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HomeMy WebLinkAbout07-1866UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION 577 Lamont Road Elmhurst, IL 60126 :Cumberland County Plaintiff V. Robert Ryan, Jr. Michelle Ryan NO. I 1359 Zimmerman Road ?lUL Carlisle, PA 17013 Defendant(s) 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar 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. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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 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. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Household Finance Consumer Discount Company Recording Date: LODGED FOR RECORDING 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: 1359 Zimmerman Road MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township COUNTY: Cumberland DATE EXECUTED: 6/2/04 DATE RECORDED: 6/7/04 BOOK: 1868 PAGE: 3982 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 Mortgage 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 1/30/07: Principal of debt due $146,680.26 Unpaid Interest at 8.4t* from 9/2/06 to 1/30/07 (the per diem interest accruing on this debt is $33.76 and that sum should be added each day after 1/30/07) 10,319.15 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of $56.33 should be added in accordance with the terms of the note each month after 1/30/07) 225.32 Extension Interest Due 5,260.65 Recoverable Advance 3,870.17 Attorneys Fees (anticipated and actual to 5% of principal) 7,334.01 TOTAL $174,294.56 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the 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 $174,294.56 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 Legal Description ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A SPIKE IN THE CENTER OF THE PUBLIC ROAD LEADING FROM CHURCHTOWN TO THE YORK ROAD AT THE LINE OF LAND NOW OR FORMERLY OF DR. WILLIAM BROD; THENCE BY SAID LATTER LANDS, SOUTH 77 DEGREES 30 MINUTES WEST, 159.5 FEET TO A POINT; THENCE BY LANDS FORMERLY OF MERLE EDWARD MILLER, ET UX., NORTH 30 DEGREES 30 MINUTES WEST, 51.5 FEET TO A STAKE; THENCE BY LAND NOW OR FORMERLY OF WILSON P. HURLEY AND HELEN L. HURLEY, HIS WIFE, NORTH 59 DEGREES 30 MINUTES EAST, 150 FEET TO A SPIKE IN THE CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE CENTER OF SAID ROAD, SOUTH 30 DEGREES 30 MINUTES EAST, 100 FEET TO A SPIKE, THE PLACE OF BEGINNING. SAID PREMISES BEING DESCRIBED ACCORDING TO A SURVEY OF W.G. RECHEL, REGISTERED SURVEYOR, DATED OCTOBER 8, 1958 THE ABOVE-DESCRIBED PREMISES HAVING THEREON ERECTED A DWELLING HOUSE AND OTHER IMPROVEMENTS WITH A MAILING ADDRESS OF 1359 ZIMMERMAN ROAD, CARLISLE, PENNSYLVANIA 17013. Page 1 of 1 February 16, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HHIPOTECA. EXHIBIT ,A program and they will assist you in submitting a complete application to the rennsyivania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your Page 2 of 2 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Robert Ryan Jr. Michelle, Rxan - - ----------- 1359 Zimmerman Road __Carlisle PA_17013 -----------..-.-_._.-------_____.._._-- ._Decisi©n.One Household Finance Consumer Discount Comaanv HOMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE PROGRAM 3MIT AWAY RF FT iGIRT F FOR FINANCIAL ASSISTANCE WMCi; CAN SAV F, YOUR HOME FROM FORF.CI.OSITRE AND HFT P YOIT MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE FACTO), 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. 't'F psRY STAY OF FORF.C-1.nSiTRF. -- 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 Oface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS WFTiNG MUST OCCITR WITHIN w r+r 0 HOW TO C1 THE YOUR MORT Te(ATE i REA1TT.TO RTC: CIE T JP TC) DATE_ CONSTTM 'R CREDIT COITNSFT iNG 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, nddrescec and telerhr numbers f r e meted oncnrn r c r f it rouncelingageneiec for he eountlE in which the nrnnerty is located Alre set forth nt the end of this, Native, It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPi ICATiON 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 Page 3 of 3 face- to-face meeting. YOU MIST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will. be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. 