HomeMy WebLinkAbout01-5957MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINOS HIOHWAY, SUITE SO0
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage Corp.
P.O. Box 57038
Irvine,.CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
i CiVIL DIVISION
:Cumberland County
Geraldine E. Shultz
Irvin L. Shultz
200 East Locust Street
Mechanicsburg, PA 17055
Defendant(s)
NO. - Kq$7
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, ~O TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
Le hah 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 o en
persona o con un abogado y entre~ar a la corte en forma escrita sus
defensas o sus objeciones a las 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 o
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 o sus propiedades u otros
derechos importantes para usted.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of thc 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 mall 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
/s/Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
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: Option One Mortgage Corporation DBA, H&R Block Mortgage
Assignee: Wells Fargo Bank Minnesota, National Association
F/K/A Norwest Bank Minnesota, National Association, as
Trustee for SASCO Mortgage Loan Trust, 1999-BC4
Recording Date: 7/23/01 Book: 679 Page: 3257
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
The information regarding the Mortgage being foreclosed
follows:
is as
MORTGAGED PREMISES: 200 East Locust Street
5~JNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg
COUNTY: Cumberland
DATE EXECUTED: 6/24/99
DATE RECORDED: 7/13/99 BOOK: 1556 PAGE: 915
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
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
10/12/01:
Principal of debt due and unpaid
Interest at 9.5%*
from 11/1/00
to 10/12/01
(the per diem interest accruing on
this debt is $19.16 and that sum
should be added each day after
10/12/01)
$73,629.70
6,630.70
Title Report
250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs)
280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $77.20 and that sum should
be added on the first of each
month after 10/12/01)
850.72
Late Charges
(monthly late charge of $37.46
should be added on the fifteenth of
each month after 10/12/01)
374.60
Other Fees
1,567.10
Attorneys Fees (anticipated and actual
to 5% of principal)
TOTAL $87,264.31
* This Interest Rata is subject to adjustment as more fully set
forth in the Mortgage and Note.
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 $87,264.31 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
Mark J.'Udre~j'
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN TEE BOROUGH OF MECHANICSBUR~,
COUNTY OF CUMBERLAND A~D COI~0NWEALTH OF PENNSYLVANIA, BOUNDED ~ DESCRIBED
ACCORDING TO A SURVEy MADE EY ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED MAY
24, 1974, AS FOLLOWS~
BEGINNING AT A POINT REING THE SOUTHEAST CORNER OF THE INTERSECTION OF LOCUST
STI~EET AND RACE STEEET~ THENCE BY THE SOUTHERN LINE OF LOCUST STREET, NOETH 77
DE~REES 30 MINUTES EAST 32.7 FEET TO THE WESTERN LINE OF LANDS NOW OR FORMERLY OF
FLORENCE SWARTZ~ THENCE ALON~ SAID SWARTZ LARD, SOD'£~ 12 DEGREES 30 MINUTES HAST
42.5 FEET TO A POINT~ THENCE CONTINUIN~ ALON~ THE SAME SOUTH 16 DE~REES 55 MINUTES
EAST 152.7 FEET TO A POINT ON THE NORTHERN LINE OF ST. JOHNS ALLEY~ THENCE ALON~
THE SAME SOUTH 77 DEGREES 30 MINUTES WEST 32 FEET TO THE EA-~TERN LINE OF HACE
STREET~ THENCE ALON~ THE EASTERE LiNE OF RACE STKEET NORTH 16 DEOI~EES 41 NI~'~'~S
WEST 170.7 FEET TO A POINT~ THENCE CONTINUIN~ ALONG THE SAME NOHTH 12 DEGP. EES 30
MINUTES WEST 24.5 FEET TO THE POINT OF BEGINNINg.
BEIN~ KNOWN AND NUMBERED AS 200 EAST LOCUST STREET.
