The URL can be used to link to this page

Home My WebLink About01-03257 '~- ~ ,-=~-. ""'~'" "~ -J..~ , "I'~ ''''''''~_'llmotJl~'''''-~~, ^ 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 3200 S.W. Freeway, Suite 1422 Houston, TX 77027 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Jeffery E. Detrick a/k/a Jeffrey E. Detrick Carol A. Detrick 555 Browns Lane Elnola, PA 17025 Defendant{s) : NO. or 3:2-57 ~ Ie-- 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 a,nd a judgment may be entered against you by the Court without fu~ther 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~'" -.~ .. ~ ~ o,~ ...L.~~ ~ ~illllIM4.d--b.i 4~!Iio' ~""~ 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 previo 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 listed. 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 DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 ,"_. ""~ -~I=J,~ ~ ., ; . ."-,~=.' "" liill~B~'---"""'~ NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion ofit, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This lawlirm 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 " , " ~ ~ ~,,~ -""-' l ~,' ~~ ....... "'~~ ""'~I~_'t&'fu\\<"'l!il"",""'",,~ Assignor: Union Federal Savings Bank Assignments of Record to: Washington in Interest to Bank United Recording Date: 08/28/96 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: of Indianapolis Mutual Bank, F.A. Successors Book: 528 Page: 837 2. Defendant{s) is the individual designated as such on the caption on ~ preceding page, whose last known address is as set forth in th~ 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: 555 Browns Lane Enola, PA 17025 MUNICIPALITY/TOWNSHIP/BOROUGH: Township of East Pennsboro COUNTY: Cumberland DATE EXECUTED: 05/08/95 DATE RECORDED: 05/11/95 BOOK: 1262 PAGE: 285 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 " "= ~. .... 0 ~ .~'"'"-'...~~ . ''''-._=,,~,_ -^~. .joJ'jjj~,>Iu'-~~~.Ii11!ijlii:: breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of OS/23/01: Principal of debt due and unpaid Interest at 9.25% * from 10/01/00 to OS/23/01 (the per diem interest accruing on this debt is $29.08. and that sum should be added each day after OS/23/01) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/{Balance) (The monthly e~crow on this account is $179.84 and that sum should be added on the first of each month after OS/23/01) Late Charges (monthly late charge of ~46.72 should be added on the flfteenth of each month after OS/23/01) NSF Fees Other Fees Attorneys Fees (anticipated and actual to 5% of principal) $113,190.21 6,833.80 250.00 280.00 427.29 286.33 15.00 41. 00 5,659.51 TOTAL * This interest rate fully set forth in $126,983.14 is subject to adjustment as more the Note and Mortgage. A'~'''''''~~" ~~ .. . ~ ~,." """- ~~ - ~~j ., , ~ ~- ....~-. t, P-' - -- "'"'&'nl-:illi1ii1'fl;,'.i&~' 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 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 $126,983.14 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 ~;"""I'''' -"1 . ~. . ~ ~I "'~ ~....... -gr,;-~"""l'O"k;j'" / ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT. BEGINNING AT A CONCRETE MONUMENT ON THE EASTERN LEGAL RIGHT OF WAY LINE OF GREENMONT DRIVE, AT THE SOUTHWEST CORNER OF LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF LOT NO.9, NORTH 59 DEGREES 39 MINUTES 27 SECONDS EAST, A DISTANCE OF 100.00 FEET TO AN IRON PIN AT THE SOUTHEAST CORNER OF .LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, THENCE ALONG LANDS NOW OR LATE OF GIUSEPPE SGRIGNOLI, SOUTH 30 DEGREES 20 MINUTES 33 SECONDS EAST, A DISTANCE OF 101.18 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT. HAVING A RADIUS OF 125.00 FEET. AN ARC LENGTH OF 7.77 FEET TO AN IRON PIN; THENCE CONTINUING ALONG SAME, SOUTH 74 DEGREES 39 MINUTES 29 SECONDS WEST, A DISTANCE OF 76.52 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 25 FEET, AN ARC LENGTH OF 32.95 FEET, TO AN IRON PIN ON THE EASTERN LEGAL RIGHT OF THE WAY LINE OF GREENMONT DRIVE; THENCE ALONG THE EASTERN RIGHT OF WAY LINE OF GREENMONT DRIVE, BY ANOTHER ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 175 FEET AN ARC LENGTH OF 1.60 FEET TO AN IRON PIN; THENCE STILL CONTINING ALONG SAME, NORTH 30 DEGREES 20 MINUTES 33 SECONDS WEST, A DISTANCE OF 56.63 FEET TO A CONCRETE MONUMENT, THE POINT AND PLACE OF BEGINNING. CONTAINING 8.732.92 SQUARE FEET, MORE OR LESS. BEING LOT NO. 10 ON THE FINAL SUBDIVISION PLAN OF PENN HILLS, SECTION 1. DATED MAY 30. 1990 AND RECORDED OCTOBER 3, 1990 IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 61, PAGE 79. BEING IMPROVED WITH A DWELLING KNOWN AS 555 BROWNS LANE. UNDER AND SUBJECT TO ACTS OF ASSEMBLY, COUNTY AND TOWNSHIP ORDINANCES. RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICE COMPANIES, EXISTING RESTRICTIONS, AND EASEMENT, VISIBLE OR OF RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THERETO. """"-'"!iO<'..; ,~ ' "~~..~" , ,~ ._-~ ~-~--- . '*-ilo .II f/f}57u:31 , 'perf-fl.{ 'J::. DATE:_February 27, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!'a!!'e on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the . attached pa~es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to helD to save your home. This Notice exolains how the Dro!!'ram 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 with vou when vou meet with the Counselin~ A~ency. ' The name. address and ohone number of Consumer Credit Counselin!!' A!!'encies servin!!' vour Countv are listed at the eud of this Notice. Uvou have anv questions. vou may call the Pennsvlvania Housin~ Finance A!!'ency toll free at 1-800-342-2397. (Persons with impaired hearin!!' can call (71'1\ 780-1869), Lt1 111 ru "'" 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 ney in your aref' .. n..",Lh"r~ssodation ..:-h . ble ..J] Retum Receipt Fee ru (Endorsement Required) C CI Restricted Oelivwy Fee (Endorsement Required) Postmark H... ES DE SUMA NDO EN St.;:::: IFICACION ru ESTA AGEl"'" S AL NUMERI ~ RESTAMO P:;;. MORTGAGE, LA PERDIDJl;i: c c rr .JI _$ "'" CJ Certified Fee Postage $ Certified Fee Return Receipt Fee (Endorsement Required) -- Restricted Delivery Fee (Endorsement Required) Postmari< H... c C .JI t:J .