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.) NATURE OF THE DEFA TI,T -- The MORTGAGE debt held by the above lender on your property located at: 1359 Zimmerman Road Carlisle PA 17013 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: Monthly Payments of $1126.75 for October 2, 2006 through January 2, 2007 = $4507.00 43.05 for Februar 2 2007.31443.05 Montlily_Pa enfs "fl Monthl Late, Charges of $5633 for _October 2ti20(16_t _ffi.Februwr 2, 2$2$1.65 Other charges (explainritemize): NSF=$40.00 Other-429.70 Property Inspection=$10750 _TOTAL AMOUNT PAST B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Ih no use if not ap li -ahl .): NU 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 S67041Sb- PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa=ent¢ mnet he matey rash achier'c rherk, certified check mon" order mnde payaHe and gent to* Ildren Law Offirec. P. C_ Wanderest C:=orate Center 111 W eres Rand, Suite 200 assume the mortgage (leDt, proVaaea Mal all Lae UULSLauL1111g pay111e11LS, WliUg'CZ? attu aLtv111Gy a 1GGA aIIU ,,vJw are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 4 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (]?n rent nce if not anplicahle l: NIA W YOU DO NOT-CURE, THE DEFATIT.T -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the. lender in ends to exercise its nights 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 'T'HIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose tjnon your mortgaged nr =nerty_ IF THE MORTGAGF TS 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 begins legal proceedings against you, you will still, be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, 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 $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you Ire he defy tl within -the, TTIIRTY ( )- DAY netjad, you will not he rjen tired to ntt"ex's rn fees. OTHER I ENDER RF.MFDMS -- The lender may also sue you personally for the unpaid principal. balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffumied it, then lender cannot pursue this remedy. IS SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, y'1 still have the naant to mire the nefanlt and prevent the sale at any time. up to on?,, hour he-fore the Sheri ff's Sale You n1- d to reacnnahle_attome ' Day;na the total amount then c d to pills n)? late or other h rgec then cost, connected with the, fnre lmure c le. „nd any other rests annected with the Sh off c Sale as c ctfied - 1- .U- t_..ao. --A h„ .,Arfr,rm;no anv other reouimments tinder themortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. FART TEST POSSTBT F SHFRTFF'S SATE DATF. -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approAmately_ months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: __ H$BC Mortgage Services Inc _---_-------_--__.....___....._..------._......... Address: 636 Grand Regency Blvd. - ------------ Phone Number: Fax Number: Contact Person: FFFFCT OF SHERTIFFIS SATE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSiMIMON OF MORTGAGE -- You may not transfer your home to a buyer or transferee who will ., , , . .,.., ..... _11 `1-- ---`-`---.L__- ..1.----- --- I ..M...... n..?., F..?n n-a --,#o Page 5 of 5 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. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 6 of 6 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 CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN 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- a TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717)541-1757 FAX (717) 541-4670 Urban League; of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle. PA 17013 (717)243-3818 FAX (71.7) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 -? Lac 6r n r n ?a' t3 nos ?'` {1}CoJ\1• i V ` 1 rr r;1 Pw- I ae_i V- 1 .t , r 0 t O t . O Ln u, ++33 co:. co xi m UU $ Q : n PasleQe ims-50 -n -g Postmafi CertN+ed Fee i p ware p ?3 Retum Receipt Fee O' fl (EndormenlRege+sed) C1: ReaMcled DetiveN Fee C3 (Endr?rement Requ!red} o'. a rq TOW & Feel n3' N _ -0 p. D di, i W 00 m Q 2 O A CD c n Er 9 m 0 N a m N Z 3 Z L7 M 6^ fL 1n 0 'O C] M M Er E3 Q' 02 I.n PU M 0 S ?J V' L r r e V - ? ' f C ? f'ti imp? co ^ - co C C1-E ?3Gm( i Ln . ,n ru 0, ?gNar. ? .- ? p F uc ? ? }fin SvM? 2tG•' co . cc UNa M O Postage $ . Cart>tisd Fee Postmark II' 0 i 7c?^ N•`e Renim ReCAiDU ed CS' C] i } (Endorsam,3n',Peq r-3 O Pe i6etod Detlver,: Fee meM Ragtnmdl O in : Ul (Fndorrn rR N Totat postage & Fees sent D n o or Po Eox nr S. S _ _---? AYW. 12-1 tier _ -o Do -n j Oj O: C3 C3 6" 0 31 t?d 9 t i.' d Er ;cr L!'1 M iv p N N m w h P D V E R I F I CAT I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. VA^ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. rC.) (J '69 ? c [ ? C.:) WSJ N" 10 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. Robert Ryan, Jr. :NO. 07-1866 CIVIL TERM Michelle Ryan Defendant (s) PRAECIPE 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: May 30, 2007 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire Attorney for Plaintiff fs V E R I F I C A T I O N 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: 4113o `67 Name : J ELLE BRAY Attorney in Fact Title. Company: H BC Financial Services as ser er on behalf of Household Finance Consumer Discount Company Robert Ryan, Jr. Michelle Ryan Loan #0008803298 MJU #07010573 rlo a -c F -c Ti ' : ! -'; 3 rn ro ca UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer Discount Company 577 Lamont Road Elmhurst, IL 60126 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Robert Ryan, Jr. Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 Defendant (s) NO. 07-1866 CIVIL TERM 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) Robert Ryan, Jr. and Michelle Ryan 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 1/31/07 to 5/30/07 Late charges per Complaint From 1/31/07 to 5/30/07 $174,294.56 4,051.20 225.32 TOTAL $178,571.08 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. LAW PFKCES, P.C. DAMAGES ARE HEREBY ASSESSED AS I DATE : rk J *- Tdren, ESQUIRE torney for Plaintiff UDREN LAW OFFICES, P.C. BY: [ark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 C$ERRY BILL, NJ 08003 856-669-5400 Household Finance Consumer Discount Company Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Robert Ryan, Jr. Michelle Ryan Defendant(s) TO: Robert Ryan, Jr. 1359 Zimmerman Road Carlisle, PA 17013 N0. 07-1866 Civil Term DATE of Notice: May 18, 2007 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE 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 USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 , NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT TEIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO OLLECT A DEBT. ANY INFORMATION OBTAINED WILL1138 UPM FOR THAP4?URRQSE. V a an r v.aa ...aa, a...-..y... a... ?. Wo crest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAw OFFICES P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WIOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5600 pleadings re -com Household Finance Consumer Discount Company Plaintiff V. Robert Ryan, Jr. Michelle Ryan Defendant(s) TO: Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-1866 Civil Term DATE of Notice: May 18, 2007 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 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 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 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES A 9T, THIS LAW FIRM IS DRSeLBD TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT COLLECT A DEBT. ANY INFORMATION OBTAINED NXL% BE USED FOR TEAT PURPOSE. ark gn Esquire dcrest Corporate Center 11 J V Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 j{Lg UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-69Q0 ATTORNEY FOR PLAINTIFF Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION 577 Lamont Road !Cumberland County Elmhurst, IL 60126 Plaintiff MORTGAGE FORECLOSURE V. Robert Ryan, Jr. NO. 07-1866 Civil Term Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Minnesota COUNTY OF Dakota 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: Defendant: Age: Residence: Emplovment-l Robert Ryan, Jr. Over 18 As captioned above Unknown Michelle Ryan Over 18 As captioned above Unknown Title: tLLt 1:1,mwy Attorney in Fact Sw Vtoa scribed Compan : HSBC Financial Services be Zp day as se icer on behalf of Household Finance Consumer Discount Company of , 2007. o rY u lc s JAMES C. MORRIS NOTARY PUBLIC • MMINESOTA MY COMMISSION EXPIRES JAN. 31, 2 0 0.9 SHERIFF'S RETURN - REGULAR CASE NO: 2007-01866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS RYAN ROBERT JR ET AL RICHARD E SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RYAN ROBERT JR the DEFENDANT at 0644:00 HOURS, on the 27th day of April 2007 at 1359 ZIMMERMAN ROAD CARLISLE, PA 17013 MICHELLE RYAN a true and attested copy of COMPLAINT - MORT FORE by handing to WIFE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 37.60 Sworn and Subscibed to before me this day So Answers: R. T mas Kline 05/01/2007 UDREN LAW OFFICES By: puty Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-01866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS RYAN ROBERT JR ET AL RICHARD E SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RYAN MICHELLE the DEFENDANT , at 0844:00 HOURS, on the 27th day of April , 2007 at 1359 ZIMMERMAN ROAD CARLISLE, PA 17013 MICHELLE RYAN by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 ;r?j??r+•+?? .? Service .00 Affidavit .00 • Surcharge 10.00 R. Thomas Kline .00 16.00 00/00/0000 Sworn and Subscibed to By: before me this day D puty Sheriff of A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer €:COURT OF COMMON PLEAS Discount Company 'CIVIL DIVISION Plaintiff ::Cumberland County V. ;MORTGAGE FORECLOSURE Robert Ryan, Jr. NO. 07-1866 CIVIL TERM Michelle Ryan Defendant (s) To: Robert Ryan, Jr. 1359 Zimmerman Road Carlisle, PA 17013 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. X Judgment by Default Money Judgment Judgment in Replevin Prothonotary 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: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Robert Ryan, Jr. Michelle Ryan :NO. 07-1866 CIVIL TERM Defendant(s) To: Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary .; rl-?, S1311,0-1 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: 856-669-5400 C? r,3 O co UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Robert Ryan, Jr. :NO. 07-1866 CIVIL TERM Michelle Ryan Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $178,571.08 Interest From 5/31/07 3,308.48 to Date of Sale 9/5/07 Ongoing Per Diem of 33.76 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. rk Udren, ESQUIRE A TORNEY FOR PLAINTIFF ?V - w --'59. - e a 149. C c Q ?;? ? C a C - 3:0 w .. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1866 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From ROBERT RYAN, JR AND MICHELLE RYAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRITPION. (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 of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than 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 $178,571.08 L.L. $.50 Interest FROM 5/31/07 TO DATE OF SALE 9/5/07 - $3,308.48 - ONGOING PER DIEM OF $33.76 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm % Atty Paid $172.60 Plaintiff Paid Date: MAY 31, 2007 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Due Prothy $2.00 Other Costs lieputy Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Robert Ryan, Jr. :NO. 07-1866 CIVIL TERM Michelle Ryan Defendant(s) C E R T I F I C A T 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 LAW OFFICES, P.,9- ' Udren,--SSQUIRE EY FOR PLAINTIFF c? {' Cg ip i BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company ;CIVIL DIVISION Plaintiff :Cumberland County V. ;MORTGAGE FORECLOSURE Robert Ryan, Jr. ::NO. 07-1866 CIVIL TERM Michelle Ryan Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 Household Finance Consumer Discount Company, 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: 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert Ryan, Jr. Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 1359 Zimmerman Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Household Finance Consumer 577 Lamont Road Discount Company Elmhurst, IL 60126 5. Name and address of on the property: Name Monroe Township Municipal Authority Address 1220 Boiling Springs Road Mechanicburg, PA 17055 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 Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 Tenants/Occupants 1359 Zimmerman Road (Monroe Township) Carlisle, PA 17013 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. UDREN LAW OFFICES, P.C. DATED: May 30, 2007 ?N lr\ "z-' taWJ. Udren, ESQ. ttorney for Plaintiff every other person who has any record lien q - n ?, ?, -?,`? ? ?? ; ,; ? ...? -? i._ '- ? ( ? ?? .10 4 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Robert Ryan, Jr. €:NO. 07-1866 CIVIL TERM Michelle Ryan Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert Ryan, Jr. 1359 Zimmerman Road Carlisle, PA 17013 Your house (real estate) at 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $178,571.08, 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 immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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.) w C 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 856-669-5400. 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 856-669-5400. 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ??? ? erns r or UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff .Cumberland County V. =MORTGAGE FORECLOSURE Robert Ryan, Jr. ::NO. 07-1866 CIVIL TERM Michelle Ryan Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 Your house (real estate) at 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $178,571.08, 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 immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 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.) f YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 856-669-5400. 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 856-669-5400. 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 © ? Q n '? ° g CASE NO: 2007-01866 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS RYAN ROBERT JR ET AL RICHARD E SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE RYAN ROBERT JR DEFENDANT the at 0844:00 HOURS, on the 27th day of April , 2007 at 1359 ZIMMERMAN ROAD CARLISLE. PA 17013 was served upon by handing to MICHELLE RYAN (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 3/???07 37.60 Sworn and Subscibed to before me this day So Answers: iL R. T omas Kline 05/01/2007 UDREN LAW OFFICES By. puty Sheriff of A. D. CASE NO: 2007-01866 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS RYAN ROBERT JR ET AL RICHARD E SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RYAN MICHELLE the DEFENDANT , at 0844:00 HOURS, on the 27th day of April , 2007 at 1359 ZIMMERMAN ROAD CARLISLE, PA 17013 by handing to