Loading...
HomeMy WebLinkAbout01-03709 ..,~'~I~"~l'~'~~~ il-~J " ~",~.--", "~""".~'__""~"~.~' _~,' ~~,=~ ' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) I" "~.... "~~~h.~l'~'"""''''''';;;''~'''''''d.:~" ',~ ~~~~.. .~~.. ~,I 0,"", J!i n~ ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 01- J"'lCfj Ctoi[ ~~ 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 Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 " _';~,"""~"~~~' ,"''''''~ ., .~""""".--,,,,~~,..,~ ~ .~' 11 '~'~liiIiIlvliI"'" "^"~","","d." .~ .."- J " l,_~ ~ '< ~ ~ ~~~'WloiiIlI'~' , ~~ ,".~'-' ~1'" ~__--.u.'_'~''''''''='<''\_'-,.'""r-,~:--' ' 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 usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAHENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA COYA DIRECCION SE ENCOENTRA ESCRITA ABAJO PARA AVERIGOAR DONDE SE POEDE CONSEGOIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 _,~l!liitiiil,.,L--,~- ~_." ,"wq_'-~V' ''liII.wlIi ~ " 'J' , """"'_-"'~~~T T ,1~:VI;lll " :i~~__"""~"*,-J","""'''d''~_'''"",,,,,,,"'''"' NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Is/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 '",,:Cl::did~" ~ ~ ,,_.I.; .'. "~ ..."<~'~- "- <- ~ ~ .; ~~-"l~~W",","",,"'l)<''''k'''';' 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: TMS Mortgage Inc. dba The Money Store Assignments of Record to: The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Recording Date: 3/2/00 Book: 639 Pg: 425 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 9 William MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 5/15/98 DATE RECORDED: 5/20/98 BOOK: Penn Drive Township of Lower Allen 1454 page:764 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 - -W:< ~-";. -,,-,- - -~-~~. "' I,. "-~ ~,~ ~~ i '~.~~~~.~"~~"',;r~~""'iI'''','''~~",,,-,,,,, ' 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 6/01/01 principal of debt due and unpaid Interest at 11.95% from 2/01/01 to 6/01/01 (the per diem interest accruing on this debt is $13.87 and that sum should be added each day after 06/01/01) $42,369.52 1,678.27 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0 and that sum should be added on the first of each month after 06/01/01) 2,546.00 Late Charges (monthly late charge of $21.93 should be added on the fifteenth of each month after 06/01/01) 218.67 Suspense Other Fee's CA MTG RECOV (27.40) 15.00 1256.40 ~U;,'''-'","'~~M' '1$',..,."....."..' ,J -~''''''.I'. "~ .~'"i~~~ '- ...~--.... ....... ~~'."'"""""',_o ~n~iilIl_ ""~""','"''''''"''''~~'''l :'M~.~~""","', "'-c',,},,"o. Attorneys Fees (anticipated and actual to 5% of principal) ?.J1R.48 TOTAL $50,704.94 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 $50,704.94 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. SQUIRE MARK J. UDREN ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 d~'~' .'~'~"'~"~~'Mi;"~.IIli[ " ' '"' " ;,~~~ I h '-'.'~"'''''''''''';;'''~~",-~~~~~=,,,,,;,,,,,,"~,,,.~,,j,t. DF985 TERRY L RICHARDSON 9 WILLIAM PENN DR CAMPHILL,PA 17011 April 6, 2001 NBRC 0081022097 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortllalZe on vour home is in default and the lender intends to foreclose. Soecific information about the nature of the default is orovided in the attached Dalles. A The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains how the program works. To see if REMAP can helD vou. VOll must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIllS NOTICE. Take this Notice with vou whell vou meet with the coullseline aeellCV. The name. address. and ohone number of Consumer Credit Counselinll Allencies servine: vour county are listed at the end of this Notice. lfvou have any auestions. YOU may can the Pennsvlvania Rausinll Finance Ae:encv toll free at 1-800-342-2397 (Persons with imoaired hearine 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 NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (pENNSYLV ANIAHOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PRESTAMO POREL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS NAME(S): PROPERTY ADDRESS: TERRY L RICHARDSON 9 WILLIAM PENN DR CAMP HILL, PA 17011 LOAN ACCOUNT NUMBER: CURRENT LENDERJSERVICER: 0081022097 HomEq Servicing Corporation IMPORTANT INFORMATION ON THE BACK OF THIS PAGE EXHIBIT A ",~'"~.r"~~.,h,-<, ~-~ , .~ '~. "~~..L""-"~~~,__"~~Jllimt,,,,,L=~,,,,~,,, ",,",',,- HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGmLE FOR FINANCIAL ASSISTANCE wmCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . 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 Ac~ you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a llface-to-face" meeting with one of the consumer counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desilmated consumer counselinl! al!encies for the county in which your orooertv is located are set forth at the end of this Notice1 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Ynur mortgage is in default for the reasons set forth later in this Notice (see foiiowing 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 Fund. To do so, you must fill out, sign and file a completed 'Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Availabie funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOlLLOWING 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.) IMPORTANT INFORMATION CONTINUED ON NEXT PAGE ",.,,,...~~~~,,,", -Ulll!iflj&-- "'ol>~;_~",~"~& ... : ~~~~~~"""'i""~'''';' HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it un to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 9 WILLIAM PENN DR CAMP HILL, PA 1701 I CAMP HILL PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number ofpayments Delinquent: b) Delinquent Amount Due: c) Late Charges: d) Recoverable Corporate Advances e) Other Charges and Advances f) Less funds in Suspense: e) Total amount required as of (due date) 3 $1,315.80 $174.81 $1,140.81 $15 $ 0.00 $ 2,646.42 B, YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WmCH IS $ 2,646.42) PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WInCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check. certified check. or money order made oavable to: Regular Mail HomEq Servicing Corporation P.O. Box 96053 Charlotte, NC 28296-0053 Overnight FUNB Lockbox 96053 1525 West W.T. Harris Blvd, Charlotte, NC 28262-00 . You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its riehts to accelerate the mortlm.ee debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE LETTER DATE, HomEq Servicing Corporation also intends to instruct their attorneys to start a legal action to foreclose uoon your mortl!a2ed nrooertv. IF THE MORTGAGE IS FORECLOSED UPON-, The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred up to $50,00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred even if they are over $50,00, Any attorney'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 oeriod. YOU will not be reauired to Day attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage, RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, vou still have the rieht to cure the default and Drevent the sale at anv time un to one hour before the Sheriff) Sale. You mav do so bv nayine the total amount then Dast due nIus any late charees. charees then due. reasonable attornevsl fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff) Sale as snecified in writinll by the lender and by nerfonninll any other reauirements under the mortll82e. 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. IMPORTANT INFORMATION ON THE BACK OF THIS PAGE r ;,,"'~""""'""''"~.. ~"''''''''li!'~ ~, -..""', =,~' ~=~ ,~ < ',,',"n ...1 , , """"i1I-':' ~ ~ --""'~~_~_"'!'Y""~""~'i"'- EARLIEST POSSIBLE SHERIFF'S SALE DATE. It is estimated that the earliest date that such Sheriff's sale could be held is would be approximately five (5) months from the date of this Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will he by contacting the lender. HOW TO CONTACT THE LENDER BY TELEPHONE OR MAIL: Name of Lender: Address: Telephone Number: Fax Number: HomEq Servicing Corporation FUNB Lockhox 96053, 1525 West W.T, Harris Blvd Charlotte, NC 2&262-0053 &00795.5125 Ex!. 10302 916-617-0655 ~FFECT OF SHERIFF'S SALE. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and your tllmishings and other belongings could be started hy the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT . TO SELL TIIE PROPERTY TO OBTAIN MONEY TO PAY OFF TIIE MORTGAGE DEBT, OR BORROWER MONEY FROM ANOTIIER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE TIIE MORTGAGE RESTORED TO TIIE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE TIIE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIlE RIGHT TO CURE YOUR DEFAULTS ANY MORE TIlAN THREE TIMES IN A CALENDAR YEAR). . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTIIER LAWSUIT INSTITUTED UNDER TIIE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTIIER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTG-Y LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED TO THIS LETTER Sincerely, HomEq Servicing Corporation "~~"1'~''''-' ~' !iI!iIllI~P"---'= ~~". " ~ H'" ,~ ~~, """~W_, , .. .......,-~' ~ "~ "' ~~-'-' ""... ,~;,;w J,,~ " -""",-",,,,,,,,,,,,,,'~:d.. , . DF985 TERRY L RICHARDSON 9 WILLIAM PENN DR CAMP IDLL, PA I70Il April 6, 2001 NBRC 0081022097 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortllal1e on your home is in default. and the lender intends to foreclose. Soecific infonnation about the nature of the default is nroyided in the attached oal1es. .. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains now the program works. To see if REMAP can helD vou. 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 counselin2 a2encv, The name. address. and ohone number of Consumer Credit Counselinl1 Al1encies servim! Your countv are listed at the end of this Notice. livou have any auestions~ YOU may call the Pennsylyania Housinl1 Finance Al!encv toll free at 1~800~342-2397 (Persons with imoaired hearin2 can call 717-780-18691. 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 NOTIFICAlON EN ADJUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA, SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRlBA PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNERS NAME(S): PROPERTY ADDRESS: TERRY L RICHARDSON 9 WILLIAM PENN DR CAMP IDLL, PA 17011 LOAN ACCOUNT NUMBER: CURRENT LENDER/SERVICER: 0081022097 HomEq Servicing Corporation IMPORTANT INFORMATION ON THE BACK OF THIS PAGE EXHIBIT A i~ ~ ,--~ll~ ~... - -- '.="""".^~,,_~~~~" "~~ L~~~_J ~ , . - "-"~''';''''~ ,-~,.~[~ ="-~ '1 -'=~-'~~l!;;&~,,,,.,,,,,,_,,,.i HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . 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, yon are entitled to a temporary stay of the 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 wilh one of the consumer counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE ypUR MORTGAGE DEFAUL Tn EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desilrnated consumer counselinl! a12encies for the COlmtv in which Your orooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting, You should advise this lender immediatelv 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 Fund. To do so, you must fill out, sign and file a completed -Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit cOlmseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TIlE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a deCision after it receives you application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TillS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) IMPORTANT INFORMATION CONTINUED ON NEXT PAGE ~oM'~"''',j.,.,"., ~.,~<~o ""'""~ ~~ ,. ~o'~"'''''''~ _ ~" '"" " ~,- .. J"_ """- ~_ "~ __UPIl~'~~ ,- ~~'"'- ~~_...._iIlI1iI","",.,"V\~"""",-""~"_:,;;~,, HOW TO CURE YOUR MORTGAGE DEFAULT (Brin~ it nD to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 9 WlLLIAM PENN DR CAMP HILL, PA 17011 CAMP HILL PA 17011 IS SERIOUSLY IN DEF AUL T because: A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number of Payments Delinquent: b) Delinquent Amount Due: c) Late Charges: d) Recoverable Corporate Advances e) Other Charges and Advances f) Less funds in Suspense: e) Total amount required as of (due date) 3 $1,315.80 $174,81 $1,140,81 $15 $ 0,00 $ 2,646.42 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2,646.42) PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's cheek. certified cheek. or money order made oavable to: Regular Mail HomEq Servicing Corporation P.O. Box 96053 Charlotte, NC 28296-0053 Overnight FUNB Lockbox 96053 1525 West W.T. Harris Blvd, Charlotte, NC 28262-00 . You can cure any other default by taking the following action within THIRTY (30) DAYS of the date ofthis letter: (Do not use if Dot applicable,) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its rillhts to accelerate the mort!!