~~$~~::'.~ri~:.C::~S~~Z:bYmaiWrl t:I Street,AptNo~Box~ . ?:. u .-K-...mh_nnh_munm C C "'" Total Postage & Fees $ ~ Total Postage & Fees $ .JI Page 1 of 5 CI .~a%L:~~:.:l>.7!:.~;j~~_~~.~:~nnmmn__n c $treet, Apt No.; or POBox No, c c:J 'Ciij':siiite:ZIP+4...nn.u-on.-_n.n.h.___nnnnnnnn.nunn.nnu-nn~n~ "'" 'i:5;i;:Siire.'Z1P~""-._--"'.'-'~'---""-"--..'--"-'h-n..--....--.....__......_._.... PS Form 3800, February 2000 See Reverse for Instructions EXHIBIT P,) Form 3800. February 2000 ,See Reverse for Jnslru '"~ '" -.~~ ~ ,,, ,..,r..",,~~ HOMEOWNER'S NAME(S): Jeffery E. Deitrick Carol A. Deitrick PROPERTY ADDRESS: 555 Browns Ln. Enola, Pa. 17025 LOAN ACCOUNT # : ORIGINAL LENDER: 6057037 Union Federal Savings Bank of Indianapolis CURRENT LENDER/SERVICER: Bank United 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 ACf OF 1983 (fIlE "ACf"), YOU MAY BE ELIGffiLE 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 consumer credit counseling agencieS listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YDUR 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. 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 teleJ?hone numbers of desi at consumer credit counselin a encies for the coun in which the ro e is located are set forth at the end of this Notice. It is only necessary to sc edule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature. of your default.) , If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out , sign and file a completed Homeowner's Emergency AsSistance Program Application with one of the designated consumer credit <;ounseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for !he program and they will assist you in submitting a complete application to the Pennsylvania Housmg Finance Agency. Your apphcation 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 TillS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. . Page 2 of5 .-.J ~- .iIJil........-"<\ii' . j ~--.". - ~",''''''""-^~" ~"::rI~;iJr.:! A~ENCY ACTION - Available fun?~ f?~ em~rg~cy mor:tgage assistance are very limited. They will b~ disbursed by the A~ency under the ehglblhty c~t7na esta~hsh~ 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 abo~e. you will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. . NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TillS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have 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: 555 Browns Ln. Enola. Pa. 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due; November 2000 tbm February I. 2001 Late Fee's (2) (al (2)(al $ 1.152.55 (each) $ 1.168.08 (each) $ 192.89 ($46.10 each) Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $ 21.75 (property inspection fee's) $ 4.855.90 B. YOU HA VB FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot apolicable): HOW TO CURE THE DEFAULT - You may cure the default within TIllRlY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $ 4.855.90 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIlE TIIIRTY (30) DAY PERIOD. Pavrnents must be made either bv cash. cashier's check. certified check or monev order made oavable and sent to: - Bank United P.O. Box 4864 Houston. Tx. 77210-4864 You can cure any other default by taking the following action within TIllRlY (30) DAYS of the date of this letter: (Do not use if not aoplicable.) 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 ril!hts to accelerate the mortl!al!e debt. This means that the entire outstanding balance oflhis debt will be considered due immediately and you ma:( lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due IS not made within THIRlY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed property. Page 3 of5 ,"-c_r""'ii1~~ I!f~ ~~ I, '0' ,~ w ~I<~ '" ,~ in "'" ~'ih&dk'-"".."_-<icli.< IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attomeys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attomey's fees actually incurred by the lender even if they exceed $50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY Deriod. vou will not be reuuired to Dav 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. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the l1IlRIY (30) DAY period and foreclosure proceedings have begun, vou 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 mav do so bv 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 anv other costs connected with the Sheriffs Sale as specified in writing by the lender and bv performing anv 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 Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. Y ou'may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Bank United 3200 S.W. Freeway, Suite PT-1442 Houston. Tx. 77027 800-395-9803 713-543-3969 Charlotte Johnson or Tim Adams Phone Number: Fax Number: Contact Person: EFFECT OF SHERIFF'S SALE - You,should realize that a Sheriffs 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 Sheriffs 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.lL may** or _ may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstandingpayments, 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. ** Assumption may be subject to credit approval and or other conditions Page 4 ofS oJ"''''.'''~ilro '......- , < b~~,"~~, " "___~ "' .....~~"'..~~_ ~" ~"I~' ,~~- YOU MAY ALSO HAVE THE RIGHT: . TO SELL WE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIIER LENDING INS1TIUl10NTO PAY OFF TIllS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HA VB WE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HA VB TIllS RlGHT TO CURE YOUR DEFAULT MORE WAN TIIREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT TIIE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER TIIE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTIIER DEFENSE YOU BELmVB YOU MAY HA VB TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER WE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Enclosed, please find a list of all Counselinl!: Al!:encies , Page 5 of5 ,~ ~ '""0' - -, <".' "" """';? ,-~ '--~h-'-' . . V E RTF I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading. are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Udren, ESQUIRE MARK J. UDREN & ASSOCIATES ~~~~i\hl.1lli1iliJ;)M:Ri0ii~rili~""iill!I1'il:l&'r~\"'1'(&~.l'" Jf:(~,~;"-,, .'hl;fi""'&i/\.J:\~"",,*,$i_'~,~Ol!liII_{l"'i~-!r~~-'~~'w.J:~~ij;:itdliOJ J '~~ ~ "'-. ~R ~ ~ ~ -.: -4:.. '" \sJ \1\ .... ",,-~."