -~.-,~ ~ ".-",--, - o c "" -ow rrlfT' -"'-1 ..:.:--.,- :ZC !:Qd.o: ,<C~ ZO -0 PC ~ o 1>" c:: '" I 0"' \'-':.:..,/:,j." - "'~:-,~~i::r:~~tl!, , ~. -.~ ~~_. ~~<"~ . ,I I ...." .. . .. o Tl ;po ,.~ .-, ;'.hp ~C}H "UY S~~J ~r: :i] ...),.~ 7....... Orn .~ '].:;.: S:J '< '? U1 Iv 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) TO: THOMAS R. FORD 167 Old Town Road Gardners, PA 17324 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. ES~lire At this telephone number: 856-482-6900 "---- - , . - ~-~ < ..'-.......~,-~ ~~~- ,. " MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. '. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 4/8/01 to 6/14/01 Late charges per Complaint From 4/15/01 to 6/14/01 Escrow payment per Complaint From 5/1/01 to 6/14/01 $80,878.56 1,168.92 56.00 189.50 TOTAL $82.292 98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy which is attached hereto. .,1 MARK J. . . Mark Ud en, ESQUIRE Attor ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: 4-'9 b, ;}t"Y, .' INnI . TED (7,,14 -t;.,. ) PRO PROTHY f)_~ - "" --. "~- , . .......-." ' .,. .Ff'....; ~ ~.~,.'- ~-Jl' " "'" . MARX J. UDREN << ASSOCIATES BY: Mark J Odren, 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COlVlMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) TO: WENDY S. ARNOLD 167 Old Town Road Gardners, PA 17324 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J Udren. Esquire At this telephone number: 856-482 6900 ..- ._~ ". ,-, . ',---'- , ~ .,. ...; "'- ~ "AAM_~,,--f_.. .. ~ MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D, NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant{s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 4/8/01 to 6/14/01 Late charges per Complaint From 4/15/01 to 6/14/01 Escrow payment per Complaint From 5/1/01 to 6/14/01 $80,878.56 1,168.92 56.00 189 'i0 TOTAL .$82,292 98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy which is attached hereto. . . S ,I Mark Atto Ud en, ESQUIRE ey for Plaintiff DAMAGES ARE HEREBY ASSESSED DATE: ()/~ ~, :2rY>/ AUn> T~ ~ ~ ~~)~. P 0 PRO Y o._^._~ --I ,~-. -~ . ,-- ~'1liI ....... .l ~,.~ ~ iIllI!IlIiIl .. ~~ ~"I~"~j;f, MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 ~040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 167 Old Town Road Gardners" l;'al7:324. Amount due $82.292 98 Interest From June ,15. 2001 to Date of Sale December 5. 2001 Per diem @$17.19 2.991. 06 (Costs to be added) $ MAR REN & ASSOCIATES Mar ATT n, ESQUIRE R PLAINTIFF ~~~.ii~~~:.z1ililli,~>ir-_~\"..0J'!'1l!:.~[m'I_&iif,Ma\l!:3;C_;'!I';'E'-'--l~~",",) ,_ -S'~.";~~~Ji;W_W;'$~!o1i!'IWil:~W~ffiJ!i!~8"i.~f.,,~;.lro!!l~~';a,1'I"'''\1:tW;;;:'lII!~I~_! -"~:-5:r~ ~ ...... ~ .... -p r- ~ ~ ~ ~ ~ .... ~~ -..0 r- ...... it. g ~ ~ ~8 &, g ~ 0 0 ~ 0 ~ -l:: c C- o <::I c- c: ~, If) ~ I I <- TI -Om "'" ~ "~ - ~ (?"V mm G5 ;::-:1p2 ~ ~ r6) :- , Zx , ~ z~ I "oct! , i-r , OOe:c::;: en : ;') ~..J ~6 r~:J~) . :r~:J!I> - " ... - ~ ~o --1...+J ... .... ::11:: 0- -0 70 )>c: f!? om ~ :J1 ~ =< f'0 :IJ -< ~ ~- -~ ^ '" ~ - ~- c ,"'''''''''~-,..''''- ~iI!a'-"'~' ~'. j , .~ = !' ;"'I!',.,t" 'Lm;_~:;. 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 : NO. 01-2765 Civil Term Defendant(s) C E R T I FIe ATE , Mark J.Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Ma k ~ d n, ESQUIRE AT ORNEY FOR PLAINTIFF ;~jj;~iIllliJill!il:ll<~,~li:1fur0",":" ,."i_-.f,"fj~,t,"'!l:ti-_~"'j!;8\:~""irill~"~,,,t;,~,..,!i,,',, ~;,_-"",:,""";:-<':cl:i_~Jl;;"i#!;i~m~:,,-iJ,*~";~-!C'''',l:'J~t&",ii~-,';!l!ipl~M~lii!jj_l!iIId!k!i!~~~_,fj{:I!'&lEI!iIllII tl;i:' 0 0 0 C -n ;;: ". .-4 -UUJ c:= mm G') Fr1~ ZI' ZC I "':Jm (f).r:;;: cr. -'-]M -<--- ~.:)(T !<t) .r.:::> ",. ;J;:Jrl >'n ::-ili.: Z'. ~~O --0 >-C' co ~m v :5 ,...., U"I ~ -< N -< ~~ "~"~-. ". ~_. ~, . " -- .- '"" . ~ - - ~'^'""' ~ "~ .".- .,'-", ~~~";,. r - MARK J. ODREN &: ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 : NO. 01-2765 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. F/K/A Norwest 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: 167 Old Town Road, Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s) : Name Address THOMAS R. FORD 167 OLD TOWN ROAD, GARDNERS, PA 17324 167 OLD TOWN ROAD, GARDNERS, PA 17324 WENDY S. ARNOLD 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 - -~. , -;, ~'"'~-"-""'. 'c~ ~i!:.1i 1M" r , 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 STREET, CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 167 Old Town Road, Gardners, PA 17324 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 uns falsification to authorities. K EN & ASSOCIATES DATED: June 14, 2001 M rk J. Udren, ESQ. A torney for Plaintiff ~~~<J'*~1"'itl1;Hd8,,;;;~16ii\:t~1@'''{~~'''''>.fu:i.'r,;iq!'i,;ci..>illII..~j~\iiWII~~~~J"i'v"~" _'ti!"~~~~t!i!:- ,".,." -~l~IiIlil2l1J-~-~'iOlij':i '! \1 . ~ ~ ~ :1 ~ ~l II :1 I " 1 ~ 0 0 () c: -'n -~ ~ -~ $-~ -CJQ:'l /l~ [pIT-' ,fi ~---'" I -.'~:1j7 Zr.;; 0"' (j) ","::,E {_'~~C} -<L C:Cl ". r" -it >C'" -'_'.-0 Z. .1 :::r: ';;;!o --0 /:-rn >c: '? g ~ (J1 ~ N . ~'H.. -,=~~ ~ ~~ "- - ; -~, " -= -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 wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 Defendant(s) : NO. 01-2765 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: THOMAS R. FORD 167 OLD TOWN ROAD GARDNERS, PA 17324 Your house (real estate) at 167 Old Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COtJRTHOUSE, CARLISLE, PA to enforce the court judgment of $82,292.98, 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 yon MAY BE ABLE TO PRF.VF.NT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) - ,< ""'. ~.~ -"'~~.' , ~ ,- ""'~-" -'~ ~,. lt~'~t~Ai: - 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 800/990-9180 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Servicio de Reference Legal Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717/249-3166 or 800/990-9180 _il!liij~liI!I>'itllr.mwf~\t.iI'klrf,'M'.llI~~~W~\,~J-,;"jIh~liid'",~"~,,,;.,i-.0ji1l'~~~fi~l~~~Mm~;b!!!i!~l"l~,*~',"""","-lll!IJijr.'lii1ir ~ kr - .' ~ - .< --"- "J~!i&:'jl~ 0 0 ~ - c: ~ .~ ~ ~.C -r1 -OW G? ~-nF mrn -'t? Z>> I -', ti?r:;: 0" ':-~c' :<7 :-..1-1\ \20 3~ CJZ-; :;,J; ~Q Cf! Of\\ :;;e ~ ~ :.Jl ?:O r-:> ~ r: """~ ~.4'~_,,-~ ~ ,,,,,,,,."-,, ~- . -..............' ~ ! , !~- - ,,,","-~ .