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments, If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE LETTER DATE, HomEq Servicing Corporation also intends to instruct their attorneys to start a legal action to foreclose uoon your mortl!alZed orooertv. IF THE MORTGAGE IS FORECLOSED UPON-, The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred even if they are over $50,00, Any attorney's fees will be added to the amOUDt you owe the lender, which may also include other reasonable costs. If vou eure the default within the THIRTY (30) DAY oeriod. YOU will not be reauired to Day attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, vou still have the ri2ht to cure the default and Drevent the sale at anv time uo to one hour before the Sheriff's Sale. You .mav do so bv Davin!! the total amount then oast due olus any late charlles. charlles then due. reasonable attomevs' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as snecified in writine bv the lender and bv oerforminll any other reauirements under the mortllal1e. 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. IMPORTANT INFORMATION ON THE BACK OF THIS PAGE 1 ,~~"'~". itl...._L~~'"~ilft~-~,~"''''''''=,,'''>"~ ~~_~I_= '," I". '_.1: .~.~~".,~ ".,.,,~,.-- , "" ~..=.~:~ l2lbil",x~~,u> .~,,;C,<, ,.,' ' , EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earHest date that such Sheriff's sale could be held is would be approximately five (5) months from the date of this Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER BY TELEPHONE OR MAIL: Name of Lender: Address: HomEq Servicing Corporation FUNB Lockbox 96053, 1525 West W.T. Harris Blvd Charlotte, NC 28262-0053 800795-5125 Ex!. 10302 916-617-0655 Telephone Number: Fax Number: EFFECT OF SHERIFF'S SALE- You should reaHze 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 may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE TIllS DEFAULT CURED BY ANY TIlIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIfE RIGHT TO CURE YOUR DEFAULTS ANY MORE THAN THREE TIMES IN A CALENDAR YEAR), . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER TIlE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HA VB TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTG-Y LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED TO TIllS LETTER Sincerely, HomEq Servicing Corporation .;k,""""v""'ill!l"_"'~"",-<'~k.~l@1' , ="-'Iri!.~~.'."-~"' ....~....lI!II~ = =~";..i_~ '" ~ Jw ,J.L , ~'"'-'~'k:jM~Illia~"""~''''d'''<';.,~,^,'''''''''''':""'_':. I 1 "( ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE AND BEING IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, AND DESCRIBED AS FOLLOWS, TO-WIT: BEGINNING AT A POINT ON THE SOUTHERLY LINE OF WILLIAM PENN DRIVE (FIFTY (SOl FEET WIDE), AT THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9, BLOCK "B" ON THE HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING THREE HUNDRED EIGHTY-TWO AND ONE TENTH (382.1) FEET MEASURED WESTWARDLY FROM THE INTERSECTION OF ALLEN ROAD; THENCE SOUTH 31 DEGREES 39 MINUTES EAST ALONG SAID DIVIDING LINE A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO LOT NO. 12 ON SAID PLAN; THENCE ALONG LOTS NOS. 12 AND 13, SOOTH 58 DEGREES 21 MINUTES WEST A DISTANCE OF SIXTY (60l FEET TO LOT NO. 7 ON SAID PLAN; THENCE ALONG SAID LOT NO.7, NORTH 31 DEGREES 39 MINUTES WEST A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO THE SOUTHERLY LINE OF WILLIAM PENN DRIVE; THENCE ALONG WILLIAM PENN DRIVE, NORTH 58 DEGREES 21 MINUTES EAST A DISTANCE OF SIXTY (60l FEET TO A POINT, THE PLACE OF BEGINNING. COMMONLY KNOWN AS: 9 WILLIAM PENN DRIVE TAX ID NO: 13-24-0797-104 , ,~."~.~',~~ '" "~F'~H """"'~T~'Jm,~_',~,,~ """=~~---"'""'~lillIl1l'" J_. -" L._..~~, ..,~~ ~~.~,<~"-",,-~,kG,",,,,,, - V E R I FIe A T 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 Plaintift"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 Mark J MARK J ESQUIRE & ASSOCIATES authorities. 'C " , ~"'~~~ilf1!fm-li1f!\:;...{i;';!ii;;i;,'.f,1fu;j;t"",""i1t"Wlm....".;illSi"!ii';~1%:';:i;,",i-i~~":lliVv;"'_~"'_0~'i"':':""1",,,,,,~~,'M,,,"r,;tiEtW;;;ii,,~~W'1Miilil'W-~i1!fiIi($1~~~!<:i"":&:l:1;. l1ntl!1Wl iifV ~ .,,~ '," ',,- ~~/iIilI~~illiiIillIl~~~" , Ii I:: I' ~ I ',I jl Ii ::, , , , 11 ~ () 1l'\. ). ~ '6Q.. ~ h t () 0 0 9 ~ C -Tl ~ ~ 8 6 <" ~ :-:::1 -rJf~j lI.J S2 ~~j ;z :.:c; -n :j , , 1 r:~'~ It, I Zl- ~~ ~~:~':: Ul - () r VJ e--:: C) ~j , V " :1:::: f"" ' t ~:=~ /--;, '::',::,~(') ". .... ;"'<...} 23m ...- ~"- 1- ~,. ;;;:-~,! L~ :.) :J.J -( <;) -< ,,~~,.. ~"-. - "~.,, -~, -< "' ',"'-'<l,.."r~'~".~._" 0,....... --~ -.. I.-~<"'i -. - " -~~ , ,-l _,' _, " ~l!ltl.!''';;~&'~'' SHERIFF'S RETURN - REGULAR CASE NO: 2001-03709 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS RICHARDSON TERRY L SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RICHARDSON TERRY L the DEFENDANT , at 1938:00 HOURS, on the 28th day of June , 2001 at 9 WILLIAM PENN DRIVE CAMP HILL, PA 17011 by handing to TERRY RICHARDSON 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: DocJ~eting Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 So Answers: r~r"/~~ R. Thomas Kline 06/29/2001 MARK UDREN Sworn and Subscribed to before By: tL-- me this N ~ day of 0..1., d-IJ.OI, A.D. q~thO~t:;/I' ',~' '^' ~~=,-.- , """"- ~ . , 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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 william Penn Drive Camp Hill, Pa 17011 Defendant(s) ,,,,,,,',,_,', -, ,1 ,,,-,j .' < ~~, >"'-.;~" ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3709 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AJ!lD 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 6/2/01 to 8/3/01 Late charges per Complaint From 6/2/01 to 8/3/01 Escrow payment per Complaint From 6/2/01 to 8/3/01 $50,704.94 873.81 43.86 0.00 TOTAL $51,622.61 I hereby certify that (1) the ;:l.ddresses 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. DAMAGES ARE HEREBY ASSESSED AS DATE: IJ ~ ~ L. ::JrY':.l-- / ,/ ODREN & ASSOCIATES Udren, ESQUIRE for Plaintiff .""",""''''''''''-''i"",.<'''~!lt'''-ck''...d..=.<,''''''.w""".,h\ic;;,"""""",,,,,,,,;,,,-i.'ki;;,,,,,,",~"~'<"'-----' i~Iiii~"'L" "',"',,~---'" ~",,,,,",,,,,_-..