-~-, --'".~..".- ,,, "--,,. _ ,,,,',_?',~_","'-<0'~~"',""" .".~~,','~_ _ ,__~ ? ~_ .c;_ ~, ~ "~, "",~,",, .."~ ,-~~ !'~ - , v, . ."<:: ~:-; l--- -,..' iir l ~ [1 -~. '011 . C-) n " ',) \.:.; (') :..oj - ,,) .'- '-,) ~n'l ~<! ::u "" :::> '-.J ~ ~ ffi .\. ~ ..( .{:; ~\ ~ P ~ e d t f4 - -"'---~< H - l . ~ "~ ~ . -.. -.J "--~"'lIiiiiii1 ,..""""'" '~~k> . MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CH~RRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 . . NO. 01-3257 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 I 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 5/24/01 to 11/13/01 Late charges per Complaint From 5/24/01 to 11/13/01 Escrow payment per Complaint From 5/24/01 to 11/13/01 TOTAL $126,983.14 4,513.56 233.60 1,079.04 ~132.809.34 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. & ASSOCIATES DATE: ..1.~() t{-/ ~/")(')I AS '~CATFD ~ Afl~ 12 PRO PROTHY DAMAGES ARE HEREBY ASSESSED ~-- "" , .~. I ~ _-oJ ~ , ~iIililIIi~~'ii MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, F.A. Successors in Interest to Bank united 3200 S.W. Freeway, Suite 1422 Houston, TX 77027 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. DATED: TO: Jeffe~y E. Detrick a/k/a Jeffrey E. Detrick Carol A. Detrick 555 B~Owns Lane Enola, PA 17025 Defendant{s) June 22, 2001 Jeffery E. Deitrick a/k/a Jeffrey E. Deitrick 555 Browns Lane Enola, PA 17025 NO. 01-3257 civil Term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. . UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE 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 NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLEC1' A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,- i7, ' .-- "" ~ ~ . ~~~ ~. ~- :J. *'*~ " --~l'-._~;'''''~~''''- mu MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 10.0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, F.A. Successors in Interest to Bank United 3200 S.W. Freeway, Suite 1422 Houston, TX 77027 Plaintiff ATTORNEY FOR PLAINTIFF ~ COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County v. DATED: TO: Jeffery E. Detrick a/k/a Jeffrey E. Detrick Carol A. Detrick 555 Browns Lane Enola, PA 17025 Defendant{s) June 22, 2001 Carol A. Deitrick 555 Browns Lane Enola, PA 17025 NO. 01-3257 Civil Term IMPORTANT NO'l'ICE yOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE 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 NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i.. ' , ~ , -" -- ~ ,"" "'~"U'iiLtl: )ii,; MARK J. UDREN &: ASSOCIATES BY: Mark J. udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, F.A. Successors in Interest to Bank United 3200 S.W. Freeway, Suite 1422 Houston, TX 77027 Plaintiff v, Jeffery E. Detrick a/k/a Jeffrey E. Detrick Carol A. Detrick 555 Browns Lane Enola, PA 17025 Defendant{s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-3257 Civil Term STATE OF AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF N~~~ C6..Mck n SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant{s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Jeffery E. Detrick a/k/a Jeffrey E. Detrick Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Carol A. Detrick Over 18 As captioned a Unknown Sworn to and subscribed ~~. N tary Public ANDREP, SCHABER NOTARY "t", '" Of NEW JERSEY . .' C' 0092003 MyC""'''''.J~,ull(;;xplres ~", , " ".' ;;une: rn~. '\l::i.-€t\ l ~'ct: ]. tle: foc- la;",,\; ff Company: . \JJt"e/\ ~ 7\s""",c.\c4g -El~~i!l~~lililllif~M~lil:OO~~j_:&iilii!lliii.'Atiii:i.a.ffi"~i'l"~i,-~,,~,"~.s;'''~l~,j~~~1JM;">li~I'HII"'1Jo!l.lll@4li1\>:1:il\'o\1I_/;j~~"--' ""'"~, ~--"';"'". ~ ~-, <- k,i , , " ,.. f (') 0 0 (') ~ C -q t ~ -offi - -- 7i ...a mrr' 0 ~'I- Z',; <: :i7lp <A.. , Z- g Ci5S::: ~-,~~p1 j:5i;" m ..u'y ~ r ;,:::c; -0 ~:=:jC) ~ ~o 3 ?S=f} ~ r pO ~ :ZM L ~ c 0 :z: ,-; =<! t..) 55 0 -< ~ ~ -,~, ~ ~,?~ .... ,~,=_,,_"", ",~~r~~'__>~~,,"...~,~__ '___ c~~ -," if MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY'f::L.D. NO. 04302 1C#~ N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 Defendant{s) TO: Jeffery E. Deitrick a/k/a Jeffrey E. Detrick 555 Browns Lane Enola, PA 17025 .' '..&u<-L"'''Oll!!!il;i <.... Ili'W'L4t~jG,,"'h,*- ' ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3257 Civil Term NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ~ Judgment by Default Prothonotary 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 ,T Udren. Esquire At this telephone number: 856-482-6900 ~~ ~"''' '(" ~~, ~ ~"'"' , o..""",~., ~~~, MARK J. UDREN &: ASSOCIATES 'BY: Mark J. Udren, Esquire A'1"T'lTLD. NO. 04302 1lf40 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 08034 856-482-6900 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff ATTORNEY FOR PLAINTIFF 500 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. " , Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 . . NO. 01-3257 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 I 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 5/24/01 to 11/13/01 Late charges per Complaint From 5/24/01 to 11/13/01 Escrow payment per Complaint From 5/24/01 to 11/13/01 $126,983.14 4,513.56 233.60 1.079 04 TOTAL $132.809.34 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. & ASSOCIATES DAMAGES ARE HEREBY ASSESSED AS '"(1CATED ~ H7-b,~ t. PRO PROTHY DATE: /I >)U 1<- ~IY>{ ~ ~ --,- . -~ ,,:'_l~_iliiiM'.' ;"~r."ffiW,~,,';": MAIq J.UDREN &: ASSOCIATES ~Y: Mark J. Udren, Esquire ~TTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA l7025 Defendant{s) : NO. 01-3257 civil Term TO: Carol A. Deitrick 555 Browns Lane Enola, PA 17025 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary ~ Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 856-482-6900 ~ ~ I =' ~ ~~iEiil~"i ! MARK J. UDREN &: ASSOCIATES -,sY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. 