February 02, 2001
Irvin L Shultz
Geraldine E Shultz
200 E Locust Street
Mechanicsburg, PA 17055
Homeowners Name: Irvin L Shultz
Geraldine E Shultz
Property Address: 200 E Locust Street, Mechanicsburg PA 17055
Loan Account No.: 178804-1
Original Lender: Option One Mortgage
Current Lender/Servicer: Option One Mortgage Corporation
HOMEOWNER,S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAl,
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE ~ HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must
arrange and attend a "face-to-face,, meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CAT.T.~D "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
OP171
EXHIBIT A
Re: Loan No. 178804-1
OPTION
ONE
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this Notice,
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of designated ~onsumer credit counselinq agencies for the~county in
which the property is located are set forth at the end of this Notice.
It is only necessary to schedule one face-to-face meeting. Advise
your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default.) If you have
tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY ~
YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED,
AGENCY ACTION - Available funds for emergency mortgage assistance
are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your
application.
OP171
Re: Loan No. 178804-1 Oi~]~
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply, for
Emergency Mortgage Assistance.)
**********************************************************************
HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
NATURE OF THE DEFAULT ~ The MORTGAGE debt held by the above lender on
your property located at:
200 E Locust Street, Mechanicsbur~ PA 17055
IS SERIOUSLY IN DEFAULT because:
months and the following amounts are now past due:
(a) Monthly payments: 1 MONTHS @ $ 701.53
2 MONTHS @ $ 701.53
(b) Previous late charges;
(c) Other charges; Escrow, Inspection,
NSF checks
(d) Other provisions of the mortgage obligation,
if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED
AS OF ~HIS DATE
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the followin~
B. YOU HA~-E FAILED TO TAKE THE FOLLOWING ACTION
applicable):
$ 2104.59
$ 74.92
$ 0.00
$ 0.00
$ 2179.51
(Do not use if not
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $2179.51, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
~ayments must be made either by cash, cashier,s check, certified
check or money order made payable and send to:
Overnight Mail Address
3 Ada
Irvine, Ca. 92618
Western Union Quick Collect
Pay to: Option One Mortgage Corporation
Code City: Option, Ca
You can cure any other default by taking the
thirty (30) days of the date of this letter.
(applicable.)
following action within
(Do not use if not
0P172
Re: Loan No. 178804-1
IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within
THIRTY. (30) DAYS of the date of this Notice, the lender intends to
exercise its rights to accelerate the mortgage debt.
This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to,pay the
mortgage in monthly installments. If full payment of the total amount
past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your
mortgaged property.
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 the
lender brings legal proceedings against you, you will still be required
to pay the reasonable attorney's fees that were actually incurred, up
to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable attorney's fees actually incurred by the
lender even if they exceed $50.00. Any attorney's fees will be added to
the amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period, you
will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF,S SAT,~ - If you have not
cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriff's
Sale. You may do so by paying the total amount then past due~ plu~
any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs
connected with the Sheriff's Sale as specified in writing by the
lender and by performing any other requirements under the mortgage.
Curing your default in the manner set forth in this notice will
restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriff's Sale of the mortgaged property
could be held would be approximately (7) SEVEN Months from the date
of this Notice. A notice of the actual date of the Sheriff's Sale
will be sent to you before the sale. Of course, the amount needed
to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment or action will be
by contacting the lender.
OP173
OPTION
ONE
Re: Loan No. 178804-1
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
Address:
Phone Number:
Fax Number:
Contact Person:
Office hours:
Option One Mortgage Corporation
3 Ada
Irvine, CA. 92618
800-326-1500, Ext. 8004
949-784-6032
Rushie Taylor x5769
Monday through Thursday 7:00 a.m. to 9:00 p.m.
Friday 7:00 a.m. to 6:00 p.m. PST.
PST
EFFECT OF SHERIFF,S SALE - You should realize that a Sheriff's Sale will
end your ownership of the mortgaged property and your right to occupy it.
If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could
be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You __ may or X may not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the
other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT TO:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
OP174
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Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents.~ T~e undersigned understands that
this statement herein is made. subject to the penalties of 18
Pa.C.S. Section 4904 ~relating to unsworn falsification to
authorities.
Mark J.
MARK J.