MICHELLE RYAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 S/.2d-,b 7 L?. 16.0 0 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 00/00/0000 By. lputyi Sheriff A.D. Household Finance Consumer Discount Company In the Court of Common Pleas of VS Cumberland County, Pennsylvania Robert Ryan, Jr. and Michelle Ryan Writ No. 2007-1866 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 19, 2007 at 2030 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Robert Ryan, Jr. and Michelle Ryan, by making known unto Michelle Ryan personally and wife to Robert Ryan, Jr., at 1359 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2007 at 1809 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert Ryan, Jr. and Michelle Ryan located at 1359 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Robert Ryan, Jr. and Michelle Ryan, by regular mail to their last known address of 1359 Zimmerman Road, Carlisle, PA 17013. These letters were mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriffs Costs: Docketing 30.00 Poundage 80.00 Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 11.52 Levy 15.00 Surcharge 30.00 Law Journal 355.00 Patriot News 398.33 Share of Bills 15.69 $ 968.04 C. So Answers: R. Thomas Kline, Sheriff 9/iJ/,' 7 BYEI / Real Estate ergeant 4 w UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer Discount Company Plaintiff V. Robert Ryan, Jr. Michelle Ryan Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-1866 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Household Finance Consumer Discount Company, 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: 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert Ryan, Jr. 1359 Zimmerman Road Carlisle, PA 17013 Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:. Name Address none 4. Name and address of the of record: Name last recorded holder of every mortgage Address Household Finance Consumer Discount Company 577 Lamont Road Elmhurst, IL 60126 v A 5. Name and address of every other person who has any record lien on the property: Name Address Monroe Township 1220 Boiling Springs Road Municipal Authority Mechanicburg, PA 17055 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 Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 Tenants/Occupants 1359 Zimmerman Road (Monroe Township) Carlisle, PA 17013 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. UDREN LAW OFFICES, P. DATED: May 30, 2007 Vi. Udren, ESQ. torney for Plaintiff 4 "? s -a `'?. r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer Discount Company Plaintiff V. Robert Ryan, Jr. Michelle Ryan ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-1866 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert Ryan, Jr. 1359 Zimmerman Road Carlisle, PA 17013 Your house (real estate) at 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $178,571.08, 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 OWN'ER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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.) YOII Y STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS WM 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 856-669-5400. 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 856-669-5400. 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 t ) UDREN LAW OFFICES, P.C. BY: Nark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer Discount Company Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Robert Ryan, Jr. Michelle Ryan Defendant(s) MORTGAGE FORECLOSURE NO. 07-1866 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 Your house (real estate) at 1359 Zimmerman Road, (Monroe Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $178,571.08, 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 OiNNBR'S RI=TS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 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.) • A YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVRN IF THE SHERIFF'S SALE DOES TARE 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 856-669-5400. 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 856-669-5400. 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 "1 ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A SPIKE IN THE CENTER OF THE PUBLIC ROAD LEADING FROM CHURCHTOWN TO THE YORK ROAD AT THE LINE OF LAND NOW OR FORMERLY OF DR WILLIAM BROD; THENCE BY SAID LATTER LANDS, SOUTH 77 DEGREES 30 MINUTES WEST, 159.5 FEET TO A POINT; THENCE BY LANDS FORMERLY OF MERLE EDWARD MILLER, ET UX., NORTH 30 DEGREES 30 MINUTES WEST, 51.5 FEET TO A STAKE; THENCE BY LAND NOW OR FORMERLY OF WILSON P. HURLEY AND HELEN L. HURLEY, HIS WIFE, NORTH 59 DEGREES 30 MINUTES EAST, 150 FEET TO A SPIKE IN THE CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE CENTER OF SAID ROAD, SOUTH 30 DEGREES 30 M 41MS EAST, 100 FEET TO A SPIKE, THE PLACE OF BEGINNING. SAID PREMISES