--- - , ~nIi"' il:lli -"Jl;i$1<- " , .. SHERIFF'S RETURN - REGULAR CASE NO: 2001-02765 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE VS FORD THOMAS R ET AL BARRY J HORN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FORD THOMAS R the DEFENDANT , at 0918:00 HOURS, on the 8th day of May , 2001 at SHERIFF'S OFFICE COURT HOUSE 1 COURT HOUSE SQUARE CARLISLE, PA 17013 by handing to THOMAS FORD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 .00 .00 10.00 .00 28.00 So Answers: . _ ,_~'-'~?? .\f;J.jO- " .4~ ?' ~~",,'t;."'t; ,.(- R. Thomas Kline '^'c..A"$ Sworn and Subscribed to before me this :13 .A day of ~ ~f A.D. (l"'o,(L ~,~ ~ 1p10thonotary , -~"~"",~j"" ~ _~w .~ ,J "'_.= ~ "'" ,. .' ;'".-'"I~~~f!', . ) - SHERIFF'S RETURN - REGULAR CASE NO: 2001-02765 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE VS FORD THOMAS R ET AL PATRICIA SHATTO , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ARNOLD WENDY S the DEFENDANT , at 0845:00 HOURS, on the 9th day of May , 2001 at SHERIFF'S OFFICE COURT HOUSE 1 COURT HOUSE SQUARE CARLISLE, PA 17013 by handing to WENDY S. ARNOLD 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 So Answers: 6.00 .00 .00 10.00 .00 16.00 iF.''".~~~;::~''''''''I''':{~;.9~(!#> R. Thomas Kline 05/09/2001 MARK J UDREN me this .;2.3~ day of BY~-P~/_L~zt: Deputy Sheriff Sworn and Subscribed to before ~ d-bV f A.D. ~Q~# rothonotary F __"= ___~'~LL~ .~~ -< -~ ~...~""~""--" _ 1. ~~ . =,~~"" >_~" "'-"-'-"'~~'~1ii0;j;fjM!lll;j!A~\:';;"f,+0i!l!tt1&'1!;:''''''- MARK J. UDREN & ASSOCIATES BY: Mark J Udren ATTYr.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) : NO. 01-2765 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 26, 2001 MARK J. UDREN & ASSOCIATES By:m Mark ~tldLen, Esquire Attorney for Plaintiff -=u'~""^.""""'-,=_"'" ,"'-w__~'"_"'~;.,,~~.~_.~ _ ~ ' " .~-, .~-" ..~ '" '< '~#IlM'il!'lif....rnt'02 . 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-2765 civil Term v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) DATE: August 6, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S}: Thomas R. Ford Wendy S. Arnold PROPERTY: 167 Old Town road Gardners, Pa 17324 Improvements: RESIDENTIAL DWELLING The a.bove captioned property is scheduled to be sold at the Cumbe~1and County Sheriff's Sale on December 5. 2001, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A "^,.~,. 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UDREN & ASSOCIATES BY, Mark J Udren, Esquire ATTY I.D. NO. 04302 10.40 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-2765 Civil Term v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Thomas R. Ford and Wendy S. Arnold has filed Chapter 13 Bankruptcy in Middle the District of Pennsylvania on December 4, 2001, Bankruptcy Case No. 01-06436. Ma~=' Esquir, MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ~fi!!\li:lilli;ii!.ilm"!illli!;~q.'''''''''.:tii"",",'f~~li1Ii.,~!Mil,;<i!$1'lH,'<ll:i>:I'''Jl'!'~;~t''_1'k,;",,!;;,~,,"':;'U!if~'!ittM:~i~~_;)fl: "'~~~ he _.~_ .,_~","__,J ',',' "";':J,ili!$.~~Mr.;j@;,__...~B:!l~~T--'~"~ "" ._v v' (") <:::0 C C N .. ~. < :-z -oif) ~ r111T ~O i-ii:~l Z:.:r~ zr:- I ::~~t~i (f) _...,~ UJ ---2" 1'__J~l r:' '-,-1"--) ::::::;L; ~: ' '.~.T, )>r, ;.."):D ~("" ...h '~> C) ;J> -- 9 (3fTl C ~ c:-l :::> -,..~ en :n -< ". '" ...!: ,0_ ~ ,~ =-~- " ,^"-," < .