Udren, ESQUIRE
UDREN & ASSOCIATES
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KIN~S HIGHWAY, SUITE 500
CHE~Y HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
Defendant(s)
ATTOR1TEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
!CIVIL DIVISION
. Cumberland County
:
]NO. 01-5957 Civil Term
PRA~CIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
DATED: November 23, 2001
MARK J. UDREN & ASSOCIATES
BY ~~rk ~.~dren, Esquire
~ Attorney for Plaintiff
VERIFICATION
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer of the
Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
are taken from records maintained by persons supervised by the
undersigned who maintain the business records of the mortgage held
by Plaintiff in the ordinary course of business and that those
facts are true and correct to the best of the knowledge,
information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
~ARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue,
Lemoyne, PA 17043
Apt. #4
Defendant (s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
~ CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURB
NO. 01-5957 Civil Term
PP, AECIPE FOR OuuGMENT FOR FAILUR~ TO
A~SWER AND ASSESS~.WT OF DAMA~F_,~
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant(s) for failure to file an Answer to Plaintiff's Complaint
within 20 days from service thereof and for foreclosure and sale of the
mortgaged premises, and assess Plaintiff,s damages as follows:
As set forth in Complaint
Interest Per Complaint
From 10/13/01 to 11/23/01
Late charges per Complaint
From 10/13/01 to 11/23/01
Escrow payment per Complaint
From 10/13/01 to 11/23/01
$87,264.31
804.72
74.92
TOTAL
(1) the
of the Plaintiff
I hereby certify that addresses
Defendant are as shown above, and (2) that notice has been given
accordance with Rule 237.1, a copy of which is attached hereto.
REN & ASSOCIATES
/ ~ d. U_~zen, ESQUIRE
._J' ~ttorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED /9
PRO-gROTHY ~
and
in
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota, National
Association F/K/A Norwest Bank
Minnesota, National Association, as
Trustee for SASCO Mortgage Loan
Trust, 1999-BC4 c/o Option One
Mortgage Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue, Apt.
Lemoyne, PA 17043
Defendant(s)
#4
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-5957 Civil Term
DATED: November 12, 2001
TO: Geraldine E. Shultz
1137 Columbus Avenue,
Lemoyne, PA 17043
Apt. #4
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NO~IFiCACIO~ IHPDRTAN~E
USTED SE ENCUENTP~A EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBAALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTP~A
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
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AlfD THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORI~TION OBTAINED WILL BE USED FOR THAT
PURPOSE.
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE $00
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota, National
Association F/K/A Norwest Bank
Minnesota, National Association, as
Trustee for SASCO Mortgage Loan Trust,
1999-BC4 c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue, Apt.
Lemoyne, PA 17043
Defendant(s)
#4
ATTOP-NEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-5957 Civil Term
DATED: November 12, 2001
TO: Irvin L. Shultz
1137 Columbus Avenue,
Lemoyne, PA 17043
Apt. #4
IMPORTA/~OTICE
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 JUDGMENTMAY 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
717-249-3166
800-990-9108
NO~IF~CACIO~ IMPORTANTE
USTED SE ENCUENTEA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITAABA~70 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
717-249-3166
800-990-9108
NOTICE: PDRSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEHED TO BE A DEBT COLLECTOR Ah~D THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORKATIO~ OBTAINED WILL BE USED FOR THAT
PURPOSE.
MARK J. UDHEN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE $00
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
200 East Locust Street'
Mechanicsburg, PA 17055
Defendant (s)
ATTOP, NEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-5957 Civil Term
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF ~ :
COUNTY OF ~/'/ : SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended· and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment
Geraldine E. Shultz
Over 18
As captioned above
Unknown
Defendant: Irvin L. Shultz %
Age: Over 18 ~ ~~/~
Residence: As captioned above\~
Employment: Unknown !.1 ~
Title:~/-
Sworn to and subscribed comPar~y:
· 20
before me this
Notary ~
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue,
Lemoyne, PA 17043
Apt. #4
Defendant(s)
5OO
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
i CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
01-5957 Civil Term
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
Interest From November 24~ 200]
to Date of Sale ~
Per diem @$19.16
(Costs to be added) $
1.973.48
MARK J. .UDREN & ASSOCIATES
, ESQUIRE
'~/~,TTOR~EY FOR PI~h. INTIFF
MARK J. UDR~N & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue, Apt.