~~~~,,,.,tM~l-~b~>'.;;"',,-;;:,~,iliiliil#i\."' . MARK J. UDREN << ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Olc;l County Road SUJ.te 429 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Terry L. Richardson 9 Wi liam Penn Drive Camp Hill, Pa 17011 Defendant(s) NO. 01-3709 civil Term July 23, 2001 Terry L. Richardson 9 Wi liam Penn Drive Camp Hill, pa 17011 I~ATANT N.Q'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 NOTIFIC~CION I~~RTANTE DATED: TO: USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED 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 US TED 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 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. ","~~-""," ,,'~'" ",~<.-~ ~~,~,,'~-^ >.. ' -~ ,_'H _ 0 c.i.,... ~~"'~ ~ 1~'IIlIiil' -"''''"~~"~,,,,''U, '~'~"':,,;:..,i;,. . MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-3709 Civil Term v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) STATE OF AFFIDAVIT OF 1\tW. \'~Ll ' WX'Ji~::/\ .' NON-MILITARY SERVICE SS COUNTY OF THE UNDERSIGNED being <;luly' sworn, deposes and says that the averments herein are based, i.1pOl). 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: Terry L. Richardson Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Over 18 As captioned above Unknown Sworn to and sub~ribed bef, o.,.1[,t, ,'~ m~e. ~ .liS <3lq da, y ,of O~ ' 2001. ~-c)~'7J'{),_j{ (]Jll ~k - ,0tarY~~~K N()TARYfUBYc OF NEW JERSE'f ~'Expile$8/18/2003 iii~~~~W~i!l:i;!!i"clB"'0J2'h,Mi"'","'mj0~"",,~,~~~jjA,1'''''''''k';'''-,",", o,h"~"",~"jj;j;.'i~h',,",,l"';;G;;",,~,;,,~,","..,,;J:i~llili'I!.n~ir!!ffill!~1iI~~W~' ,~" "'iiiiIIiIiIIiI" "~'- ..~'~~-" . ~ ~ (.:) '6q. '[ ':-0 0 c::> 0 c 8 s:: -n ;0. -~t '"Om ~ - Lpnl en ihfTI ~ ......... ~:tJ <<'_:Xl Zc' f :g0 ....... (j) J> cr. CI) -<2:~ '3,S ~ t~ ~c' ""'" ~T~ :I-l )i> :.lr: z8 (:-)'."-. 7~() )>c 9:'l o Iii -. Z ~ P: =< &:"" 0 -< ..... "<~~ =""','~.,,, .~" .'~~~r~"~, ,~~,,""~, ,,' ~". ',,.,,,~. .,~ "~', ,,"",,". . '" '. )..C>4ARK J. UDREN & ASSOCIATES BY~~ ~rk J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) TO: Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 ." I k/, . ^",'-""w -'ffii-:! ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3709 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. 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, f '~'j 0" ~" ~'n'" '-, ;,:, . 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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . ' : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William penn Drive Camp Hill, Pa 17011 . . NO. 01-3709 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 6/2/01 to 8/3/01 Late charges per Complaint From 6/2/01 to 8/3/01 Escrow payment per Complaint From 6/2/01 to 8/3/01 $50,704.94 873.81 43.86 0.00 TOTAL $5].622 61 I heJ:"eby certify that (1) the addresses of the Plaintiff and Defendant aJ:"e as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN & ASSOCIATES {" I ,J,I'"'Y>I Udren, ESQUIRE for Plaintiff AS '~(3;JA.) k- ~ PRO PROT Y DAMAGES ARE HEREBY DATE: {)u.<t ASSESSED ~"." ~-_.......~- ~ 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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) ,'. ,.."-' "t'T":iI.fF.. ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3709 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 9 William Penn Drive Camp Hill, Pa 17011 Amount due $51,622.61 Interest Froin August 4. ,2001 to Date of Sale December 5, 2001 Per diem @$13.87 (Costs to be added) 1.719.88 $ MARK J. UDREN & ASSOCIATES Udren, ESQUIRE EY FOR PLAINTIFF !a,iI1,;",llJ~iO!lbl\}~,"&o-<t__t;;,,;b);n~"'U;!\h '" 'll>ll.Jili"<-iJ1i'lL"!tii! ~iilillf!ill'iillll't!_ ,;t~ _ *ilMiiIi1Ilii*~ " . .~,ili%&,,*;r,,;iMw,_.m "-"A''''d:.-o.dllt ~'lffijiii ,'" ftl'i18 iiMa ~"~. C> 'q. -l::W", ~ "I;) !0-:-Ofrtf" 0 (.::) -4 . ~B8b~9 ~ 'i a 8 0 0 0 C "T1 I I ;g;: ::>- -l , -0 ~ IT; ~ ""Om - rTlp f'Tlrn G") :::::: ~ ~ ~~F 2::0 I _-.Qfn ... zr::: 0"> ~"~:;y lr) ... ... CJ) 1'" '~r) r- ... ... ~cj ";::-7, )J ... ~ ,~ :s::: ;IO~ ?;:n ( ~8 - 4(') - cp cyn - 5>c ~ ... ~ t:'" ..... 0 -< .,.~-=,~" ~, ~= ,,<,=- ~~~< ,~. '._ ' ~~ V_"",", ---<---~.~.~, - '. ..~, __ .",~r,,"";._ ~_'" ~"",-- ,'"'"..,,. ~,.,~" "" ~~ ~~-~"~~ "<i '___110.. "-~..o," ' '~, ~ '__~ ~.'- MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 william Penn Drive Camp Hill, Pa 17011 Defendant(s) '1'.- ~, .'.:'j - - - ~ - ,----," r "'lI~~~,lk';~ ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3709 Civil Term 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. . UDREN & ASSOCIATES Udren, ESQUIRE Y FOR PLAINTIFF ilti1i~_~~~~H*,g~~,f0.\'Jt;rI"',';~h"t1>i.0~l!t!i%K",~,t"'0l:ili"';ilcio'k!'"\""'>"~~W;';J.;l;.i0!i,;,,",k"":i!d5t,o/' ,. , ':'J.Illf:'>~""'"''''''~m~!ilII!'~ilil1f. tart< ~~ati ,." .,v'=.""._" ~~. - ~~ .~- - ~, ~ .=, - ,""". " ~ ;J.L_, -"~. -'",~~~ l.d:tl1lil1l1li11ii1l ~~,' 0 0 0 c -offi 'T"} :::- =:;:.l rnrTI C rl'i21 2::0 G') Zr I r- (J) ".. Q) ,""'8 ~z ',.' , '"' j ~c:; ;l> ~--:;:iO ~o '[' -r ::Jl: i"",:;.:d 5>0 :':?c) c <?? om Z ::- :;;! =< 0 :0 -< ~ ,," ~ '\'~. ~==""""'",- "O~_ MARK J. UDREN << ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, pa 17011 Defendant(s) "" 1,0 e, fi:h1k,~"~ ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . NO. 01-3709 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C, 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: 9 William Penn Drive, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Terry L. Richardson 9 William Penn Drive, Camp Hill, Pa 17011 2. Name and address of Defendant(s) in the judgment: Name Address Same As #1 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address LOWER ALLEN TOWNSHIP LOWER ALLEN TOWNSHIP AUTHORITY 1993 HUMMEL AVENUE, CAMP HILL, PA 17011- 5983 120 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. ALTERNATIVE LENDING MORTGAGE CORPORATION See Caption above. 305 5TH STREET, BAY CITY, MI 48708 lj,' -. . ~ ., ...... . -L'- -'-1 ,,- ". ,;',,",,,",;,:, -,,' - ,- ~~g'ih . 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. I 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 wno has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 9 William Penn Drive, Camp Hill, Pa 17011 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: August 3, 2001 MARK J UDREN & ASSOCIATES ~- Mark J Udren, ESQ. Attorney for Plaintiff ,ijj~1Ii~~lfij;ilifj;'P!i,;:;~.;Nnf'~!801li',1tm~;d~~~e~k~ill'!1o'<Ii-gA_'-iio>;:''''';m"'c~;-.'d~.