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Home My WebLink About01-04559NARK J. IIDREN & ASSOCIATES BY: Nark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive 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. YOII SHOIILD TAKH THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICH SBT FORTH BHLOW TO FIND OIIT WHERE YOII CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 Le han demandado a usted en la torte. Si usted quiere defenderse de esters demandas expuestas en las paginas siguientes, usted tiene veilZte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hate falter ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte 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 soya sin previo aviso 0 notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de ester demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes parer usted. LLEVE BSTA DENANDA A IIN ABOGADO INMEDIATAMENTE, SI NO TIENS ABOGADO O SI NO TIENE EL DINERO SIIFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAMB POR TELEFONO A LA OFICINA CIIYA DIRECCION SE ENCIIENTRA HSCRITA ABAJO PARA AVERIGIIAR DONDE SE PIIEDE CONSEGIIIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 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 flee stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (85~ 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 Assignments of Record to: Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 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: 23 Wheatfield Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland DATE EXECUTED: 6/7/99 DATE RECORDED: 6/17/99 BOOK: 1550 PAGE: 901 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 7/17/01: Principal of debt due and unpaid $172,181.49 Interest at 9.45 from 4/1/01 to 7/17/01 (the per diem interest accruing on this debt is $44.58 and that sum should be added each day after 7/17/01) 4,825.62 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 7/17/01) 0.00 Late Charges (monthly late charge of $87.48 should be added on the fifteenth of each month after 7/17/01) 735.36 Corporate Advance 96.00 Non-Sufficient Funds Charges 15.00 Other Fees 61.48 Attorneys Fees (anticipated and actual to 5~ of principal) 8,609.07 TOTAL $187,054.02 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. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has been sent as required on the date appearing on the copy attached hereto as Exhibit "A", 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 $187,054.02 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 r ALL THOSB CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESE% TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WIT8 SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY ,RONALD S. RAFFENSPERGER, REGISTERED SURVEYOR, DATED S$pTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COUNTY PLAN BOOK 52, PAGE-142, MORE PARTICIILARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE EASTERN RIGBT-OF -WAY LINE OF W88ATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET S0IIT8 OF T8E INTERSECTION OF T8E EASTERN RIGHT-OF-WAY LINE OF WBEATFIELD DRIVE AND THE SOIITHERN RIGBT-OF-WAY LINE OF WILD ROSH CIRCLE; THENCE ALONG LOT NO. 30 NORTH 85 DHGRBES 25 MINIITE3 EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT N0. ~32; THENCE ALONG LOT N0. 32 SOUTH 4 DEGREES 35 MINUTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT T88 NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIBLD DRIVE; T8ENC8 ALONG SAID RIGHT-OF-WAY AND A CURVE TO TH8 RIGHT HAVING A RADIUS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, TH8 PLACE OF BEGINNING. CONTAINING 17,671 3QIIARE FEET, MORE OR LESS. BEING IMPROVED WITH A DWELLING HOUSE, KNOWN AS AND NUMBERED 23 WBHATFIELD DRIVE, CARLISLE, PA 17013. OF-OS-01 MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 L•AN= •1792659 DATE=09-09 USER=RF3 KEY=0P171 VERS=012 TITLE=Part 1 Pennsylvania NOI lc FORM= LINES-PER-PAGE=NO CONDITIONS=9 ~~~-irfie) n~+~ciN~ ~ }DOO IS3a ooc3 SIHk kz}~- #} ~ttOo I S-'~ oc;~ j S~ 4 $ 42 8~ April 09, 2001 Ronald Johnson Catherine Johnson 23 Wheatfield Drive Carlisle, PA 17013 Homeowners Name: Ronald Johnson Catherine Johnson Property Address: 23 Wheatfield Driv, Carlisle PA 17013 Loan Account No.: 179265-9 Original Lender: OPTION ONE Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU_NAY_BE_ELIGIBLE_FOR_FINANCIAL ASSISTANCE_WHICH_CAN_SAVE_YOUR_HOME_FROM FORECLOSURE_AND_HELP_YOU_MAKE_FUTURE MORTGAGE •PAYMENTS n._ 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 fox thirty (30) tlays 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_CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT",_EXPLAINS'HOW_TO_BRING 'YOUR MORTGAGE UP TO DATE. OP171 E/~H~B~T /A OS-OS-O1 MSP LETTERWRITER ACTIVITY FOA MONTH OF 09-01 LOAN= 1792659 DATE=09-09 USER=RF3 KEY=0P171 VERS=012 TITLE=Part 1 Pennsylvania NOI lc FORM= LINES-PER-PAGE=NO CONDITIONS=9 Re: Loan No. 174265-9 a. 