~ ~ ~" Wells Fargo Home Mortgage, Inc. fi'k/a Norwest Mortgage, Inc. VS Thomas R. Ford and Wendy S. Arnold 4 ~.., < . "nirj["""""-)~~ ,~-,~+~~. " '~- --~'<t..l " In The Court of Common Pleas of Cumberland County, Peunsylvania Writ No. 2001-2765 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 30.00 15.00 .50 1.00 25.66 3.25 15.00 15.00 1.12 12.21 20.00 246.80 206.94 $ 622.48 paid by attorney 3 -07-02 Sworn and subscribed to before me This JL/~ day of ~ 2002, A.D. Cfr, Q Mdlh) Prothonotary ~. So Answers: ~~~~<~-c.e R. Thomas Kline, SHeriff BY -J 0 tit{ cS~ Real Estate Deputy f.sC Ue. 3 ",/if.23 ~ 1,J:2fJo;- - ",,""-- ., "j - ~ ,_.- ~_ H ....cc 1"-- '",., ".~S . , .MARK J. UDREN << ASSOCIATES' BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. . ., Thomas R. Ford. Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 : NO. Q1-2765 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. F/K/A Norwest 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: 167 Old Town Road, Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s) : Name Address THOMAS R. FORD 167 OLD TOWN ROAD, GARDNERS, PA 17324 167 OLD TOWN ROAD, GARDNERS,PA 17324 WENDY S. ARNOLD 2~ Name and address of Defel;ldant(s) .in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE~ ,I 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 ",' ~." ~~,~ ~ ~ .~ .i&,.""'="':'u ."'''l,'w;~i~~, . 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 STREET, CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 167 Old Town Road, Gardners, PA 17324 I verify that the statements made in this affidavit are true and correct tQ 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 uns falsification to authorities. K DATED: June 14, 2001 M rk J. Udren, ESQ. A torney for Plaintiff . . ,,j ~1~~~;i;.qti"'"""tlt4:g~~iI;g~!li"~'1lll;;li#i;lf.k;;"I~.IS!l..cl":;~!kfu.iwg,~iliif,I~~~ dlM:;;;-_..-!iI~ , ~ > .nlU VI riV rl' S N !jJd , ,~, , , IO,~U liE 9 UI'il1irK<" .:il-imJi!iI~:S ~ ~,,~ "O~_~ 1._ , - ,~ t 'lift' "".M;[~l::!l "'0~:'o}~ L'J>l ~ 1. -,~~ - ~-- ~~"~... .~ ,J. "'" , ~~ .- ''', i n::'-' """ Ml': . 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. F/K/A Norwest Mortgage, Inc. 5024 parkway Plaza Blvd Charlotte, NC. 28217 . COURT OF COMMON PLEAS . CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 : NO. 01-2765 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WENDY S. ARNOLD 167 OLD TOWN ROAD GARDNERS, PA 17324 Your house (real estate) at 167 Old Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in tbe COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $82,292.98, 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 '1'0 PREVENT 'I'HIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take 1mmedia~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 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 '"' ,~~ r "~-- -" ....... ,~ .i.1e " ~ !Ii i:1.ll!l/;;. '-, Jr . " . . , 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 TIlE 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 800/990-9180 ASSOCIATION DE. LICENCIDADOS DE FILADELFIA Servicio de Reference Legal Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717/249-3166 or 800/990-9180 ~~U~.l:Il1W~~;i!f;jiMtlU-ik'il;j~4t4;-f'~li~~i,it'-<l""-;~~~';':~~5iW',DA!~~~~~~~W>iJ _. ~~ ~ -. ~--~-~ , ~~ < ~~!illlO:!'~-'.J:I 1!!rlln ''''-''''"''4l" . V\ if'i !\ll~; ?1~3d ",.~-, . -- ,l " I In. WJgf. .