~MiM;~i'i'-'-:..:i1 -:":'i-~"'~ - ,.,' ;"'d~:"'_ ,.' i'~ ~-;>'''-''''';'"1','!l';~'''''~'~''>'-='''''''f',~~ ._ " '".....,..~,~..-""-,__._ .~~., _,,_~~..~ ~ _, ~~ ~~-- .~ ,,~- , . ~ '''''' 'j i -~ ""~~'&ili\lii'"'~""'" l,' ~,~ ... """Ii! i . , 0 Cl 0 c: ,,:<;: .., X- ~j mtD C= Zg:) Ci") t:-i~ Zs;: I .~~y ~Z en C' :< 0- :D'" .",....0 ):> <J~~ ZO ~., -"- 5>8 en bm Z '---1 -' z::- ~. -< c::> S'J -< -," ,~~ "-" '- ..j - , . " " .-",,1 .' .."~-. ili>1l!;;11~lk', I' MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-.6900 ATTORNEY FOR PLAINTIFF The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) . NO. 01-3709 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry L. Richardson 9 William Penn Drive Camp Bill, Pa 17011 Your house (real estate) at 9 William Penn Drive, Camp Hill, Pa 17011 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 $51,622.61, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BF. Jl.BT,F. '1'0 PREVENT THIS SHERIFF'S SJl.T,F. 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 2. You may be able to stop the sale by filing a petition aSking the Court to strike or opeo 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 ~ssert 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.) " ~--~~ - ,~~ ~. , . ,-J '--,,,,;,,,,, ',~ -" '>~k;" .:.~,;~~"'_-'-" ~~: . 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 ASSOCIATION DE LICENCIDADOS DE CUMBERLAND Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 i~~MllI'J~~Jti!;!i1l!I1lrflt.ilir,io'lli0fi1'.;ad;"'.ij(;,i1lJ'-~",r.,M'if{,.;l4~.i,".iU";"'r-j"~ci;-"~_,:,--"f',;'h{~~'.1~~~"'OiJ~~iila!i~TIIi "'~~~'<I!"I~m LB5tllliiliW~~~~ ~ o,;t'''!_'' _ 'Of",,""'" ,'O,l;lb_,~~,_~f"'. '., ,~"'"_ _ ."";,, "c<,A-',""'~~'>",*, ~, ~~" ",. ,^,,;X,/,S,__o" ,~ ...''''''' , , "," ~" ~'W, "'~ '," ,,_, .~ ~, ,0 ~ " ,_,._ ,~ - ~WiItii,L e Cl 0 .., <"'" ". .,,05 c:: :.:j mrn G") ;:-j:i:D Z::c , ZC I -"Om ~~Z (T. -nO r:::l; ;;6 )> :;;-~ iJ::H ZO :2: ~.,,) C) 5>0 CO Zrn C Sl z - ~. =< ~ :xl C) -< ~ i n 1 .. ),1 "; I' ,I I' ; ij I il Ii II "I :1 II II ,I I .- ~--~ ~. -"'" ~~ I I!iIOlo; '~ ~ ""-i;jw~ "",,-,,,o;;,,-~;":""~'$ii__ MARK J. UDREN ~ ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-3709 Civil Term v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa l7011 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, TERRI L RICHARDSON has filed Chapter 13 Bankruptcy in the MIDDLE District of Pennsylvania on AUGUST 27, 2001, Bankruptcy Case No. OI-04639. m Mark J Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff - ~~~~i!lig~~i&ilJ.,:'i'i;bli-x..Ji!o(<'A'!f~~mIil.i:!MilI~"-!T'~ ,'.'~~,H-'-< '"",,~ V'" ~~'r,,,,.,..,,~. ,~ ~^' '''-','" '-'"'' ~. "'" '", ,", .,,- ",,_. ~-"< ,," ,- , -', ~'=':lI-;.lltl ' ", " ,~, ,-~ --", ., llIilla.linl(o..'-~~ (") ("- :;:';::: "'Pcb me: z" 2<" OJ);, ~~; ;:::::t..: >,,- -,......; ~c~ -c ~ ..... .",.' ."" -i-:'i 'I ,Ii ~/i ~, ,; l-i " '" ~ ! [i It::::) I,~_) -n U:> i'i1 -0 N tt': :}E~ ,'-, ! g~ -:::;-i :D -< :JC.J!'.I ::;c (.fl \,0 J "'., " ~ ". -",;;. _.~'_".';":i ltiltW'~~""'~~~""" 1 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C VS Terry L. Richardson In The Court of Common Pleas of Cwnberland County, Pennsylvania Writ No. 2001-3709 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 20.00 .50 1.00 1.03 $52.53 paid by attorney 09-21-01 Sworn and subscribed to before me ~~~~ This ~ dayof O~ -.", R. Thomas Kline, Sheriff 2001,A.D.ctr- D.71t.li<;Il!J,$,. BY q()dJ.( J~l.h Real Estate Deputy Prothonotary ,sU LlL 3 'IoU! I~" //"JJ.O'( r=~~ " , . MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ .08034 856-482-6900 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff v. Terry L. Richardson 9 william Penn Drive Camp Hill, Pa 17011 Defendant(s) ''''1 <,l( <" ",- """lID,~~~;; , .. ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-3709 civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C, 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: 9 William Penn Drive, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Terry L. Richardson 9 William Penn Drive, Camp Hill, Pa 17011 2. Name and address of Defendant(s) in the judgment: Name Address Same As #1 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address LOWER ALLEN TOWNSHIP LOWER ALLEN TOWNSHIP AUTHORITY 1993 HUMMEL AVENUE, CAMP HILL, PA 17011- 5983 120 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. ALTERNATIVE LENDING MORTGAGE CORPORATION See Caption above. 305 5TH STREET, BAY CITY, MI 48708 ~~ ~ ..~ - -' , -~J <" ,,; ",;. ~,:-" "'-""~'~ , t" , 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 13 N. HANOVER STREET, CARLISLE,PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 'Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occ~pants 9 William Penn Drive, Camp Hill, Pa 17011 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: August 3, 2001 MARK J UDREN & ASSOCIATES ~- Mark J Udren, ESQ. Attorney for Plaintiff . . 7 ''''',~,.., ,_~~ ~, ~ """' ~ mill OFFICE ,IF fiT SHERIFF CUMBec' 'JUNTY AUG 7 8 38 AM '01 ;,} !.,,;::- PE,j'", 'I' "'(' . II,!---, ~) f .... 'v' ;\.N _ JJ. ^ " ':"":"~'~_~~~_~~~ .~~~~~'" ~iiff(1llf!fl"lr.~':1f~W~_~"',l',Wt':\S~jfl'~~%"'~P"!~!11'~F1':fJ~~.~"'EI\1'fl!l(J.'lj~~~"',ti'~->,,-..~: ~~ ,~. .~ ." ~..$- ~ e:-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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 COURT OF COMMON PLEAS . CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 . NO. 01-3709 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Your house (real estate) at 9 William Penn Drive, Camp Hill, Pa 17011 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 $51,622.61, 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 1mmediate 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. 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.) 0',...... "~~ ~,~~..