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_numbexs_ of designated_consumer credit_counseling_agencies for the county_in_ which the}nropert y_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 FOA 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 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. GP171 OS-OS-Ol MSP LETTERWRITER ACTIVITY FOR MONTH OF 09-O1 LOAN= 1742659 DATE=09-09 USER=RF3 KEY=0P172 VERS=023 TITLE=Part 2 Pennsylvania NOI LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 174265-9 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 A8 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: ' 23 Wheatfield Driv, _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: la) Monthly payments: 1 MONTHS @ $ 1,958.00 2 MONTHS @ $ 1,458.00 $ 9379.00 (b) Previous late charges; $_385.94 (c) Othex charges; Escrow, Inspection, NSF checks $_15.00 (d) Other provisions of the mortgage obligation, if any $_15.48 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $_4789.92 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (DO not use if not applicable): 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 $3389.92, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be_made either_by_cash, cashier's_check, _certified check_or_money_order_made_payab le_and_send_to: Overnight Mail Address Western Union Quick Collect 3 Ada Pay to: Option One Mortgage Corporation Irvine, Ca. 92618 Code City: Option, Ca You can cure any other default by taking the following action within thirty (30) days o£ the date of this letter. (DO not use i£ not (applicable.) OP172 lc FORM= .15 OS-O5-O1 MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN= 1742659 DATE=04-09 DSER=RF3 KEY=0P173 VERS=011 TITLE=Part 3 Pennsylvania NOI lc FORM= LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 179265-9 I F_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_int@nds_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 moat gage 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_uponyouur mort gaged~roperty. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lehder 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~eriod,youu wi11_not_be_required_to~ay_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_SALE - 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~aying_the_t of al_amount_then_past due, _,olus 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 wxiting_by_the lender and_by~erforming_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 05-05-01 MSP LETTERWRITER ACTIVITY FOR MONTH OF 04-01 LOAN= :742659 DATE=09-09 USER=RF3 KEY=0P179 VERS=016 TITLE=Part 4 Pennsylvania NOI LINES-PER-PAGE=NO CONDITIONS=O Re: Loan No. 179265-9 HOW TO CONTACT THE LENDER: Name of Lender: Option One Mortgage Corporation Address: 3 Ada Address: Irvine, CA. 92618 Phone Number: 800-326-1500, Ext. 6009 Fax Number: 999-789-6032 Contact Person: RAMON FZGUEROA X 5815 Office hours: Monday through Thursday 7:00 a.m. to 9:00 p.m. PST Friday 7:00 a.m. to 6:00 p.m. 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. lC FORM= OP174 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. `..,: . Mark Udren, ESQUIRE MARK UDREN & ASSOCIATES SHERIFF'S RETURN - REGULAR a~ ~> -. CASE NO: 2001-04559 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS JOHNSON RONALD ET AL DAVID MCKINN$Y Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON CATHERINE the DEFENDANT at 0831:00 HOURS, on the 1st day of August 2001 at 23 WHEATFIELD DRIVE CARLISLE, PA 17013 RONALD JOHNSON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ ~ day of `~ A.D. rot~ar~ So Answers: .~~~ R. Thomas Kline 08/02/2001 MARK UDREN v'lZI/V~.~-~i Deputy Sheriff „~~~~.~~ ~~"- CASE NO: 200]:-04559 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS JOHNSON RONALD ET AL D MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON RONALD the DEFENDANT at 0831:00 HOURS, on the 1st day of August 2001 at 23 WHEATFIELD DRIVE CARLISLE, PA 17013 RONALD JOHNSON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.90 Affidavit .00 Surcharge 10.00 .00 31.90 Sworn and Subscribed to before me this ~'~' day of aov/ A.D. '"_ rothonotary So Answers: ~~ R. Thomas Kline 08/02/2001 MARK UDREN By. G~/~1 J'// t~r~2!M/h~c-c/ Deputy Sheriff U MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff - V. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L: Johnson Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO TAE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: September 4, 2001 & ASSOCIATES BY: ..