Lemoyne, PA 17043
#4
Defendant(s)
ATTOPd~EY FOR PLAINTIFF
: COURT OF COMMON PLEAS
i CIVIL DIVISION
: Cumberland County
· MORTGAGE FORECLOSURE
' NO. 01-5957 Civil Term
CERTIFICATE
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
)
)
)
(x)
( )
An FHA insured mortgage
Non-owner occupied
Vacant
Act 91 procedures have been fulfilled.
Over 24 months delinquent.
This certification is made subject to the penalties of 18
Sec. 4904 relating to unsworn falsification to authorities.
Pa. C.S.
~~REN & ASSOCIATES
l ) ~rk~'._. ATTORN~.yU~L~E~NQTUiI ~FE
~F~%RK J. UDREN & ASSOCIATES
~y: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTOP/~EY FOR PLAINTIFF
COURT OF COMMON PLEAS
i CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue, Apt. ~4
Lemoyne, PA 17043
Defendant (s)
01-5957
Civil Term
AFFIDAVIT pURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank
Minnesota, National Association, as Trustee for SASCO Mortgage Loan
Trust, 1999-BC4, 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: 200 East Locust Street, Mechanicsburg, PA 17055
1. Name and address of
Name
Geraldine E. Shultz
Owner(s) or reputed Owner(s):
Address
Irvin L. Shultz
2. Name and address of Defendant(s) in the judgment:
Name Address
1137 Columbus Avenue, Apt. #4, Lemoyne,
1137 Columbus Avenue, Apt. #4, Lemoyne,
PA 17043
PA 17043
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
NONE
4~ Name and address
£ecord:
Name
Plaintiff herein.
Eagle Nat'l Bank
Banc One Consumer Discount CO.
of the last recorded holder of every mortgage of
Address
See Caption above.
8045 West Chester Pike, Upper Darby, PA 19082
5001 Honin Dr., 2nd Floor
Mechanicsburg, PA 17055
Nat'l Bank of PA 4401 Market St., Camp Mill, PA 17011
Penn Housing Finance Agency 2101 N. Front St., Marrisburg, PA
5. Name and address of every other person who has any record lien on the
property: Address
Name
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.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Sq., Carlisle, PA 17013
13 N. Manover St., Carlisle, PA 17013
Bureau of Compliance, Dept. 280946
Marrisburg, PA 17128-0946
o
knowledge who has
the sale:
Name
Tenants/Occupants
Name and address of every other person of whom the plaintiff has
any interest in the property which may be affected by
Address
200 East Locust Street, Mechanicsburg, PA 17055
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.
M~J./~REN & ASSOCIATES
DATED: November 23, 2001 ~
rk . ESQ.
k~/ Attorney for Plaintiff
ATTORNEY FOR PLAINTIFF
~ J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE
CHERRY HILL, NJ 08034
856-482-6900
500
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Geraldine E. Shultz
Irvin L. Shultz
l137.Columbus Avenue, Apt. #4
Lemoyne, PA 17043
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-5957 Civil Term
TO:
Geraldine E. Shultz
1137 Columbus Ave.,
Lemoyne, PA 17043
Irvin L. Shultz
Apt.#4 1137 Columbus Avenue, Apt. #4
Lemoyne, PA 17043
Your house (real estate) at 200 East Locust Street, Mechanicsburg, PA
17055 is scheduled to be sold at the Sheriff's Sale on March 6, 2001, at
10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, PA, to enforce the court judgment of $88,221.15, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
N0~IC~E OF OWN'ER/,~u~RI~6~TS
Y.Q~F~E TO PREVENT THIS SHERIF"~
TO prevent this Sheriff's Sale, you must take ime~[
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:
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.)