~'. ~ .. '"""",,,,0 ' , d~ " ~~-""~'.' ~-. '-~-'~~"'''''-''~''b_,'' , 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 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 ASSOCIATION DE LICENCIDADOS DE CUMBERLAND Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 .. , ,-, . ALL THAT--CERTAIN PIECE OR PARCEL OF LAND SITUATE AND BEING IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND, COMMONWEALTB: OF PENNSYLVANIA, AND DESCIUEED AS FOLLOWS, TO-WIT: I , I I BEGINNING AT A POINT ON THE SOUTHERLY LINE OF WILLIAM PENN DRIVE (FIFTY (SP) FEET WIDE), AT- THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9, ELOCK "B" ON TB:E HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING THREE HUNDRED EIGHTY-TWO AND ONE TENTH (382.1) FEET MEASURED WESTWARDLY FROM TB:E INTERSECTION OF ALLEN ROAD; THENCE SOUTH 3LDEGREES 39 MINUTES EAST ALONG SAID DIVIDING LINE A DISTANCE OF ONE HUNDRED TWENTY (l~O) FEET TO LOT NO. 12 ON SAID~PLAN; THENCE ALONG LOTS NOS. 12 AND 13, SOUTH S8DEGREES 21 MINUTES WEST A DISTANCE OF SIXTY (60) FEET TO LOT NO. 7 ON SAID PLAN; THENCE ALONG SAID LOT NO.7, NORTH 31 DEGREES 3.9 MINUTES WEST A DISTANCE OF ONE B:UNDRED TWENTY (120) FEET TO THE SOUTHERLY LINE OF WILLIAM PENN DRIVE; THENCE ALONG WILLIAM PENN DRIVE. NORTH S.8 DEGREES 21 M:Z:NUTES EAST A D:Z:STANCE OF S:Z:XTY (60) FEET TO APOJ:NT. THE PLACE OF BEGJ:NN:Z:NG. COMMONLY KNOWN AS: 9 WILLIAM PENN DRIVE tAX :Z:O NO:- 13-24-0797-104 HILL PA 17011 9 WILLIAM PENN DRIVE, CAMP , - 11_24_0197-104 PROPERTY lD# HARDSON A SINGLE woMAN , TO SAID pREMISES IS VESTED IN TERRY ;'D~b J FOSTER, HusBAND AND ~.:r:EEDFROM GEORGE H. FOS~iD~i'/~~97tN DEED BOOK168 ~AGE 586 WlFE DATED 10/25/97 AND RECO BEING KNOWN AS , , ~ nO _ -.,' ~-',~,., _0' ~" "--" '-""~.~ji~;--) .~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) , .,' ~, ! NO, 01-3709 CIVIL Xl{ TERM CIVIL ACTION. LAW TO THE SHERIFF OF (]1I11hf>rl FInd COUNTY: To satisfy the debt, interest and costs due The Bank of New York as Indentured Trustee for The from Monev Store Turst 1998-C Terry L. Richanison, 9 WIlliam Penn Drive, Camp Hill, FA 17011 PLAINTlFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description (2) You are also directed to attach the property ot the defendant(s) not levied upon in the posseSSion of GARNISHEE(S) as fOllOWS: and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any c;tebtto or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing tMreof; (3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due 8"1,h77.61 from 8/4/ 1 to 12/5/01 Interest Per diaR @ $B.1l7 - $J.71Q RR Atty's Comm % LL $.50 Due Prothy Other Costs S1.00 Atty Paid Plaintiff Paid $108.06 Date: AllgJ'''t 6. 2001 Curtis R. Long Prothonotary, Civil Division ~~. 2 7pc/J~J Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kinqs Hiqhway, Suite 500 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-482-6900 Supreme Court 10 No, 04302 &.';~,;~" i.iI:liJ~~illioih'b~"~~~~~":M)'@L"-'t;r"!""}"j""_,,,l,.!O;,b\,,"!i"-"di$:?h~iillt- ..:.,,~, ,1tt] r"rollnl,..,,;j;~'~----""M~~" ~'~' ,., ~~ 1dliiI1Mi1Bi' REAL ESTATE SALE No. 7) O+,' Sepl-- / ()/ d-(30 J , '~f'. .. . . ., l;f,,~fi'h ;~~~W~ !lJJ~Om1 U!~ ;J:l~6K11:13m~ InM-I"""";' iI.PI~.A rl,i,,0)"\i:!.. .id d,.t."I.".I""'''', 1"1 L' 1i1/l./JI> 11' /) Ii . /1 ~, 17/JA/lt. ~ t~!~;;;st, ";,~~' t,>...\1-1',..,el-,:,.. ,1..,.(.~1.1o:;U ~t~ -~ _~!!..~.f,.DJf:.J''-ff' Oumberland COUfltv, ' i!I\ ,mcl numoored as: q tU11l14m fJJIj'L fJn . fhm{J ff/lJ ana more I! "\:rihed on exhibit "A" flied this writ and by this reference\lCorporated herein. Date:, If pI. If). O?m I I1l ~-J \.( , I" I ',11 (' J I' :.r 1, I'::: 'll'lJd , ' ; ':' ~': 10, HV 8E 9 l DnV ).ll/llC~ , '. iJ:lllr.;H~ ,;'. ", ,ofiC/^ .. " ",, dO 311;;;0 ,-~_,~-,,,..,,_o,__,,,,O'_""'''~ "._ '''~~'''"''=''''^'_'~' ,'__~"',"""____",..,"_" ~,". ,'" "" ._'^ ' - -- < lr.., c:;;;) '~ 'c:::a (ft) &ViI ~1 ~- ~ - ," ~ . I. ,.'1 ,-,,1 ",,,," -;fj,jJ 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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant{s) . . NO. 01-3709 Civil Term PRAECIPE FOR WRIT OF ~XECUTION TO THE SHERIFF: Issue Writ of Execution in ;the above matter: Amount due $51,622.61 Interest From August 4. 2001. 4,244 22 to Date of Sale .Tune 5, 2002 Per diem @$l3.87 (Costs to be added) $ I . \ j M rk J Udren, ~ ATTORNEY FOR P N & ASSOCIATES t'Ai:;;'~dl', ~!iiiiI~,,~~~ffiil!ll-i;,~'i:ft:i~;YYc",i:"''''f':,<'' iii , <'--~lilMil!lii!ii_ll "~v '"'>b ""~~~.ft,1Ifii:= _ ~ .:o.k.k- 'w,' ~,'~', ~ .Cq (":J ...... ~ i ...) ...... ..J:: n w B 7t t..., '" ..0 .&t D- . ~ . 0 c.:l 0 0 ~ C "1 0 D c: 1'0 .. ;--... ~ ;;p' ,.. C 0 Ii" (> -ute ~ ::::-' ...... () -..0 tN '''' - .,'1 mn'; ';"~ '--.--;= "- 0 I , ~ ~ I Z:c ----,;Tl / I I GJp:! r5J ~~~: ._';-...., 0 y -<,,= ,~ r- W CL. ~ =1=.: ...... 6 ~~: -,,... ~5f~ "'<lJ , .. .. .. !f:- .. ~ .. ?? () ,~ )>- -\ 1= :2: ).:>- c- Xi :::< '0 -< , .. .. , ..., ... , ,,"" . "..,_. ., ,q", ,". ,,~~,-" , --. ,~~ n'~' .."'_ -"''',~"O,"C,'''',.~, "_~_~_~^' ,",v. , rz ,,' "".....~.- }-- "';'~1'~- " -- ~-\>)l\ii_'.i'- MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 8S6-482-~900 ATTORNEY FOR PLAINTIFF The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old county Road Suite 429 Carle place, NY 11514 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 . NO. 01-3709 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. N & ASSOCIATES ,j'~i8iXujg~~kl~:Mi~_~~ilW<'l!&Will""iiOO!JR,g"".5h,;""~".,,,_'e,"~'lliJ~JU ",~l-';'~~'~ -',,-", H'_~ ~. O"~ ~.. -~. ~-~~,,-= ."'~";<"'.~<> "-,,~, .- ,^,^~" ."_..~~ "-" '~-~.' ~."' '. rM\ii.Ja; c_ "" - ~ '~'l(~ ~ '.:.0 ,. IIIiIiI ,,~ ..-:'j ~i ! 0 0 ~~ C I'..) s: L- ""OCL ~;; ~J:~ [!lr", .'""- Z_,. -- -- 2: C: .".- ',.' (f)~ - 9 ;:.<,~ y\."~' :~--' :'1:1j >c: ~" > ::>(2 Z." .' {~; Cf! r)\ ,; 5>'e :::--{ -'C;;- "'~~ ~ ,,", ~ -' -..::;, ,0 -~ ~r '1 ,4. ~ --,' 1,,-'1, , ~> _ ,'"_l .,~""",.'lIiW--"'"" ~ J. UDREN & ASSOCIATES BY: Mark J Vdren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, pa 17011 - NO. 01-3709 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C, 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: 9 William Penn Drive, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Terry L. Richardson 9 William Penn Drive, Camp Hill, Pa 17011 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 Lower Allen Township 1993 Hummel Ave., Camp Hill, PA 17011-5983 Lower Allen Township Authority 120 Limekiln Rd., New CUmberland, PA 17070 L, ' " " _J ~---~~~ , Name record: Name and address of the last recorded holder of every mortgage of Address Plaintiff herein. See Caption above. Alternative Lending Mortgage Corp. 305 5th St., Bay City, MI48708 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 9 William Penn Drive, Camp Hill, Pa 17011 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: January 7, 2002 ~ii'''''''O"~~I~~B"<l!