__._ ., ...__~_, .....1..~._., Attorney for Plaintiff . r . . 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: ~~ ~~'- v~ ~ ~. Name ` THY J. ILCI-IA1C Title quo nt Secretary Company: MARSC 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, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 . P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 'NO. 01-4559 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) 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 7/18/01 to 9/4/01 Late charges per Complaint From 7/18/01 to 9/4/01 Escrow payment per Complaint From N/A to N/A $187,054.02 2,184.42 87.48 4 TOTAL 5189,325.92 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above,~~d (2) that notice has been given in accordance with Rule 237.1, a ¢opk o~ which is attached hereto. & ASSOCIATES vrv a, .rvY~ for Plaintiff DAMAGES(~ARE HEREBY ASSESSED AS INDICATED DATE : J ~s,7 f-. ~'J ,~Q'j ) Ta DD! MARK J. DDREN & ASSOCIATES BY: Mark J. IIdrea, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term DATED: August 24, 2001 TO: Ronald Johnson a/k/a Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249--3166 or 800-990-9108 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 TERMING 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 PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PIIRSIIANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEENFSD TO 88 A DEBT COLLECTOR AND THIS IS AN ATTENPT TO COLLECT A DSBT. ANY INFORMATION OBTAINED WILL BE IISED FOR THAT PDRPOSS. .-, NARK J. tJDREN & ASSOCIATES SY: Nark J. IIdrea, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITB 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF ~ ~"~ y a~~ SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and 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: Ronald Johnson a/k/a Ronald L. Johnson Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Catherine Johnson a/k/a Cathy L. Johnson Age: Over 18 Residence: As captioned above // ~ / Employment: Unknown ~/f/ ~ /s ~n / Title: !,/,ATH J.'MILC.HH Sworn to and subscribed Compan Ass' tart Secretary before me t is (O day _ o X4..5., > 2 0 v ~. SCARIFY i UiN Commission # 1Z7T761 ll[[~ otary Pu li ~ -''~~ camty € z AAIrCartm.6g~ies5ep21.4DD4 y ~~ ~~~_ • NYARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association,FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term Defendant(s) TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive 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. ~ Judgment by Default Prothonotary Money Judgment Judgment in Replevin Judgment for Possession _ Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark dr n ~.~{~ ~ i re At this telephone number: 856-482-6900 Mnux J UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BYz Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITS 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National 'COURT OF COMMON PLEAS Association, FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association, as -Cumberland County Trustee for SASCO Mortgage Loan Trust, 1999-BC4 :MORTGAGE FORECLOSURE P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189,~?~_92 Interest From September 5, 2001 4,101.36 to Date of Sale DAY _~, Per diem @$44.58 (Costs to be added) & ASSOCIATES J. lpdren, ESQUIRE NEY FOR PLAINTIFF P MARK J. UDREN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. N0.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) ~.C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: __ A. An individual ~B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): - %_A. _B. _C. and the property Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: ~,..., ., ~ ,d MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National 'COURT OF COMMON PLEAS Association, FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association,. as :Cumberland County Trustee for SASCO Mortgage Loan Trust, 1999-BC4 -MORTGAGE FORECLOSURE P.O. Box 57038 Irvine, CA 92619-7038 _ Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) C E R T I F I CAT E Mark. J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. J. Udren, ESQUIRE NEY FOR PLAINTIFF :_.,. P ~ . •iKARR J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for 5ASC0 Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County =MORTGAGE FORECLOSURE 'NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Ronald L. Johnson Catherine Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Cathy L. Johnson 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 , J ^4 •. Name and address of record: Name Plaintiff herein. Citifinancial, Inc the last recorded holder of every mortgage of Address See Caption above. 