YOU~ ~~ YOUR PROPE~]I~AND YOU HAV~QTHER RI~i{T~
~~I FF
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 scheduleunless 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 HA%rE A LAWYER OR
CANNOT AFFOI~D ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHER~ YOU CAN
---~ET LEGAL HELP.
LAWYER I~EFEP-RAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
'MARK'J. UDREN & ASSOCIATES
BY: Mark J. Udren
ATTY I.D. NO. 0%302
10%0 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 0803%
856-%82-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTOP, NEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
~CIVIL DIVISION
:Cumberland County
Geraldine E. Shultz
Irvin L. Shultz ~NO.
1137 Columbus Avenue, Apt. #4
Lemoyne, PA 17043
Defendant(s)
01-5957 Civil Term
~tFFIDAVIT OF SERVICE PURSUAi~T TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which
is attached hereto as Exhibit "A", was sent to every recorded lienholder and
every other interested party known as of the date of the filing of the
Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which
was signed for by Defendant(s) on the date specified on the said Return
Receipt. Copies of the said Notice and Return Receipt are attached hereto as
Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached
hereto as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said
Order is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P.
3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: February 4, 2002 --~N~K J. UDREN & ASSOCIATES
BY: · ~ ------ '"
Mark J. Udren, Esquire
Attorney for Plaintiff
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association, as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue,
Lemoyne, PA 17043
Apt. #4
Defendant(s)
ATTOP/~EY FOR PLAINTIFF
: COURT OF COMMON PLEAS
! CIVIL DIVISION
:Cumberland County
· MORTGAGE FORECLOSURE
: NO. 01-5957 Civil Term
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank
Minnesota, National Association, as Trustee for SASCO Mortgage Loan
Trust, 1999-BC4, 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: 200 East Locust Street, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Geraldine E. Shultz
1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043
Irvin L. Shultz
1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
NONE
4' Name
record:
Name
and address of the
Plaintiff herein.
Delta Funding Corporation
last recorded holder of every mortgage of
Address
See Caption above.
1000 Woodbury Road, Woodbury, NY 11797
Banc One Consumer Discount CO. 5001 Honin Dr., 2nd Floor
Mechanicsburg, PA 17055
4401 Market St., Camp Hill, PA 17011
Nat'l Bank of PA
Penn Housing Finance Agency 2101 N. Front St., Harrisburg, PA 17105
5. Name and address of every other person who has any record lien on the
property:
Name Address
NONE
6. Name and address of every other person who has any record interest
the property and whose interest may be affected by the sale:
Name Address
in
I Courthouse Sq., Carlisle, PA 17013
13 N. Hanover St., Carlisle, PA 17013
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
Real Estate Tax Dept.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
7. Name and address of
every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
200 East Locust Street, Mechanicsburg, PA 17055
Tenants/Occupants
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: February 4, 2002
MARK J. UDREN & ASSOCIATES
Mark J. Udren, ESQ.
Attorney for Plaintiff
F~%~R/( J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
National Association
F/K/A Norwest Bank Minnesota,
National Association,9 as
Trustee for SASCO Mortgage
Loan Trust, 1999-BC4
c/o Option One Mortgage
Corporation
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Vo
Geraldine E. Shultz
Irvin L. Shultz
1137 Columbus Avenue, Ap~. #4
Lemoyne, PA 17043
Defendanu(s)
ATTOR/~EY FOR PLAINTIFF
SO0
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-5957 Civil Term
DATE: December 7, 2001
TO: ALL PARTIES IN INTEREST ~ CLAIMANTS
NOTICE OF SHERIFF'S SALE
QF P~ P~O~T~
OWNER(S): GERALDINE E. SHULTZ & IRVIN L. SHULTZ
PROPERTY: 200 East Locust Street, Mechanicsburg, PA 17055
Improvements~ RESIDENTIAL DWELLING
The above captioned property is scheduled ~o be sold at the
~umherland County Sheriff's Sale on Mar~h~6~ll, at 10:00 A.M.,
at the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE,
PA. Our records indicate that you may hold a mortgage or judgment
on the property which will be extinguished by the sale. You may
wish to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after Sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
×HIBIT A