~.IQ(j_.t~E.tli'iM,~@-U--~'''"~';:''':''-'-!'Af.''''E~,M~M'~1!I~ii~_t_liit'-- ", ~~ ~~~,~ " ~- ,> ~, . - .J ,,-,,~ ~', ';','-""'r" ,~~ > ;,' ~;""" " IIl'P , 0 0 p C 1'0 ~' , , Cl cc. c..... ...:~.f tpPl ),~ ~~ ~ ,. ]2 ~ , t,'! , i j;: --.- ;:!:::;r" ---~lQ Z>..:,' "-\.,~ ~:'7i ^'i''': (,~ ~C 9? C) fT, "'"- &::- 5! ::< '0 :cJ -< " -'" ""","' " ~ "~ " '~- - -,' ^ - " ~ ",,-' ;.=~~""';'~~j' . - ~ 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 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 . NO. 01-3709 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Your house (real estate) at 9 William Penn Drive, Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $51,622.61, 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 B~ ABLE '1'0 PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immedia~e ac~ion! 1. The ~ale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) oJ' L, ,',' -~..;:;' I,. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until .the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribu~ion 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 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 i';';~~M~~,~~~;liffi~~\i;~",'lif0itl'j:,,,,:;jI.iJL"~~r'",,,_""'~"""'">"-:, o!lilo""~_-O:~"<>"jl"'-,;,L"~';';"i:".,.-.~~,,,,;.,.;( I ~""~,,,,,,!~','c;,,,~<,,"._~",,, <;!>"~ ""-', ~,'_""~_ ~~ ~_,,,,,,,,,,_,>_,,,,,_, ,"~, ,_ ,Co"__ <.1,e-:' ,', ~" ,~~ . ~'"'' ' ,c_ ~ .. -,." -,-~"""" ~. ", >'~""'''"'1lIiIII ~~ . ..... - .-~: ) ~- ,0.. 0 0 n c: pt.,) -,'I ~~,: ~J-;;C;< ~. I -00: ~S 'Tl nln-' :",,,j" Z:J~, C1 -:O"r" ~~ (I) ",':_ , -<"" () r::: r--' '--.-' :C..' ~, )> or' Z c:: :::1::;: (J :;r.-.. C) CD 1-'';; ,'1"; c:: ...~,I / ;:-'~ ~ ;:- """ -0 -"": -< g - ~ '-" ,~ - " "i,.;;j.w..~,*",;pC ALL THAT CERTAIN PIECE OR PAR9EL OF LAND SITUATE AND BEING IN THE TOWNSHIP OF LOWER ~ ALLEN. COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, AND DESCRIBED AS _, FOLLOWS. TO-WIT: BEGINNING AT A POINT ON THE SOUTHERLY LINE OF WILLIAM PENN DRIVE (FIFTY (50) FEET WIDE), AT THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9, BLOCK "B" ON THE HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING THREE HUNDRED EIGHTY-TWO AND ONE TENTH (382.1) FEET MEASURED WESTWARDLY FROM THE INTERSECTION OF ALLEN ROAD; THENCE SOUTH 31 DEGREES 39 MINUTES EAST ALONG SAID DIVIDING LINE A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO LOT NO. 12 ON .SAID PLAN; THENCE ALONG LOTS NOS. 12 AND 13, SOUTH 58 DEGREES 21 MINUTES WEST A DISTANCE OF SIXTY (50) FEET TO LOT NO. 7 ON SAID PLAN; THENCE ALONG SAID LOT NO.7, NORTH 31 DEGREES 39 MINUTES WEST A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO:!l!HE'SOUTHERLY LINE OF WILLIAM PENN DRIVE; T1lENCE ALONG WILLIAM PENN DRIVE, NORTH 58 DEGREES 21 MINUTES EAST A DISTANCE OF SIXTY (50) FEET TO A POINT. THE PLACE OF BEGENNING. .. . .;,,~ BEING KNOWN AS 9 WILLIAM PENN DRIVE, CAMP HILL, PA 17011 PROPERTY ID NO.: 13-24-0797-104 TITLE TO SAID PREMISES IS VESTED IN TERRY L. RICHARDSON, A SINGLE WOMAN BY DEED FROM GEORGE H. FOSTER, JR., AND DORIS J. FOSTER, HUSBAND AND WIFE, DATED 10/25/97, RECORDED ll/26/97, IN DEED BOOK 168, PAGE 586. ~"'~,,"J""'liOiili~~'<'~~"-" > - ~ ""''''',,....'''.......=' ~ '=~ "'" - ~~,~~' , _, "0 _~ "_~ '""''''', ~~~". Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 1 of2 Bankruptcy Docket Report 1 01-04639 (Harrisburg) RICHARDSON, TERRI L Docket items entered between 01/01/1931 and 12/31/2001 Filing No. Docket Entry View Date document 08/27/01 I VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Doc #1 PDF (30 Plan and Summary [BOD 08/27/01] [KZ] P-ill\~ 09/17/01 2 CERTIFICATE of Mailing of Notice of341 Meeting. Objections to the plan are due None 15 days after meeting held. [EOD 09/17/01] [CA] 10/12/01 3 341 meeting held, [EOD 10/12/01] [CA] None 10/29/01 4 MOTION for relief from stay filed by THE BANK OF NEW YORK as Indenture None Trustee for the Money Store Trust 1998-C (fee pd. $75,00, rec. #575466-KZ) [Disposed] [EOD 10/29/01] [BW] REQUEST for admission [BOD 10/29/01] [BW] CERTIFICATE OF NON-CONCURRENCE [EOD 10/29/01] [BW] 10/30/01 5 ORDER that answers aredue on 11/19/01 Re: Item # 4, [Rescheduled] [BOD None 10/30/01] [BW] 11/05/01 6 ORDER Confmning Plan [EOD 11/05/0 I] [BW] None 11/05/01 7 ADVERSARY PROCEEDING FILED NO. I-OI-00269A United States Trustee vs. None Stuart B. Donegan, Esq. re: To obtain an injunction or other equitable relief [BOD 11/06/0 I] [B W] 11/19/01 8 CORRESPONDENCE from Movant requesting new standing order Re: Item # 5, None [BOD 11/19/01] [BW] 11/21/01 9 ORDER that answers aredue on 12/11/01 Re: Item # 4. [EOD 11/21/01] [BW] None This entry cancels the previous due date, Re: Item # 5, [EOD 11/21/01] [BW] 11/28/0 I 10 CERTIFICATE of service Re: Item # 9, [EOD 11/28/01] [BW] None 12/19/01 II MOTION for defaultjudgmentRe: Item # 4. [Disposed] [EOD 12/19/01] [BW] None 12/19/01 12 CERTIFICATE of service Re: Item # II. [BOD 12/19/01] [BW] None 12/19/01 13 ORDER granting default judgment Re: Item # II. [EOD 12/19/01] [BW] None ORDER granting relief from stay Re: Item # 4, [EOD 12/19/01] [BW] Printed: 12/31/0109:31:44 I PACER Service Center I I Transaction Receipt I I 12/31/200109:31:44 I Ip ACER Login: IImuOOIl II Client Code: I IDescription: IIDocket IICase Number: 1112001-04639 I IBilIable Pages: III II Cost: 110.Q7 I http://pacer.pamb.uscourts.gov/cgi-bin/foxweb.exe/npacer/nPacer?ExecTIris=docket&puic.,. 12/31/2001 _,I .. .., ' '-><, ,~,~~' '~ ,",1 \~.-...."t'__C''''j" MARK J. UDREN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-3709 civil Term v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Terry L. Richardson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on August 27, 2001, Bankruptcy Case No. 01-04639. Mar~n. E"quir. MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ~~~lliMj_@l,'iii~,1'_~'~,lt'li~Jit~,j,"f1.<n""mll;';;-"",":"" 'If'ej,[H:,,,,,",',",- "",,,:;,~~,~~.~;iii{" ~P" ~ '""_',"" ,~,'~""""," ,_" ,~, __,", 'r,_" c___' ~ ,'~ ,,,,- .,~ "''''',-~"'~ ,~, , " ,;; ;~,~ J~"_.i.., ill' ' _la~iU! >~ !.llU,I!'TUL'~~~' " i"jUJlIJ.'" () ~; ,Jl:T~ 0Ir-,-', ~;,T' ,,;.-'--.... (/).',,", <<..... L~._ r:: ,:' ~~f~ :j .'" ,,-,-" :'--..) -"'1 1~;'1 C.:..J 'IMII~~ II!iI!Ili _1:" ',~",) r<:.' c::::> -' .--, ~ -.'--C" :-- -< 16-i\\ ~.~-'-'''" ~ .-",-"= ~',""~'~"" ,..