'I 1 Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 Defendant(s) . . NO. 01-3257 civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judg~ent in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer 1;0 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 5/24/01 to 11/13/01 Late charges per Complaint From 5/24/01 to 11/13/01 Escrow payment per Complaint From 5/24/01 to 11/13/01 TOTAL $126,983.14 4,513.56 233.60 1.079.04 ,$132.809 34 I hereby certify that (I) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of is attached hereto. & ASSOCIATES DAMAGES ARE HEREBY ASSESSED AS DATE: /l}y} If.-~ d..C)CYJ . , IND(J;TED A~) PRQ PROTHY Kc.~ 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 Defendant{s) "" "<e>il" ,...,,,,,1, .'~"",""~",;,-,"" "'11lii.:' ..,~"~ I<tJ! ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3257 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $132.809 34 Interest From November 14. 2001 to Date of Sale March 6,2002 per diem @$25.94 (Costs to be added) 2.931.22 $ MARK J. UDREN & ASSOCIATES M rk J. Ud n, ESQUIRE ATTORNEY FOR PLAINTIFF ~";~l!li!>lc~~&l<&""\'''~'iX'''-E,k,;~'':,2li.3jjI:2;~~:;ij,i}j'''j~'-'J=I!i.,,-,\'':"'1;,, ,,!",,~ . -_~~:h,!'-;l!#~,-->' ~J!i'-i...lIiliolI..iIl:W!l~"",il ,~_~"'lk-I!;dijt,,,",,-iim>i'!il:! """""-,.,><",,,,"' - ~_,'_,:6_'_"';-~"^:" ...... ~"""'V-.J ~ "-> ~p ~~ V? ~V)" -..J ~v" . -:-- . . . . . , .. ~ 1l '1 0 C>&d8~8g (') a () C 0 C 'Ti ::::::. ~ I i j ;s:: ;;e ( j -00::; ::::> ~~ ~~ mg; '- "'" ....t z) "'l ZS;; ....0 ~ - - ~ " (J):: eJ", "" Vv " ~ "- ~6 "'l ..", w ~t ~o ::1: -0 ~ ... , " .~ )>c: " "- "- " "- Z N ~ -.. =<! ()) ", ~,,', "'.~^.""_u,. "" ,,,. ."". ,.,-, ,_., h_ '""',___y".~"",.",,," " ~", '-"_","'___",,",,~_~,~ ." " ~ ,,^,~~, -, -- '-+-' -'~ ' -~ =~ ~ _r_ --';1 II I I ~ :s .... -- " ""-~ 4~)I~fWi~'~1imki MARX 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 - . NO. 01-3257 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating .to unsworn falsification to authorities. ""'A~T","-~''',::!i'"'_''%f,"'H'''>t~M~~Ii,IM!li~'I>il!!I"j.~i;Jl<'MtiIJii~,,.-j--' 0'. lli~""'''-'"'' _I.J:,,,,,,,",,,,,,,,,,,-,,, ,~"~" ~(J~ ," "_,="'t?('o,y",,,"_,'~~''''_''''_'''''~',T~'''?p,, <0" Cl, .."" .~ ~, _7__ ~ _ ~ , ," '"',' ,'-~Y" , ",~_, :ti --," ""'1i"."~' 0 0 (~) C -1'1 s: - : ~:3 ,"- ""OW 0 mm ,cC " i" Z"""l ~s; -CiCJ (To :,:;,J'-,"-> "<-,, '::-::'~t ~CJ "" - ~8 ::'3: ~;,~~ f:;s I:-? or" )>-c -. ~ N :> (Xl ~ -. ~ .,- -~ - '"-- Il~ ~ " , ~" "~",d",;,,", ~~"i ~ ~ 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555-Browns Lane Enola, PA 17025 . NO. 01-3257 Civil Term Defendant{s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, F .A. Successors in Interest to Bank United, 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: 555 Browns Lane, Enola, PA 17025 1. Name and address of Owner{s) or reputed Owner{s) : Name Address Jeffery E. Deitrick A/k/a Jeffrey E. Detrick 555 Browns Lane, Enola, PA 17025 Carol A. Deitrick 555 Browns Lane, Enola, PA 17025 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 ,~-~- ...."''''"~" ".......'dltllilll _..,~ - "' ~,,----. " ~~,~ ,;' , -';iI:ldlI d' "'....mzl'\.<J;,-' ' i' ....4. Name . record: Name and address of the last recorded holder of every mortgage of Address Plaintiff herein. See Caption above. Commercial Capital Corp. 25 West 43rd St., Ste 900, New York, NY 10036 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 555 Browns Lane, Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.. sec. 4904 relating to unsworn falsification to authorities. DATED: November 13, 2001 \ ren, ESQ. fo Plaintiff ;;'~~!li*.WI;fd.~k"""i'i,~-,~fii,jRi1l~jff!iiii""-t.;ili,Ji!~':*,i';''''l' :",,,,',,,,_0\ ~'''~,~",.. ,,,,,,~,,;'i,:,~';i,-< '~"'Nj!i';,'4'''''~'''L~~:!!l!!Io<:4.......!W;,~.H~~N-,-~",~*~~1MIl~~' -~" ,~ -~'"""""'~ 'th.dM~ ~-~ ill .. () C C) C ?,: " l:)CO Z mg' c:> Z "J ~o:::: __:n Zr r.,.: (/).1> (J> ;~!(;:J _...-;~~ kO 'D '-:::~(~) ~o ~;''''T, :l: ':..,;:;:-('; ;r;f: :;do ~ (j.rn 2: .,"'"' ~ N 1> m ::0 -< ",'" ",.[,\: JJE.)lJl....J".!J1l]1 ,]1 ..~. ",..,~",,,.-o,,,.,_,' _'''''~'~'' C', ,~"'~.,,",~_","_~'___.',, "__c, , ,., .Co .,.,,~,''''''',<_o ",~_', ~ _~ " ~ <- ,"""" ,~, - =,~ , ~ "," 'llti[,:H"!_j~ilitl "'il""""'i0'*"-<ilairl!1lM4; , , 'MARx 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 . - NO. 01-3257 civil Term Defendant{s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeffery E. Deitrick a/k/a Jeffrey E. Detrick 555 Browns Lane Enola, PA 17025 Carol A. Dietrick 555 Browns Lane Enola, PA 17025 Your house (real estate) at 555 Browns Lane, Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 A.M. in the CUmberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce'the court judgment of $132,809.34, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immedia~e ac~ion~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how ~.~ "" " ." _....~".......,...... - ~ ' """"",,,"--lfu~~'b-.'''~M''-;Ii, I - YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLAeE. 1. !f 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. !f 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 HEIoP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 W';''''-'' njlliW<lll~iiill!lffifl!!t~rIi,1i!aiffiil~~@&l~,"','1l;.:!"2',(;i:'d:'--'" )'-;'~";i' ;",,,,,;il,:,,""~if;l",I)f,>l1!~~_~fi~~-iIo!l;j;fiN.~m.,B'- .~ -~. =_._~~ - \ g 0 0 -1'1 s:: Z -0 o:J c:::> - ':2g) -'c --c; ~:J ~S; ., ,---' 0'" ,'-"- ~e -".., -0 ," " ~n :;Jl: ;~~i~; ~O r:Y be" J>c: -..\ ~ \-":> ;;;; co =< ;,?'"~-"~"~--'~'~I"""'~." ,~.