~ 1 '~1lJ . _ ~,,_ ~'; \:1M,~tD }!iiJh""..'ec , :,,:"~'i:liJl\l} :lkJJ~\2E :J:j,:~'w. .lL~. ;j).iJl ,. -- -,~ -~ ~-"~ ---: . , ~~ ~- ,~~ - , ,j "~--- ' ~.... ,~^ '--JMi.~~;- . 1l.LL TEAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: I , j , ! BEGINNING AT A STONE CORNER ON THE SOUTHERN SIDE OF THE OLD TOWN ROAD, SAID CORNER BEING ON THE NORTHERN BOUNDARY LINE OFALARGER TRACT OF LAND OF WHICH THE WITHIN DESCRIBED PREMISES WAS A PART, THENCE NORTH 57 DEGREES 15.MINUTES EAST, 158 FEET TO A STAKE ON THE NORTHERN SIDE OF SAID ROAD; THENCE BY LAND NOW OR FORMERLY OF LLOYD M. BRANDT AND RECROSSING SAID ROAD. SOUTH 41 DEGREES 15 MINUTES EAST, 150 FEET TO A STAKE; THENCE BY THE SAME, SOUTH 57 DEGREES 15 MINUTES WEST, 150 FEET TO A STAKE, THENCE BY THE SAME, NORTH 43 DEGREES 45 MINUTES WEST, 152 FEET TO THE PLACE OF BEGINNING. CONTAINING .52 ACRES, MORE OR LESS; AND BEING IMPROVED WITH A TWO-STORY CINDER BLOCK AND WOOD FRAME COTTAGE. I BEING KNOWN AS PROPERTY 10# 167 OLD TOWN ROAD, GARDNERS, PA 17324 10-14-0142-055 TITLE TO SAID PREMISES IS VESTED IN THOMAS R. FORD AND WENDY S. ARNOLD, AS JOINT TENANTS WITH THE RIGHTOF SURVIVORSHIP, AND NOT AS TENANTS IN COMMON BY DEED FROM ROBERT L. SHEARER AND ANGELA J. SHEARER, HUSBAND AND WIFE DATED 4117197 AND RECORDED 4/21/97 IN DEED BOOK 156 PAGE 151 ~" , ~~ '~~"ol' o.,~,,:_-'" ,~ - i " - ~ '~'-<iiiw~ .~ -10 ~ MARK J. UDREN & ASSOCIATES BY, Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, ~UITE 500 CHERRY HILL, NJ 08034 856-482.-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 : NO. 01-2765 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: THOMAS R. FORD 167 OLD TOWN ROAD GARDNERS, PA 17324 Your house (real estate) at 167 Old Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $82,292.98, 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 RF. ABLE 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 mortgagee the back payment, late charges, costs and reasonable attorney's fees. ~o find out how much you must pay, you may call: (856) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ :'-~;"',. ,. ~ .......;......~' " 0" ~'~ "",-'~-'- ,;.' ~'.0'ji ~ r . . 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 800/990-9180 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Servicio de Reference Legal CUmberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717/249-3166 or 800/990-9180 : .{I ~~ili:'li~ll!MhI;"""',",if.t"~~i,'\il.iJdll'ilt~~!1F'l.wd"'''ii'g",,--,'''~,i.i~~!lil~~~ , . '"~''' L'~'"'-"';'1l~ili~~-"";"""''''''~->''''' FIr V, \.j';1, I' .< n ~ ~ , .,', .> ("',)'I'd , ,~) l " ( .:1,. "I 1\\, i',"tir't rD, l.u~ ,n~:r '0 'L UV J.ljiJ!ii18,~;:.~ I , 1j~;~ U~3HH1~- '~Mh '. .~j:~J .Jl:~~1I.:!lt' 1!ml' . ~ ~ ~ ii !~ : i1 ~ ~;<- .," ~~~~ ~~. , j "~ " . . . .. ,,;:"";" - . ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: -~ ., o<.-~wi;;@lli,*,{ I t I I BEGINNING AT A STONE CORNER ON THE SOUTHERN SIDE OF THE OLD TOWN ROAD, SAID CORNER BEING ON THE NORTHERN BOUNDARY LINE OFALARGER TRACT OF LAND OF WHICH THE WITHIN DESCRIBED PREMISES WAS A PART; THENCE NORTH 57 DEGREES 15 MINUTES EAST, 158 FEET TO A STAKE ON TilE NORTHERN SIDE OF SAID ROAD; THENCE BY LAND NOW OR FORMERLY OF LLOYD M. BRANDT AND RECROSSING SAID ROAD, SOUTH 41 DEGREES 15 MINUTES EAST, 150 FEET TO A STAKE; THENCE BY THE SAME, SOUTH 57 DEGREES 15 MINUTES WEST, 150 FEET TO A STAKE; THENCE BY THE SAME, NORTH 43 DEGREES 45 MINUTES WEST, 152 FEET TO THE PLACE OF BEGINNING. CONTAINING .52 ACRES, MORE OR LESS; AND BEING IMPROVED WITH A TWO-STORY CINDER BLOCK AND WOOD FRAME COTTAGE. .'