- - "" .~ " ~.~~~~~ ~.' , ,'" ~.......... ""hif,",-"'C';';("'~O;'-"'-,T_~' The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C VS Terry L. Richardson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-3709 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 J. Ddren. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30,00 20.00 1.00 9.66 15.00 1.51 $ 75.66 paid by attorney 3-13-02 Sworn and subscribed to before me so~s: -/~ -tW '-"n.. ~ ~..- -...<: /~ This ~day of 1/l1I.LUtJ . (l R. Thomas Kline, Sheriff 2002, A.D, ~,O lu,ebV;<jlJtp By-=JocU.{ Svvu:l::h Prothonotary Real Estate Deputy . ~o I y cA. a.5'4"oll i&u, j:i.:d;L'f :~"""'F'~"~~' ~ .__.~. d'. - ~CJ ~ . , --i .~ " '" ,~ ~-~ ll1Lo_ 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 ~ The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 . NO. 01-3709 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C, 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: 9 William Penn Drive, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Terry L. Richardson 9 William Penn Drive, Camp Hill, Pa 17011 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 Lower Allen Township 1993 Hummel Ave., Camp Hill, PA 17011-5983 Lower Allen Township Authority 120 Limekiln Rd., New Cumberland, PA 17070 ~ - '" -"" ,"~~J ,--_u -~'"- , &. .j ~-, ,~' J ,-,' '-~ " .~ '",,\ws 4. Name record: Name - . , and address of the last recorded holder of every mortgage of Address Plaintiff herein. See Caption above. Alternative Lending Mortgage Corp. ~ 305 5th St., Bay City, MI48708 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 9 William Penn Drive, Camp Hill, Pa 17011 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 tnat false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: January 7, 2002 I rk J Udren, E Q. ,-..___/ Attorney for P aintiff ,''''~'''" ,-,. ,,,,- ~ ' ..~~ _~h' _~.., ,L:." ,v :l!~'r;l!I;hjf_~", ... ,-. 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 " The Bank of New York as Indentured Trustee for The Money Store Trust 1998-C Old County Road Suite 429 Carle Place, NY 11514 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Terry L. Richardson 9 William penn Drive Camp Hill, Fa 17011 . NO. 01-3709 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry L. Richardson 9 William Penn Drive Camp Hill, Pa 17011 Your house (real estate) at 9 William Penn Drive, Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce tne court judgment of $51,622.61, 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 ABT,E TO PREVENT THTR SHERIFF'S SJl.T,E To prevent this Sheriff's Sale, you must take immedia~e a~~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. 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.) ,;;."'-" - ~""., . ~ J ~ o~. ~." "".. .', ;;;- ~_-"'8,,' .. 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. back, if You may also have other rights and you act immediately after the sale. defenses, or ways of getting your home YOU SlIOULD 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 LSGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 717-249-3166 ~ ~,...,~ ~^.d-'" ,I " ,~ , -,~ " ,- -\' '-'j-- If '"i\,i;;;- - .. ALL TIlAT CERTAIN ALLEN, COUNTY OF FOLLOWS, TO-WIT: PIECE OR PARCEL OF LAND SITUATE AND BEING IN THE TOWNSHIP OF LOWER - , CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, AND DESCRIBED AS " BEGINNING AT A POINT ON THE SOUTHERLY LINE OF WILLIAM PENN DRIVE (FIFTY (50) FEET WIDE), AT THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9, BLOCK "B" ON THE HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING THREE HUNDRED EIGHTY-TWO AND ONE TENTH (382.1) FEET MEASURED WESTWARDLY FROM THE INTERSECTION OF ALLEN ROAD; THENCE SOUTH 31 DEGREES 39 MINUTES EAST ALONG SAID DIVIDING LINE A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO LOT NO. 12 ON SAID PLAN; THENCE ALONG LOTS NOS. 12 AND 13, SOUTH 58 DEGREES 21 MINUTES WEST A DISTANCE OF SIXTY (60) FEET TO LOT NO. 7 ON SAID PLAN; THENCE ALONG SAID LOT NO.7, NORTH 31 DEGREES 39 MINUTES WEST A DISTANCE OF ONE HUNDRED TWENTY (120) FEET TO ,'}JlRE"SOUTHERLY LINE OF WILLIAM PENN DRIVE; THENCE ALONG WILLIAM PENN DRIVE, NORTH 58 DEGREES 21 MINUTES EAST A DISTANCE OF SIXTY (60) FEET TO A POINT, THE PLACE OF BEGENNING. BEING KNOWN AS 9 WILLIAM PENN DRIVE, CAMP HILL, PA 17011 PROPERTY ID NO.: 13-24-0797-104 TITLE TO SAID PREMISES IS VESTED IN TERRY L. RICHARDSON, A SINGLE WOMAN BY DEED FROM GEORGE H. FOSTER, JR., AND DORIS J. FOSTER, HUSBAND AND WIFE, DATED 10/25/97, RECORDED 11/26/97, IN DEED BOOK 168, PAGE 586. I ~ i -"'~~- ~ , ~I .,. ~~ -i>l~a }l.u,~'\"'-~ ' , I .~ ,~ U" ~~ "=~-- . WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3709 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cwnberland COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK AS INDENTURED TRUSTEE FOR THE MONEY STORE TRUST 1988-C PLANTIFF(S) From TERRY L. RICHARDSON, 9 WILLIAM PENN DRIVE, CAMP HILL, P A 17011 (1) You are directed to levy upon the property of the defendant( s) and to sell SEE LEG.(\L DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession ohnyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $51,622,61 Interest FROM AUGUST 4,2001 TO DATE OF SALE JUNE 5, 2002 PER DIEM @ 13,87 L.L. Atty's Comm % Atty Paid $173.09 Plaintiff Paid Due Prothy $ 1.00 Other Costs Dale: JANUARY 14, 2002 CURTIS R, LONG Prothonotary, Civil Division ~ ~(J~ L', Q 7l?/J~0F!J REQUESTING PARTY: Name MARK J, UDREN, ATTY Address: MARK J, UDREN & ASSOCIATES 1040 N, KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 \ Attome\ for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No, 04302 ,,-- ..,- "">.!",=,i""'-'~',d" ,-;"';"'~" ','...c-'__''-''''-;''' -- ,<,'(<,,;-,,; ""~_..I"'__"".",,,,,.',,,,,,,,,"'_~n.,o.,'_h"<'___""~'OIiIillJ~' ~ ',i < REAL ESTATE SALE No. ,3 On February 5,2002, the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A, known and numbered as 9 William Penn Drive, Camp Hill, and more fully described on Exhibit "A" filed Date: February 5,2002 By: JD~ JVV1.JJ~ Real Estate Deputy -, ,-"::;:)j \","A ...... -"':'#\) <'~,,~ ~~;; ~ ~ with this writ and by this reference incorporated herein. \{1~IVt\I,iC;NH3d -, ..-,,\----'r't " 201 ~d EE 2 rl HVr UHI1~j:'i, id8riflO ~~11l3HS "iLL .:10 3~1.:l;lO ,~-."~,-,~""~"~"",,,,,_~~ ~~" ~,-"',~_" .,,,\,"-"""''' _'''~U~ ' ,,- - ,""', ,"- c. ]:;