-..'t'~ -'-- "",L, "w"'- '""' _., I -"'M""" ~ '-"~"""~'~", j ALL THAT CERTAIN PIECE OR:PARCEL OF LAND SITUATE IN THE, TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A CONCRETE MONUMENT ON THE EASTERN LEGAL RIGHT OF WAY LINE OF GREENMONT DRIVE, AT THE SOUTHWEST CORNER OF LOT NO. 9 ON THE HEREINAFTER MBNTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF LOT NO.9, NORTH 59 DEGREES 39 MINUTES 27 SECONDS EAST, A DISTANCE OF 100.00 FEET TO AN IRON PIN AT THE SOUTHEAST CORNER OF ,LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG LANDS NOW OR LATE OF GIUSEPPE SGRIGNOLI, SOUTH 30 DEGREES 20 MINUTES 33 SECONDS EAST" A DISTANCE OF 101.16 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 125.00 FEET, AN ARC LENGTH OF 7.77 FEET TO ~ IRON PIN; THENCE CONTINUING ALONG SAME, SOUTH 74 DEGREES 39 MINUTES 29 SECONDS WEST, ,A DISTANCE OF 75.52 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 25 FEET, AN ARC LENGTH OF 32.95 FEET, TO AN IRON PIN O~ THE EASTERN LEGAL RIGHT OF THE WAY LINE OF GREENMONT DRIVE; THENCE ALONG THE EASTERN RIGHT OF WAY LINE OF GREENMON'! DRIVE, BY ANOTHER ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 175 FEET AN ARC LENGTH OF 1.50 FEET TO AN IRON PIN; THENCE STILL CONTINING ALONG SAME, NORTH 30 DEGREES 20 MINUTES 33 SECONDS WEST, A DISTANCE OF 55.53 FEET TO A CONCRETE MONUMENT, THE POINT AND PLACE OF BEGINNING. CONTAINING 6,732.92 SQUARE FEET, MORE OR LESS. BEING LOT NO. 10 ON THE FINAL SUBDIVISION PLAN OF PENN HILLS, SECTION 1, DATED MAY 30, 1990 AND RECORDED OCTOBER 3, 1990 IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 51, PAGE 79. BEING IMPROVED WITH A,DWELLING KNOWN AS 555 BROWNS LANE. , UNDER AND SUBJECT TO ACTS OF"ASSEMBLY, COUNTY AND TOWNSHIP ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUSLIC SERVICE COMPANIES, EXISTING RESTRICTIONS, AND EASEMENT, VISIBLE OR OF RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THERETO. - -'--o-~''''f~~=''"'''''''_'''''''''''''''''_..~ _ ^" BEING KNOWN AS 555 BROWNS LANE, ENOLA, PA 17025 PROPERTY'ID NO.: 09-15-1288-175 TITLE OF SAID PREMISES IS VESTED IN JEFFREY E. DIETRICK AND CAROL A. DIETRICK, HIS WIFE, BY DEED FROM TERRENCE F. DERLOSHON, JOINED BY CAROL DERLOSHON, HIS WIFE. DATED 5/5/95, RECORDED 5/11/95, IN DEED BOOK 121, PAGE 1171. ","',-~ , l" " '-;', x", ""'-';JIIlIi<~;;<~,,;c 1 ... . MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren " ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 Defendant{s) : NO. 01-3257 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 liB". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: .~ ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff Dated: January 29, 2002 -" "-'~ ,', ;-, ~ '.-", '>~e~~)i' y ""' ' "..,---;~;:.\,; . . ,> , MARK J. UDREN & ASSOCIATES BY: Ma~k J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900. Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstqp N010204 Northbris\dge, CA 91324 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-3257 Civil Term v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555 Browns Lane Enola, PA 17025 Defendant{s) DATE: January 21, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick &: Carol A. Deitrick PROPERTY.: 555 Browns Lane, Eno1a, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 6. 2002, at 10:00 A.M., at the CUmberland County Courthouse, 1 Courthouse Square, 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 '--; ~ ~ ~ ~ "U cn~ '" ... '" '" en r; , -n o.~ 0 O'c 3 C7j ~~ ~ ~ '" ~ ' '" 0.0 ... ~- '1l 0'" o' n -n ~ (l) 0 C" 2 ~g III -< Q!!!. ~ ~ <'z '" \""ll.~ '" ... mO' -~ '1l' 00 0_ -'1l Olir 3ln n ~ ~ 0 ,,/~ ~ "::: \1:~ ~ ~ 3 ~ ;;: ; :} - ....\ C" '" ' co 11 n ~, o 5" 3 " 1 w - " co 6' Q. ';i ~ .e. ~ 'tI co :IE :!. - co ."' :; ... o "' ~~'l:I ii'i 3i?~f~ =2;1rn~~ ~1lI Ql 6-~ 2. ~ ~~IJ~ g,~~~ g Stn3= 9. ~ ~3";!sa.Qi llICola,- _ rg~~S!.~~ gQ.~m~f,jI 3"fa-<~I; GiN] 0 ~ 3 -1 g ~ 1lI~C""CI Q. 5=ii'!!l~O ::II 3 -. :::I !l!.=:gl" 3 g:,N2 ;;: ~~~~ ~ -&'9.0~~~ liS!f~ii~ ~t~4l a IlIc8iii'3f" :::ICII(D'lll _ ~g s.~ ~ lQ _ .::: III g.S~33i=5' III ~;=~~i .a a.g: 1II ~<i1 i~i~!~~ "CIn--< CII -<0::1] iil o o.g'Qj'" a. ~~~1tI~ ~;;;-g ~ ~::ltr ; lD3'ia"l:l III a.ai:d!;f~' i3"~l!l/IEi~ 5t~~~~3. iti.~3S~ I: B:cna ~~ -allllll:r-!'::1 1ll::::;1lI1l1~_ g ~f?3~. :g iii"::J rn ~ . limeD ai -wi CI' goo III L Dl ~ "Cl o :i"' - "Cl co ::l " ~~!Iljldl;!_r~''';''-~~~I u >~~,1!il!-,~""",!'. '" '" ... w '" ~ .- Q>ir ~ ~ '" ex> ... S' ~ 0 ~ (nc'3 . CD Q- (l) 0.0 ~ ""'" "0 0 c,,,,,, o~ c " z> ~cnc.. ~;::;: 3 ",g- O' ~ ~3: "'" ~ O'<l. '" or ~ m T 0 ~ ,- ". L' /Jr~>"'2 r-/r"-) V ,xA. ~{-;<, - ~ ;t44 N\H"- ~ ,~ J~Q;' , <i?" c;; . i ~''-< L <iPJ ",r-,oO .~\: V- I'-. :.;..0 . . , I O1-1::I:CJ() 0'l(D l>>i:: 0 O1i3.Cil3 [JJ:::I en III 3 a arO"'C 0 ~ oc3 a ~ :J ,,~ (") CD ~2"'Do!!. l>>'t:l>3:s: ~ ~ ~~o - .-...... Q) - mCllN::J1] ~ <>>g> o b~ 4 or coaa ~ ACD CD 1] 0)"5'- i :: ;"g Cf ~~ ~ rr: ~-:: O)a (oJ ;0 ~ < " " c ~ p, " ~'~ "'. ~ ~~... v . ~~ z3 ~ ;:~ ~ n 0;0 (liS!. , m en= ...g . 0 oen ~g (") en e: Q) .CD g ~ ;g go l1S.P I ~;o om o !!!. Cm "'0 ::rli g- o ~ '" -; enm .oX co m" ''0 .SD... " > ~ " o Z ~' ~ o o '" '" ~, :'-'" 1:;1 "..l",' '..:11 , "'1. ,> )~, "'C) "'0 ::;3 '" 3 "''' -~ ASJo wm a- eno _m , '0 eniii' (DC:; <00 o~ ~O"!J z ~ ~ ?C Z m 3 ~ So is: 0. a o o ~ .~ en ii .!!. m ~ 0. '1l o !!l. ~ :I> --:II ~ ~" m 0>- 1: zc> -<;(/);';0", c-:Ilc; Jl:-zmc ;=ii/G>z,," r",Cf.lIl<>:I! ~8~~~ Cl ::I:Oltl) ~ :e8 ~ ~> iri 00 ~ n m is: 0. a o o DODD {){)3";%J CD Den CD a:o~~" if l!.;- 0. , m 0. '1l o " Ii " ~ DD~D ~~g.&, ~ i[[ ~ ~ iijO;o_ ~ 3:[ (II ~ CD !!oCD CD -0. -S" a - l!- Q' ::c ~[OO~9 ca = <::: ~<go ~ CDeS ~;:;,!e.~ :::r:::rCDlU o --aiil '0 c: 0 0.'0 -:::)>';~3:a ;;~g!!!.!!.~ (II < liS":":"!a, lQ lU -en CD (irc:rc: C'" ':""CDeni>> 5" C ~ n ~ n "" <5' ::J CD a- m ~ g ~ !i~ a;:> c . _CD i Oen. OCD ;+ o[ Q !!l i ti' "Tl;%J ~ CD;o~ m. '" ~ "TlCIJ'S" CD b- ~. ltg"~ e:a:x a-~!e. ~ m m !!.<D'3 no" o -::r i's ~ 0= 03';:;; -lCI c;r :To en c;r:::.li 0'00. ='""m o "en g;t: ". :II~ 1:)J~J8IT A ,i1lIMi.fn'flil\L~i!m~~!fflj~!!Jll:-'i!!!li1!:iii:,m~~"~~l*~'!.k'l!;S_'.Z<"-' ~~> ~ ',,,,,, ',"'^,-","~-~< ,",>.>-'-' ..-,<- '-",~","",""-" .-'. --"'"""",,, " -~-,~~- -" ~," ~->"', ,--- ">="^'''"'~'' " ,~, , ,~,-"',~ ".."-,,;',,,-,j~1S1M!,~~tifi!!>l.il!.mhi,,!!llf~iIM~~_l9illllili,~&rJl~.:11!i'r;nl~~"' UJ ,,"' o c <" -u ti1 [l) L~'! .!...,~ ' ~~~: r;::C: ~C) ~d c z =2 "_00_', ",,~""". ,~," _4 , ~ ~~ , ( c:-' r.v (- ::'2'> c) ""1'1 -,---, .,.... ,..:> , ~:~:; -0 J: ,,-,',.