. BEING KNOWN AS 167 OLD TOWN ROAD, GARDNERS, PA 17324 10-14-0142-055 PROPERTY ID# TITLE TO SAID PREMISES IS VESTED IN THOMAS R. FORD AND WENDY S. ARNOLD, AS JOINT TENANTS WITH THE RIGHTOF SURVNORSHlP, AND NOT AS TENANTS IN COMMON BY DEED FROM ROBERT L. SHEARER AND ANGELA J. SHEARER, HUSBAND AND WIFE DATED 4/17/97 AND RECORDED 4/21/97 IN DEED BOOK 156 PAGE 151 . . ~, ;,;.;,i,'- '-e ;<.4.ill!!lli~"t<j~"fi:e,"'.;;iM~.'!Mfidm~~;f~':ii:M~Ji!#PH,~~;"i;~,~,.;~W~irl~~~.;iol'~illi ~ ~.. ~, - "'~ ~,,-~ ",~-,~ .~ ~ ~, , ~,-,-- f' =l!. 1 il.bf.i!1illtfrfnlil\ :lI.:;~J:::t-~'-'^'''''i!iJdI~~~IIl~:':-~''''''''''''kiBllllili . << ~."-" ,-->~-, ", ~, ,~,' '-I l.i );1 'I I , !] i-I ij 1'1 li :1 [.1 ~i Ii ~ " ~ I! ~ Ii Ii 11 ~ II Ii Ii " -~".~"y ,.'~ ,~,--" rr . - - -~~- .~~ ~, , ,~- H' -~" -,- ~--- 'ir~---;.o;c:- , -' - WRIT OF E~ECUTJ6N and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) " NO. 01-2765 CIVIL 1ifX TERM CIVIL ACTION - LAW TO THE SHERIFF OF G.nnberland COUNTY: To satisfy the debt. interest and costs due Wells Fargo Hare Mortgage, Inc. PLAINTIFF(S) from Thanas R. Ford and Wendy S. Arnold, 167 Old Town Road, Gardners, PA 17324 DEFENDANT(S) (1) You are directed to levy upon the property 01 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 (allows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than ~named garnishee. you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $82,292.98 from 6/15/01 to 12/5/01 Interest Per dj"'" @ $17 19 - $2,991.06 LL $.50 $1.00 Atty's Comm Atty Paid Plaintiff Paid % Due Prothy Other Costs $116.00 Date: Auqust 6, 2001 Curtis R. Long Prothonotary. Civil Division ~by A~'2.- f? .7t;c/J~J Deputy REQUESTING PARTY: Name Address: Mflrk .1. lIilnen. Esq. 1040 N. Kinqs Hiqhway, Suite 500 Cherxy Hill. NJ 08034 Attorney for: Plflintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 . .. .......:- REAL. ESTATE SALE No. I'D Un Sept. 10, 2001 the sheriff levied uf)on the Oelendant. interest In the real property situated in flcmt-h Miclcll "'+-on '1''''.Mqip Cumberland County, Pa., known and numbered a8'-67 Old Town Rd. Gardners ana moref;li .'c;cribed on exhibit "A" flied with this writ and by this referen ~r.oroorated herein, Date: Sept. 10, 2001 8y:qo~.j~ Re 1 Estate Deputy .. ~ 5i=i7 .' :Jij fi: I VI NVrHl, SIIN3d :-::lC:'..\ \l\;:f-:) 10. HV EE 8 L 30V HNIlC: ::, .1:"110 ..~llJ3HS oHI JG 3J::l:lO -,_"'_1~~~[''li: ." ......~.~~,_.- -' l_J -,~~'""""'~-- _,",-J..,~~ " -- .-)(t~~~l"; >. I ..".. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscineous Book "M", Volume 14, Page 317. ~ PU BLlCA TION ... ................................... ..?...................................................... COpy S his 19th da of November 2001 A.D. #1 0 Notarial Seal S ALE Tony L Ru558ll, Notal)! Pu Harrt9illllll, Dauphin County MyCommiSSlonExplraOJune6,2C02 NARY PUBLIC Mamber, Pennsylvania Aasoei tlo a n otNOl4lf9scommission expires June 6, 2002 , 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 $ 205.44 1.50 206.94 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... REAL gsTATj; SALE No. 10 ~::;:=- -T Will No. 2001-2765 c~. c-,.., ClvllTerm ~:-....::~ ~ '"Wells Famo Home :~~::._- ~; ~Moi1gahQ, Inc. flk/a ;.:-::~---+. Norwest Mortgage, Inc. 0=== ," ""_:~_::___:__ _' v~ ~:-l 'ThomasA,'Ford- k, ,~ :-WendyS.Arnold iiio~'~':,-----AttY: M~rk J. Udren ~__ON. . _ ~ATI.