BEING DESCRIBED ACCORDING TO A SURVEY OF W.G. RECHEL, REGISTERED SURVEYOR, DATED OCTOBER 8, 1958 THE ABOVE-DESCRIBED PREMISES HAVING THEREON ERECTED A DWELLING HOUSE AND OTHER IMPROVEMENTS WITH A MAILING ADDRESS OF 1359 ZIMMERMAN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING KNOWN AS: 1359 ZIMMERMAN ROAD, (MONROE TOWNSHIP) CARLISLE, PA 17013 PROPERTY ID NO.: 22-10-0640-043 TITLE TO SAID PREMISES IS VESTED IN ROBERT RYAN, JR. AND MICHELLE RYAN, HUSBAND AND WIFE BY DEED FROM PAUL E. HOFFMAN AND FLORENCE N. HOFFMAN, HUSBAND AND WIFE & DONALD R. OHRUM, WIDOWER DATED 6/2/04 RECORDED 6/7/04 IN DEED BOOK 263 PAGE 2066. • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-1866 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From ROBERT RYAN, JR AND MICHELLE RYAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRITPION. (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 of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than 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 $178,571.08 L.L. $.50 Interest FROM 5/31/07 TO DATE OF SALE 915/07 - $3,308.48 - ONGOING PER DIEM OF $33.76 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm % Due Prothy $2.00 Atty Paid $172.60 Other Costs Plaintiff Paid Date: MAY 31, 2007 (Seal) lieputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 eea GO Real Estate Sale # 43 On June 5, 2007 the Sheriff levied upon the defoWent's in t the zeal prosy Waft in Mom Township, Cumberland County, PA Known and numbered as 1359 Zimmerman Road, Carlisle, more fully described on Exhibit "A„ filed with this writ and by this reference incorporated herein. I), ', une;5, 29 By. ? J4 Real Esta Sergeant 9 , .Z d 0- NN loll E . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 20, July 27, and August 3, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this day of August. 2007 Notary NOVOK sm DNORM A COLLWS NOW K&ft CARER WW. CtM?AND COtMi1Y Mr COMMM LVku Apr M{. 2010 SMA16 MOM= SO& 1W 48 Writ No. 2007-1866 Civil Household Finance Consumer Discount Company vs. Robert Ryan, Jr. and Michelle Ryan Atty.: Mark Udren DESCRIPTION ALL THAT CERTAIN house and lot of ground situate in Monroe Town- ship, Cumberland County, Common- wealth of Pennsylvania, bounded and described as follows: BEGINNING at a spike in the center of the public road leading from Churchtown to the York Road at the line of land now or formerly of Dr. William Brod; thence by said latter lands, South 77 degrees 30 minutes West, 159.5 feet to a point; thence by lands formerly of Merle Edward t• Miller, et ux., North 30 degrees 30 minutes West, 51.5 feet to a stake; thence by land now or formerly of Wilson P. Hurley and Helen L. Hurley, his wife, North 59 degrees 30 minutes East, 150 feet to a spike in the center of the aforesaid public road; thence:' by the center of said road, South 30 degrees 30 minutes East, 100 feet to a spike, the place of beginning. SAID premises being described according to a survey of W.G. Rechei, Registered Surveyor, dated October 8, 1958. THE awe-deed prdo"We ham 1M111+aon aaaI I a brMM a?od ulllrer iNOM i111M111M 7 as saw' >C?wiw loll. Grle, l?n?a 1'rdl3. BEING KNOWN AS: 1359 Zim- merman Road, (Monroe Township) Carlisle, PA 17013. PROPERTY ID NO.: 22-10-0640- 043. TITLE TO SAID PREMISES IS VESTED IN Robert Ryan, Jr. and Michelle Ryan, husband and wife by deed from Paul E. Hoffman and Florence N. Hoffman, husband and wife & Donald R. Ohrum, widower dated 6/2/04 recorded 6/7/04 in Deed Book 263 Page 2066. k03' l?tSiAT?Jt' ?lkiU?4 Y1G10?1 fly' ;':') :^4VJ513W'W3 .0906 31a3AAo YM _S 6; jqA aa4F x3 ??aazaimmor• s THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS . Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County ofDaupbin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September I Sth,1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1sl day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #43 Sworn to and subscribed before me this 20th day of August 2007 A.D. COMMONWEALTH OF PENivSYLVAfNIA Notarial Seal Tarty L Russell, Notary Public City Of rg, Dauphin County Expires June 6, 2010 em r, Sylvania a ati of Notarlas NOTARY UBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 5 f t 1 a ` r.. . , :) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, .SUITE 200 CHERRY HILL, NJ 08003-3620 856-669.-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company =CIVIL DIVISION 577 Lamont Road :Cumberland County Elmhurst-, IL 60126 Plaintiff =NO. 07-1866 CIVIL TERM V. Robert Ryan, Jr. Michelle Ryan 1359 Zimmerman Road Carlisle, PA 17013 Defendant(s) PRAECIPE TO MARK SETTLED, DISCONTINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED, upon payment of your costs only. Mark A. U ren, Esquire UDREN ieLV OFFICES, P.C. Attorne for Plaintiff DATED: October 10, 2007 ttia ?.? ? 4?_ -.., ? ??? ? I { ? ?y4 ?.. ? ?.??•rn \ ??,?