-. ~,-=-, I'j a:- ..,.. ~~ ""';:o.\",; (:Sfn -I ~ :D -< ~ ~~ ,=_. , , j + STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } SS. Robert P Ziegler I, ____________________________________________________..________________________Recordetof Deeds in and fot said County and State do 'herd>y certify that the Sheriffs Deed in which ___'-____________ Veterans Affairs Secretary ___________________________ _____________________ ____________________________________ is the grantee 5th the sa....e having been sold to said grantee on the __________________________________________u___ day of __________________.J!I!'.!'___________n_____ A. D., r _~~__, under and by virtue of a writ______________ Execution . 16th ____________________________________ _____ __ _____155ued on the _____________ _____ ____ ____ ______ __ ___ Nov day of ______________________h__ A. D., Civil ______________________________.._________________ -________ _______ ______ ___________ Term, : . 3257 Washington Mutual Bank F A Number ______________, at the suit of _______________u_______________________________u_____________ . Jeffrey E Deitrick aka Jeffrey ~ Detrick & ___________________________________aga;~~----------------2031ia~~1"--A-~r1~------------ ~ duly recorded in Sheriffs Deed Book No. __u_n_____' Page ____________. 01 . -____, out of the Court of Cornman Pleas of said County as of 01 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ____6!..___ day of _______~---------------- A. D., ')-.o.c:_?;: -'0.:4~---t0-~-~--~ Recorder of DeCd& t-~~~':'==& ,- " I-~w" ,',' _:':r,,,, . Washington Mutual Bank, F.A., Successors in Interest To Bank United VS Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick and Carol A. Deitrick In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3257 Civil Term Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on November 21,2001 at 6:32 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick, by making known unto Carol Deitrick, adult in charge, at 555 Browns Lane, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copy of the same. Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on November 21,2001 at 6:32 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Carol A. Deitrick, by making known unto Carol Deitrick personally, at 555 Browns Lane, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on January 04,2002 at 9:35 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick and Carol A. Deitrick located at 555 Browns Lane, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick., by regular mail to his last known address of 555 Browns Lane, Enola, P A 17025. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Carol A. Deitrick, by regular mail to her last known address of 555 Browns Lane, Enola, PA 17025. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5' 2002 at 10:00 0' clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren for The Secretary of V eteran Affairs, an Officer of the United States of America, its successors and assigns. It being the highest bid and best price received for the same, the Secretary of Veteran Affairs, an Officer of the United States of America, its successors and assigns of 5000 Wissahickon Ave. Philadelphia, P A " ~ .~ ,1 ~t't,,_M.\!!;-'-"__, 19144, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $1090.66, it being costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Service Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 21.33 15.00 15.00 30.00 10.00 .50 1.00 19.50 .82 15.00 30.00 20.00 437.45 366.30 24.20 25.00 29.50 $1090.60 paid by attorney 6/26/02 Sworn and subscribed to before me So Answers: This Iltw dayofQo. r~ -"<'~~ ~ R. Thomas Kline, Sheriff 2002, A.D. C}Jth;n~:'I;'" ~ ByJ odJ.{ JrnlfG Real Estate Deputy ~~ 30'~ ,.-,A) CJt.. 3'7/33 ~p1J10 , " ~ '~"Ir~---'"' ''-'M>\JIUllii@''t' ~. ... .. MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire "ATTY I.D. NO. 04302 1040 N. KINGS ~IGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 . . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff \ ! v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. Deitrick 555. Browns Lane Enola, PA 17025 . . NO. Ol-3257 civil Term Defendant{s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, F .A. Successors in Interest to Bank United, 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: 555 Browns Lane, Enola, PA 17025 1. Name and address of Owner{s) or reputed Owner{s) : Name Address Jeffery E. Deitrick A/k/a Jeffrey E. Detrick 555 Browns Lane, Enola, PA 17025 Carol A. Deitrick 555 Browns Lane, Enola, PA 17025 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 """'. ~ ~ ~~ " '~~"'"""'~~ '!iIIIl ~- '"" I, -... ",'J''eJhglllliio~,~~ "C-~~~Ai " . "'\. Name and address of the last recorded holder of every mortgage of record: ~ame Address Plaintiff herefn. See Caption above. Commercial Capital Corp. 25 West 43~d St., Ste 900, New York, NY 10036 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any}record interest the property and whose interest may be affected by the sale: Name Address in Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address , Tenants/Occupants 555 Browns Lane, Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 13, 2001 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 Washington Mutual Bank, F.A. Successors in Interest to Bank United 9451 Corbin ave. Mailstop N010204 Northbris\dge, CA 91324 Plaintiff v. Jeffery E. Deitrick a/k/a Jeffrey E. Detrick Carol A. peitrick 555 Browns Lane Enola, PA 17025 Defendant(s) 't.9i~ J , "~ ~ >~~I .' - ,~ -.J"'""nnJ"-'~ f-ll~, . ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE \ , . . NO. 01-3257 civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeffery E. Deitrick a/k/a Jeffrey E. Detrick 555 Browns Lane Enola, PA 17025 Carol A. Dietrick 555 Browns Lane Enola, PA 17025 Your house (real estate) at 555 Browns Lane, Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square,. Carlisle, PA, to enforce the court judgment of $132,809.34, 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 1\BLE TO PREVENT THIS SHERIFF'S SALE To prevent tbis Sheriff's Sale, you must take immediate action~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (8S6l 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike 'or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how . - --._~,-""-- ' --=.