-_ T q~R~,tr?Ct.Qr land with 9ff!P!oVemeQts fueIC;$ em;:ted Sltuate io'South ~aateJOtl, _ l'QW~P, Cumberland County, ~:iifvanla.:~unded.and described as follows: ~ . JNNING at a stone COOler. otl.lhe southern ~de"':'QLthe qd. 'I:9wn Road, said corner being on ~.ii~.!>PPndarylineQfalargertractof DM-y~w~ich_ the within described premises "vas iFa~ -It. thence north 57de~ 15 minutes east ft ~Ieei.eet to. '. Jiuike. OR the J1Qrthern Side.o f said '-!t_tPence O,y laPd now 01 formerly of Lloyd - -g-r;mdtand~jlJgsaidroad,south41 fd'ei...e.es ,Ji-mlJ1.!ltes.,..east, 150 feet to a stake; !1lience . .e-O",'iplJJb, 57 degrees 15 minutes . bJ'iliesame. .to.the _1;gltoi~~'~_ iU~~<n-cjm!~J2Lcd_and_ ooocL !S:e~_ _, __~ __.KNQW~L~ _1'7 Old ToWlLRood. -:~3r _ners,-B\, 17324._~ ,ERill'ERTrID #IO-fMlI42-055. ~;-TITI.E.lo saidflremis~s is vested in Thomas R. .~ ana-Wendy S. !..rnold, as joint tenants with ~~tlie.4ghtl.s.urvjvorsh:iP' and not as _tenants in :: ~omrn.QiL de~ rrom Robert L. Shearer and ~gJa-J. .ejl,l"er,bu~Mdandwi!e.dated4l17! i'W"illld recmded 4121/97 in Deed Book 156 Page ~L. . .. , " "-"-"- '_~:~Dr ~'..' ..'" 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 ofthe 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, VlZ: October 12, 19,26,2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 NOTARIAL SEAL LOIS E. SNYDER. Notary Public CalIlsIe Bow, CUmbelland CountY My Commission ExpIres March 5. 2005 ,,,,' ~,--, ~,-, . - ____..10 Wl1t No. 2001-2765 ClvtJ Wells Fargo Home Mortgage. Inc. flkla Norwest Mortgage. Inc. vs. Thomas R Ford and Wendy S. Arnold Atty.: Mark J. Udren ALL TIiAT CERTAIN tract of land with Improvements thereon erected situate in South MIddleton Town. ship. Cumberland County. Pennsyl- vania. bounded and descrlbed .. follows: BEGINNING at a stone comer on the southern side of the Old Town Road. said Corner beIng on the Northern Boundary !lne of a larger tract of land of which the within de- scribed premlses was a part: thence North 57 degrees 15 mlnutes Ea8t, 158 reet to a stake on the northern sIde of said road: thence by land now or formerly of Uoyd M. Brandt "nd recrosslng said road. South 4'1 ~ US ..... 1fMt. 110 feet 10 a stake: thence by the sa_. South 57 degrees 15 mlnutes Weal. 150 feet to a stake: thence by the same. North 43 degrees 45 mlnutes West. 152 feet to the place of be- glrUlIng. CONTAINING .52 acres. more or less; and being Improved with a ~ stol}' cinder block and wood frame cottage. BEING KNOWN AS 167 Old Town Road. Gardners. PA 17324. Property 1011 10-14-0142-055. TITLE TO SAID PREMISES IS VESTED IN Thomas R Ford and Wendy S. Arnold. as Joint tenants with the I1ght of suMvorshlp. and not as tenants 111 common by Deed from Robert L. Shearer and Angela×J. Shearer. husband and wife dated 4/17/97 and recorded 4/21/97 In Deed Book 158 ...... 151. t~ ~ . .". :1,.." l><'m''',. ,,~ .' "," _'. ',~^'"o