~' ~""-" _ ~ 0"",,_" ~~,~ _~ ~__~"', ~" , d Ii -Jf""~""'- ~ "'''--'1M<~h';'i_" # YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTH~GHTS . 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. $:;t 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 C~erland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~ ~." ,"".,._~ = -"'<<W" c..l ~ - .....,-"~ .=~~;...~,,~~, ~"..... .Itt, "'''''''''f4I!'itl~:I!iIl1''~f"''''lItlll;~M:fPJH,i&>k, j ALL THAT CERTAIN PIECE OR.PARCEL OF LAND SI~UATE IN THETOWN~HIP OF EAST PENNSBORO, COmiTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: ; BEGINNING AT A CONCRETE MONUMENT ON THE EASTERN LEGAL RIGHT OF WAY LINE OF GREENMONT DRIVE, AT THE SOUTHWEST CORNER OF LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE. SOUTHERN LINE OF LOT NO.9, NORTH 59 DEGREES 39 MINUTES 27 SECONDS EAST, A DISTANCE OF 100.00 FEET TO AN IRON PIN AT THE SOUTHEAST CORNER OF ,LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG LANDS NOW OR LATE OF GIUSEPPE SGRIGNOLI, SOUTH 30 DEGREES 20 MINU'J:ES'~33 SECONDS EAST" A DISTANCE OF 101.18 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 125.00 FEET, AN ARC LENGTH OF 7.77 FEET TO ~ IRON PIN; THENCE CONTINUING ALONG SAME, SOUTH 74 DEGREES 39 MINUTES 29 SECbNDS ~ST. ,A DISTANCE OF 76.52 FEET TO AN IRON PIN; THENCE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 25 FEET, AN ARC LENGTH OF 32.95 FEET, ~O AN IRON PIN O~ THE EASTERN LEGAL RIGHT OF THE WAY LINE OF GREENMONT DRIVE; THENCE ALONG THE EASTERN RIGHT OF WAY LINE OF GREENMONT DRIVE, BY ANOTHER ARC CURVING TO THE RIGHT, HAVING A RADIUS OF 175 FEET AN ARC LENGTH OF 1.60 FEET TO AN IRON PIN; THENCE STILL CONTINING ALONG SAME, NORTH 30 DEGREES 20 MINUTES 33 SECONDS WEST, A DISTANCE OF 56.63 FEET TO A CONCRETE MONUMENT, THE POINT AND PLACE OF BEGINNING. CONTAINING 8,732.92 SQUARE FEET, MORE OR LESS. BEING LOT NO. 10 ON THE FINAL SUBDIVISION PLAN OF PENN HILLS, SECTION 1, DATED MAY 30, 1990 AND RECORDED OCTOBER 3, 1990 IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 61, PAGE 79. , BEING IMPROVED WITH A DWELLING KNOWN AS 555 BROWNS LANE. ;'"'""""--.~. UNDER AND SUBJECT TO ACTS OF'ASSEMBLY, COUNTY AND TOWNSHIP ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICE COMPANIES. EXISTING RESTRICTIONS, AND EASEMENT, VISIBLE OR OF RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THERETO. .-- "_'~'C""""""'>""'~.__"~'''''''~'''''''''''''''_'... .- BEING KNOWN AS 555 BROWNS LANE, ENOLA, PA 17025 PROPERTYID NO.: 09-15-1288-175 TITLE OF SAID PREMISES IS VESTED IN JEFFREY E. DIETRICK AND CAROL A. DIETRICK, HIS WIFE, BY DEED FROM TERRENCE F. DERLOSHON, JOINED BY CAROL DERLOSHON, HIS WIFE. DATED 5/5/95, RECORDED 5/11/95, IN DEED BOOK 121, PAGE 1171. '---;;"'~ ~ ~.i-_.", ........._~ ,L ~ ~......J_ '. li\ili;;;/~~-..lli_.>cl'-!>,3"; WRIT OF EXECU'fION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TERM NO, 01-3257 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Washington Mutual Bank. F .A. Successors in Interest to Bank United PLAINTIFF(S) from Jeffery E. Deitrick a/k/a Jeffrev E. Detrick and Carol A. Deitrick 555 Browns Lane Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: . and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee{s) is/are enjoined from paying any . 'd.~bt 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 olthe defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other . than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above "--~ :" :_~!j:!ted. --,-';,' $132,809.34 Amount 'Due L.L. .'i0 Interest from 11/14/01 to date 2,931. 22 Due Prothy 1.00 If sal~ 3/.6602 Per Diem @ $25.94 Other Costs ttys omm % Atty Paid 125.30 Plaintiff Paid ._- Date: November 16, 2001 Curtis R. Lenq Prothonotary, Civil Division by: C)".. , Q ~ , Deputy REQUESTING PARTY: Name Mark J. Udren Address: 1040 N. Kinqs Hiqhwav, Suite 500 Chp.TT,y Hill. NJ 08034 Attorney for: Washington Mutual Bank, F .A. etc. Telephone: (856) 482-6900 Supreme Court ID No. 04302 ~ii;{rf,l{iil.n.~iL*!!IiIiiM&,:j";~c\:i~'ii-i~~,"-k'il!,;,;,,,';;;-B-3:,;-~j1.d_\'J,'~M",irihj ",~,_",,~,.,;.,(;;';;i;:}'jt,-:,>~i1!;ii%',,$ifuijY4~.{i~~Ili_~'~I;fj~lJr'B]!f'~~-~i<I_d~ '. flfl.~~I-' l1~ ~! =0 ftft ~ REAL ESTATE SALE No. 11 [ """'4iF_i I i I ! On November 20,2001, the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A, known and numbered as 555 Browns Lane, Enola, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 20,2001 By/j~ 5rvu:t& Real Estaee Deputy <8 c:v;J C\ii] c=:::::J. (ii) -,,' ...." ~S,,~f3d 'V\~'II ~:',;\'>"J') -1\"'1 ,w ;\ .- ~\ ..\\\\ ~d lit t. \\\.. .' ..~\l\'\\\';l ,,' "~, "\'~o l\(\C'0 .,' '. :10 3.. ~ ).1. "L1~ ~"\\l. ~~\\l'"'' " . !14ry ~) itil' ,fl.F~'; ~~ "~1l ~~J(~~"!__-_.,J_'9<__",,""'~__"""'''",,_',,"''''''_V'~' "'''",-<''''~,,"~M__,_' .^''''~,,''-~__ __ ',~,,_ ~~, ~,__:~_"" ~ " ~ , 1 " "L ill '1"_, _ BSTAIII!l S4WlNO. 27 Writ No. 2001-3257 Civil Washlngion Mutual Bank. FA. Successors in Interest to Bank United vs. Jeffrey E. Deitrick a/k/a Jeffrey E. Detrick and Carol A Deitrick Atty.: Mark J. Udren ALL TIIAT CERTAIN piece or par- cel of land situate in the Township of East Pennsboro. County of Cumberland and Commonwealth of Pennsylvania. bounded and de- scribed as follows. to wit: BEGINNING at a concrete monu- ment on the eastern legal right of way line of Greenmant Drive, at the southwest c()rner of Lot No. 9 on the hereinafter mentioned plan of lots; thence along the southern line of Lot No.9. North 59 degrees 39 minutes 27 seconds East, a distance of 100.00 feet to an iron pin at the southeast corner of Lot No. 9 on the hereinafter mentioned plan of lots; thence along lands now or late of Giuseppe Sgrtgnoli. south 30 de- grees 20 minutes 33 seconds east, a distance af 101.18 feet to an iron pin; thence by an arc curving to the right. having a radius of 125.00 feet. an arc length of 7.77 feet to an iron pin; thence continuing along same, South 74 degrees 39 minutes 29 seconds West.. a distance of 76.52 feet to an iron pin; thence by an arc curving to the right. having a ra- dius of 25 feet. ail arc length of 32-.96, feet. -to an iron pin on the eastern legal right of the way line of Greenmont Drive; thence along the eastern right of way line of Green- mont Drive. by another arc curving to the right. having a radius of 175 feet an arc length of 1.60 feet to an iron pin; thence still continuing along same. North 30 degrees 20 minutes 33 secanq.s West. a dis- tance of 56.63 feet to a concrete monument. the pOint and place of begiI1nlnl!, ." ". CONTAINING 8.732.92 square feet. ~are at less. BEING 4>t No. 10 ou the Final Subdivision Plan of Penn Hills. Sec- tion 1. dated May 30. 1990 and re- corded October 3. 1990 in the Of- fice of the Recorder of Deeds of Cumberland County. Pennsylvania in Plan Book 61, page 79, BEING improved with a dwelling known as 555 Browns Lane, UNDER AND SUBJECf to acts of assembly. county and township ordinances, rights of public utility and public serVice companies. ex- isting restrictions, and easement, visible or of record, to the extent that any persons or entities have aequlred legal rights thereto. BEING KNOWN AS 555 Browus Lane. Enola. PA 17025. PROPER1Y ID NO.: 09-15-1288- 175. TITLE OF SAID PREMISES IS VESTED IN Jeffrey E. Dietrick and Carol A Dietrick. his wife. by deed from Terrence F. Derioshon. Joined by Carol Derioshon. his wife. Dated 5/5/95. recorded 5/11/95. in Deed Book 121. page 1171. ''''' :, , ;-;,~" ~ -=-,. ~ ~ ~ ., ~;.,.J .......~ 'w"~ ~ ~~J&'iEI!&1!&r;, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in t]:le Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and dbsignated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~'E~ SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 N SEAL LOIS E. SNYDER. Nolary Public My= Cllll1l1lllialld County ExpIres March 5. 2005 REAL ESTATE SALE No. 27 Writ No. 2001-3257 ClvilTerm .. ... Washington Mutual Bank~ FA Succesil.~ors In Intarel;t to Bank Unltad .i.:'" vs" Jaffrey E.6eltrlck a/kIaJaffrey E. Datrlck and Carol A. Deitrick :Atty: MarkJ. Udrsn DESCRlPTION . . :ALL THAT CERTAIN pIece or parcel of land "::'Siiilate' lri the Township of East PennsQaro, :,Colirity"'i:ifCiiiiili61and arid Cominonwealth of :'::Pennsylvania, bOunded and described as follows., I,:-ii:i:wit'''''':''''''''''''''''''''''''''''''''''''''''''''' , :::,:::BEGlNNINd" at 11 Concrete tncinument oil the :":"~e.m, le~, right .o~ way line of Greenmol1t 1": 'Drive at.the Soulhwest tomer cif LOrNa. 9'00 the :-Tt~-reinaftm'"menUoned Plan of Lots; thence along '::,:~e'-Soul1:iem line of Lot No.9, North 59 degree.,> : ',)'9 'fuiriiites"l Ts'e'condS EaSt, a distance of 100.00 ,"'feclloan iron pill at,thesoutbeast'cornero(Lot ':' No.9 on. the he.rein'afkr meIitioned Plan of Lots; :'::tbeiice"ii1ong }anos' row' ',OZ' late of GiiJseppe : 'SffiigiiOli, Scii'lh 30 degrees 20 minutes 33 'L:,:::se:Cdrtds East, a distlnce of101.18 feet III an iron ':"::'pin; t'hence at an,aICctlrvingtO'tbe'right, having a rdliius of l25.CO feet, an arc length of7.?? feet to ,an iron pin; thence conth,juing albng same, South : ,14 degrees, 39 minutes 29 -scconds We~i, a :--::::illiiliinc~of.76,52 fecft'o an iroIlpiri; thence by an -::iifC''-'ciifvjrig''"fcl the righ~ having a'radius of 25 !",,~4 an arc length of 12.95 fc,cl"t? an iroupill on -:':"",the Ea~tem ,..legal right of the way tine of " Greenmant Diiye; thence al,ong'llie Eastern right ':of way line of Greenmofl-~"Drive, by another arc 'cunr.ing to the 4gh!, baving- a radi,!s of 175 teet an arc ienglh' of 1.60' feef 'to an fron pin; thence still,contimung alobg' same, Norfu. 30 degrees 10 minutes 33 seconds Wes~ a diStance 0[56.63 feet fu a ,L1Jncrete. moriti'ine'rit; 'the point and place of 3b~ing. ' '" . '!: CONTAINING"""S',13'192" square feet, marc or iress, ' ....... ..., , ,BEING Lot No. 1Q on ,;he ,final ~ubdivi5ion plan ':':ofPenn Hills, Section f, dated May 30, 1990 and ':"'!'eciittied'October 3,1990 in the office of lhe .: Recorde( of Deeds of Cumberland County, ':' Pennsylvaniain Plan Book 61, page 79. , "", BEING mlproved with a dwelfrng ~own as 555 ...,BiOwnsL.arie. ')J.NIil*"and subject to acts of assembly, County .:::"::and ',Township OrdinaI!ces, Rights of Publlc ""Utility ,arid' PU,blic ServlCe <:omparues., existing ;.- i'eiifriCtliin.< al'iJeas~ent, 'v,isible or of record, to ::, the-"'exleilt '''tha't any petsOl!S' Or en'l':lues' have .-"acqui'red legal rights thereto. ',l::: "' " BEING know!,'!. a& 555 Browri.~ Lane, -Enol a, FA ""11'015:"''' " , .. PROPERTY 10 NO,:09'15'l288-175: ":'Tr:rlE to said premises is vc...:fed In Jeffrey E. ," Dleti:ickairifCilrol A, Dietrick, 'his wife, by Deed 'from ~rerrehce F: Dedasllon, jo'inctl by CwI ',' Dcrlosbon, hts wife, futed 51519.\ reeorded, 5/~!!l5, in Deed Book 121, pa.ge,1I7L Jl.L- "~, " ""~ ,~ 'iE' "j~; ~" , .."- " -', '-" -:, " -- "-lK' ,~,--~ '~.--~ ';"1 ., " . 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 Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and piace 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 Sunday 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 29th day(s) of January and the 5th and 12th day{s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal 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 Dauphi in Miscellaneous Book "M", Voiume 14, Page 317. PUBLICATION COPY SALE#27 Sworn to and subscribed b Notario' SOIl Tony L, RUSI,II. Nolory Public Harrisburg. Oouphln COUnly Mycommissk>n Explras Juns 8,2002 NO AR PUBLIC Member, Penn,yiVania Association 01 Notal\9iV commission 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 $ 364.80 1.50 366.30 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..............................................................,..."