1 Valley St., Ste. 103, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N.Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive, 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 & ASSOCIATES DATED: September 4, 2001 dren, ESQ. for Plaintiff A MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE-500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTr O O ' Rr H VO A $ TO pR C~'I~T"' HT H RTFF S QAT F 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: & 6j 462-6900_ 2. You may beable 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. ) • vOU Mnv gm Tr r BE AFir E m0 SAVE YOUR P$Op~'RTY AND YOU HAVE OTHER RIGH?~ TiVH'N 7F TH E SHERIFF'S SATE 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 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale-never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. ~: 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOULD TAKE THIS PAPER TO YODR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH8 OFFICE LISTED BELOW TO FIND OUT WHERB YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 A s~ ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITIIATE IN MIDDLESES TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY RONALD S. RAFFENSPERGER, REGISTERED SURVEYOR, DATED SEPTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COUNTY PLAN BOOR 52,- PAGE-142, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET SOIITH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF-WAY LINE OF WILD ROSE CIRCLE; THENCE ALONG LOT N0. 30 NORTH 85 DEGREES 25 MINUTES EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT N0. 32; THENCE ALONG LOT N0. 32 SOUTH 4 DEGREES 35 MINIITES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CURVE F, TO THE RIGHT HAVING A RAD IIIS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 17,671 5QIIARE FEET, MORE OR LESS. , BESNG KNOWN A5 23 WHEATFIELD AVENUE, CARLISLE, PA 17013,; i PROPERTY ID NO.: 21-OS-0433-090 j TITLE OF SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L.JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND .AND WIFE. DATED 05/27/1999, RECORDED 06/17/1999, IN DEED BOOK 201, PAGE 979. _,,r _.. ,~,, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 ,- 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term To the Prothonotary: Kindly note on the record that the above Defendant, Ronald Johnson a/k/a Ronald L: Johnson & Catherine Johnson a/k/a Cathy L. Johnson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 26, 2001, Bankruptcy Case No. 01-05206. ~~ ~ C~~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ~•. Wells Fargo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota, National Association, et al VS In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4559 Civil Term Ronald Johnson a/k/a Ronald L. Johnson And Catherine Johnson a/k/a Cathy L. Johnson R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff s Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.66 Mileage 9.10 Levy 15.00 Advertising 15.00 Certified Mail 1.83 Poundage 2.86 Postpone Sale Law Journal Patriot News _ $145.95 paid by attorney Sworn and subscribed to before me This 19 day of 72rrrx.~.-~-~, 2001, A.D. ~ ~. ~..~~ Prothonotary So Answers: R. Thomas Kline, Sheriff BY E ~~ Real Est e Deputy b~~ 3`t~~S ~~qad~ ~~~,~ MARK J. UbREN &•ASSOG•'IATES BY: Mark J. Udren, Esquire AT`CY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National "COURT OF COMMON PLEAS Association, FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association, as :Cumberland County Trustee for SASCO Mortgage Loan Trust, 1999-BC4 -MORTGAGE FORECLOSURE P.O. Box 57038 Irvine, CA 92619-7038 . Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson _ A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 - Defendant (s) NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Ronald L. Johnson Catherine Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Cathy L. Johnson 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor .whose judgment is a record lien on the real property to be sold: Name Address NONE ,~ .,~~ 4. Name and address' of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancial, Inc. 1 Valley St., Ste. 103, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N.Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive, 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 & ASSOCIATES DATED: September 4, 2001 rk ~. Udren, ESQ. torney for Plaintiff MARK' J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 'N0. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 YO av B p m0 R VF'NT THT H RIFF' Ai F 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: (8561-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) MARK J. UDREN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) 01-4559 Civil Term ' NO NOTICE OF SHERIFF'S SALE OF REAL PROPERTY T0: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA; to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTTCR OF OwNFR'G RT HT y0 i Dy B TO PR ~7RT\rT Tj-jT4 cJ*F'R TF,_ F 4_5pT p To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900_ - 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-4559 CIVIL #~ TES CIVIL ACTION -LAW 70 THE SHERIFF OF Ctunberland `COUNTY: To satisfy the debt, interest and costs due Wells Fargo Bank Minnesota, National Association, F1CP. Noxwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage 199°~ PLAINTIFF(S) -LSaa-Trust, from Ronald Johnson A/K/A Ronald L. Johnson and Catherine Johnson, 23 Wheatfield Drive, Carlisle, PA 17013 (1) You are directed to levy upon the properly of the defendant(s) and to sell See Legal Description (2) You are also directed to aUach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and fo notrfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) Or otherwise disposing thereof; (3) If property of thedefendant(s)notlevieduponansubjecttoattachmentisioundinthepogsessionofanyoneother than a'riamed garnishee, you are directed to notNy him/her that he/she has been added as a garnishee and is enjoined as above stated: Amount Due $189,325.92 L L $.50 fran /5/ to - er iem Interest @$44 98 - $4,101. "t~ Due Prothy $1.00 Atty's Comm % Other Costs Atly Paid; 5119.90 Plaintiff Paid Date: Seotg[tber 7. 2001 REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 Qirtis R. Long Prothonotary. civil Division by /t o o F ~~2 ~ f Deputy ,~ MARK J. UDR$N & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-462-6900 Wells Fargo Bank Minnesota, 'COURT OF COMMON PLEAS National Association, :CIVIL DIVISION FKA Norwest Bank Minnesota, -Cumberland County National Association, as - Trustee MORTGAGE FORECLOSURE for SASCO Mortgage Loan Trust, 1999-BC4 - P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson - 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) PRASCIPE TO ISSIIE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189,325 92 '~ Interest From 9/5/2001 40,612 38 td Date of Sale March 3, 2004 Per diem @$44.58 (Costs to be added) $ MARK J. UDREN & ASSOCIATES v \ ~N~ k J. Udren, - ire ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRX HILL, NJ 08034 856-4$2-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION •Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 23 Wheatfield Drive Carlisle, PA 17013 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From 9/5/2001 to Date of Sale Ma~c~? 3 , Per diem @$44.58 - (Costs to be added) $189325.92 40612.38 Prothonotary By Clerk ALL THOSE CERTAIN PIECE 08 PARCEL OP LAND SITQATS IN ffiIDDLE388 TOWNSHIP, _ CIIffigre&r.nran COilNTY, PENNSYLVANIA, SN09PN AS LOT #31, AS DESCRIBED IN'ACCORDANCB WITH 5IIBDIVISION PLAN OF TH8 ffiFAtiOWS, PLAN #2, SY',RONALD S. ~+aT+T'~SPERGSR, 88GISTSRED SIIRVEYOR, DATED SEPTENBEB 18, 1986, AND RECORDED IN CDffiBRPT•aM^ COIINTY PLAN BOOK 52, PAGS•142, ffiOR8 FARTICOT,ARLY BOIINDID AND DESCRIBED AS FOLLOWS TO WIT: BEGINNIDTG AT A FOINT ON TSS EASTERN RIGHT-OF -WAY LINE OF W88ATFISLD DRIVE, SAID POINT H82NG RSFHRANCED AND LOCATED 155.00 FEET SODTB OF THE INTSP.SECTION OF T88 EASTSRN.RIGHT-OF-WAY LIMB OF WSSATHIELD DRIVE AND T88 SOIITH88N RIGHT-OF-WAY LING OF 9PILD 8058 CIRCLH; THSNCB ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINO'PES EAST A DISTANCB OF 157.27 FEET TO A-POINT AT LOT NO. •32; THENCB ALONG LOT NO. 32 SOIITH 4 DSGRE83 35 ffiINOTTSS EAST A DISTANCE OF 150.00 FEET TO A POINT AT TSS NOW NORTHERN RIGHT-OF-WAY LIFE OF WHEATFISLD DRNE; T88NCE ALONG SAID RIGHT-OF-WAY AND A CIIRVS TO THS RIGHT HAVING A RADIIIS OF 150.00 FEET AN ARC LENGTH OF 235.61 F88T TO A POINT, T88 PLAC$ OF HEGINID7ING. CONTAINING 17,671 SQIIARS FEET, ffiOR8 OR LE33 BEING I24P80VED WITS-A DWELLING HOIISE, KNOWN AS AND NODD3S88D 23 WHEATFISLD DR1:VE, CARLISLE, PA 17tl13. f BEING KNOWN AS: 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 PROPERTY ID NO.: 21-OS-0433-Q90 a TITLE TO SAID PREMISES IS VESTID IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE AS TENANS BY THE ENTIRETY BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 5/27/99 RECORDED 6/17/99 BOOK 201 PAGE 979. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE Plaintiff (s) From RONALD JOHNSON, a/Wa RONALD L. JOHNSON AND CATHERINE JOHNSON a/k/a C ATHY L. JOHNSON, 23 WHEATLEY DRIVE, CARLISLE PA 17013. (1) You are duetted to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 23 WHEATLEY DRIVE, CARLISLE PA 17013 (SEE LEGAL DESCRIIPTION) . (2) You aze also duetted to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 aze duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest 9/5/01 TO 3/3/04 @ $44.58 PER DIEM = $40,612.38 Atty's Comm % Due Prothy 1.00 Atty Paid 278.95 Other Costs Plaintiff Paid Date: NOVEMBER 21, 2003 CURTIS R. LONG Prothonotary (Seal) By: l(~9 t ( Dep REQUESTING PARTY: Name MARK J. UDREN, ESQUHtE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856 482-6900 Supreme Court ID No. 04302 -:~~ IN THE UNITED STATES BANKRUPTCY A /'~^1\ COURT FOR THE MIDDLE DISTRICT OF PENNSYLV ~ b(`Z~`a'4 2. IN RE: Ronald L. Johnson Cathy Johnson -'.'~~_ CHAPTER 13 ~~f~~-J CASE NO. 01-05206 MDF Wells Fargo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Movant vs. Ronald L. Johnson Cathy Johnson Debtor(s) and Charles 7. DeHart, III, Esquire Tnastee RESPONDENTS 11 U.S.C. SEC. 362 ~~` E® tWRRpSFlBURG Y COCT 2 2 2003 Clerk, U.S. Bankruptcy Ccurt ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW,'this ~ day of ~~(Ijf~L- ' .. , 20~,itisORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Retorm Act of 1979, as amended (The Codel, 11 U.S.C. 362, is modified with respect to premises: 23 Wheatfield Drive Carlisle, PA 17013 as to aLow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. Bankruptcy Judge 8:\WP51\8KY\2002\0233115. COD MARK J. UDREN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 656-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION -Cumberland County =MORTGAGE FORECLOSURE Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) - C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. /-MARK J. UDREN & SSOCIATES t/~.1s, c J Ud en, squire ATTORNEY FOR P ,TIFF MARK J. UDRSN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITS 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County =MORTGAGE FORECLOSURE NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive 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 Plaintiff herein. Citifinancial, Inc. Citifinancial, Inc. See Caption above. 1 Valley Street, Suite 103 Carlisle, PA 17013 Address to follow 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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. MARK J. UDREN & ASSOCIATES DATED: November 11, 2003 M k U ren, Esquire ttorney for Plaintiff MARK J. UDREN & ASSOCIATES SY: Mark J. Udren, 8squire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION -Cumberland County MORTGAGE FORECLOSURE Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) - NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 YO A S R TO NT THT H R ' T 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: 18551 482-6900. ..: 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop.the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. '(See notice on page two on how to obtain an attorney.) T/OU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS Et~'IvT TF~'HE SHERI'FF' S SAT E DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAICB THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT 8AV8 A LAWYER OR CANNOT AFFORD ONE, GO TO OR T8L8PHONS T8E OFFICE LISTED 88LOW TO FIND Oi7T WH8R8 YOII CAN G8T LEGAL 88LP. LAWYER R8F8RRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KING$ HIGHWAY, SUITS 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NOTIECE OF SHERIFF'S SALE OF REAL PROPERmY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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: ia551-482-5900. _, n r 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 MAY STILL BE ABLE TO SAVE YOUR PROP,BRTY AND YOU HAVE OTHER RTGH'r5 EVEN TF THE SHERIFF' S SALE DOES TAKE PL•aaCS 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 656-462- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII S80IILDTAKB T825 PAPER TO YOIIR LAWYER AT ONCE. 'IF YOII DO NOT HAVB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH8 OFFICB LISTED HELOW TO FIND OIIT W8HR8 Y00 CAN GET LEGAL BHLP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-97.08 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITS 500 CHERRY HILL, NJ 08034_ 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County 'NO. 01-4559 Civil Term To the Prothonotary: Kindly note on the record that the above Defendants, Ronald L. Johnson & Cathy Johnson,. have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 26, 2001, Bankruptcy Case No. 01-05206. Bankruptcy was reinstated December 4, 2003. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Wells Fargo Bank Minnesota, In the Court of Common Pleas of National Association, f/k/a Norwest Cumberland County, Pennsylvania Bank Minnesota, National Association Writ No. 2001-4559 Civil Term As Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriffls Costs Docketing 30.00 Poundage 2.49 Advertising 15.00 Mileage 4.14 Levy 15.00 Surcharge 30.00 Law Library Prothonotary 1.00 Share of Bills 29.32 $ 126.95 paid by attorney 01/13/04 Sworn and subscribed to before me So Answers, This ~ day of ~ ~ ~'~ ,.--- R. Thomas Kline, Sheriff 200 A.D. ) ~ I~ ,- Q ~BY Prothonotary Real Es to Deputy ~rJG 4J MARR J. IIDREN & AS$O.CIAT53S BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SIIITE 500 CHERRY HILL, N7 08034 656-482-6900- Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term AFFIDAVIT PURSIIANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 23 Wheatfield Drive 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 Plaintiff herein_ Citifinancial, Inc. See Caption above. 1 Valley Street, Suite 103 Carlisle, PA 17013 Citifinancial, Inc. Address to follow 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 23 wheatfield Drive 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. MARK J. UDREN & ASSOCIATES DATED: November 11, 2003 M k U ren, Esquire ttorney for Plaintiff NARK J. UDREN & ASSOCIATES HY: Nark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota,. National Association, FKA Norwest Bank Minnesota, National Association, as Trustee - for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS :CIVIL DIVISION - Cumberland County =MORTGAGE FORECLOSURE v. _ Ronald Johnson "NO. Oi-4559 Civil Term A/K/A Ronald L. Johnson - Catherine Johnson A/K/A Cathy L. Johnson - 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) NOTICE O~~~F,,73IFF' S SALE OF REAL PRO~?E12T~[. TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale _on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room,-2nd. Floor, Courthouse, Carlisle, PA, to; enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ]3p~'LCE OF OWNER'S RIGHTS VOi M,~jY SR aR7•E TO PRF,VF.NT TH2S SHER2FF" S SALE To prevent this Sheriff's Sale, you must take ymmesiia_t_e_acYaon:. 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: (85F1 482-5soo_ t 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 MAY STILL BS ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RrGu'~'S L''VT''hT TF THS SHERIFF' S SALE DOSS TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. Y0II ERODED TARB T82S PAPER TO YOIIR LAWYER AT ONCE. -IF YOII DO NOT HP:VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEP80N8 T88 OFFICE LISTED BELOW TO FIND OIIT W8ER8 YOII CAN GET LEGAL EELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue - Carlisle, PA 17013 717-249-3166 or 800-990-9108 ALL THO38 CERTA7:1P PIECE OR PARCEL OF LAND SITIIATS IN ffiIDDLBSES TOWNSHIP, C17bIBERLAND COIINTY, PENNSYLVAN7'.A, ~OSPN AS LOT #31, A3 DBSCRIHED IN'ACCORDANCB SPITH S1D7D1yISI0N PLAN OF THE ffiEAD•OWS, PLAN #2, SY',RONALD S. RAFFENSPERGBR, REGISTERED SIJRVEYOR, DATED SSPTEffiBER 18, 1986, ANDRECORDED IN CDffi8lartr•sxri COIINTY PLAN BOO7L 52, PAGE •142, ffiOR8 PARTICIILARLY B017NDED AND DESCRffi8D AS FOLLOWS TO SPIT: BEGINNING AT A POINT ON THE EAST88N RIGHT-OF -WAY Ll'NE OF WSBATFI73LD DR1V8, SAID POINT BEING REFERANCED AND LOCATED 155.00 FRET SOSiTH OF T88 73STERSECTION OF THE EASTERN-RIGHT-OF-WAY LINE OF WSEATFIELD DRIVE AND T88 SOIITHERN RIGHT-OF-WAY-L71PE OF SP~LD ROSE CIRCLE; THENCE ALONG LOT NO. 30 NORTH 85 DEGRSE3 25 ffiINIITBS EAST A DISTANCE OF 157.27 FEET TO A PO]1PT AT LOT NO. •32; TJDD:SCB ALONG LOT NO. 32 8017TH 4 DEGR8E3 35 MINtiTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT TH8 NOW NORTHERN RIGHT-OF-WAY LIMB OF WSEATFIELD DRIVE; TffiQC8 ALONG SAID RIG7iT-OF-WAY AND A CIIRVS TO TH8 RIGHT HAVING A RADIIIS OF 150:00 FEET AN ARC LENGTH OF 235..61 FEET TO A POINT, TH8 PLACE OF 8EGINNING. CONTAINING 17,671 9QIIAR73 FSST, ffiORE OR LESS. HEING IAIPHOVSD SPITE A DWELLING HOIISE, ENOWN AS AND ND74HERED 23 WHEATFIELI) DRIVE, CARLISLE, PA 17013. - BEING KNOWN AS: 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 PROPERTY ID NO.: 21-OS-0433-0;90 TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE AS TENANS BY THE ENTIRETY BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 5/27/99 RECORDED 6/17/99 BOOK 201 PAGE 979. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBEItI,AND) NO 01-4559 Civil CIVIL, ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: , To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE Plaintiff (s) From RONALD J013NSON, a/k/a RONALD L. JOHNSON AND CATHERINE JOHNSON a/k/a C ATHY L. JOHNSON, 23 WHEATLEY DRIVE, CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 23 WHEATLEY DRIVE, CARLISLE PA 17013 (SEE LEGAL DESCRIIPTION). (2) You aze 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 fox 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 duected to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest 9/5/01 TO 3/3/04 @ $44.58 PER DIEM = $40,612.38 Atty's Comm % Due Prothy 1.00 Atty Paid 278.95 Other Costs Plaintiff Paid Date: NOVEMBER 21, 2003 CURTIS R. LONG Proth tary / (Seal) By: 0. ~ Depu REQUESTING PARTY: Name MARK J. UDREN, ESQUII2E Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856 482-6900 Supreme Court ID No. 04302 UpREN LAW OFFICES, P.C. SY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA NorweSt Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189,325.92 Interest From 09/05/01 53,094.78 to Date of Sale December 8, 2004 Per diem Q$44.58 (Costs to be added) $ UDREN LAW OFFICES, P.C. ar J U r QUI E A TO Y FOR LA NTIF IN THE UNITED STATES BANKRUPTCY COURT FOR TIC MIDDLE DISTRICT OF PENNSYLVANIA. IN RE: Ronald L. Johnson € CHAPTER 13 Cathy Johnson CASE NO.OI-05206 MDF Wells Pazgo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Movant vs. Ronald L. Johnson Cathy Johnson Debtor(s) and 11 U.S.C. SEC. 362 Chazles J. DeFIart, III, Esquire Trustee RESPONDENTS MAY Z 5 2004 Cterk U.S. Benivupt~y ORDER MODIFYING SECTION 362 AUTOMATIC STAY ~, AND NOW, this _.~_ day of ~ , 20 ~ , it is ORDERID AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U. S.C. 362, is modified with respect to premises: 23 Wheatfield Drive Carlisle, FA 17013 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at SherifFs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. The relief granted by this order shall survive the wnversion of this bankruptcy case to a case under. any other Chapter of the Bankruptcy Code. Bankruptcy Judge E: \WP51\BKY\2002\0233115COd.wpd 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term 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.C. Mar} J. U n, ESQ IRE ORNEY F R PLAINTIFF 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 23 Wheatfield Drive 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 Plaintiff herein. See Caption above. Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 Wells Fargo Bank P.O. Box 57038 National Association Irvine, CA 92619-7038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq. Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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: June 30, 2004 Ma J. U\ n, SQ. \ torney for Plaintiff ( ' 4 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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.) t '1 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARS PLACE. 1. if the Sheriffs 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 aftez 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 SHOIILD TAKE THIS PAPER TO YOUR LA9PYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TBLEPHONE TH8 OFFICE LISTED SBLOW TO FIND OS1T WHERE Y0II CAN GET LEGAL HHLP, LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. N0. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 ia~ediate action: 1. The sale will be canceled 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.) 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. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO' NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OVT WHERE YOII CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or B00-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or BDO-990-9108 UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County iNO. 01-4559 Civil _. Term AFFIDAVST OF SERVICE PIIRSUANT TO Pa.R.C.P.RULE 3129.1 Plaintif y 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 '9B". /1 All Notices were served within the ti e 1'mi set or h by Pa Rule C.P. 3129. This Affidavit is made subject to the pe alti s o 18 a.C.S. Section 4904 relating to unsworn falsification to ut oriti s. Dated: November 18, 2004 UDREN W O P.C. BY: Mark J. Udren, Esquire Attorney for Plaintiff ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTORNEY-FOR PLAINTIFF National :COURT OF COMMON € PLEAS National :CIVIL DIVISION ;Cumberland County for SASCO Mortgage Loan Trust, 1999-BC4 Wells Fargo Bank Minnesota, Association, FKA Norwest Bank Minnesota, Association, as Trustee P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) DATE: October 12, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Ronald Johnson aka Ronald L. Johnson Catherine Johnson aka Catherine L. Johnson PROPERTY: 23 Wheatfield Drive Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 8. 2004, at 10:00 A.M., at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle PA. Our records indicate that-you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT e4 ~ LL s m n _ o . r m o N E ~ n °° " o E e z~o~o~ m ~ Em~m'°a `" K , _ m O1 ~ u ~Eaim_ E `m- APc xN Eu'i~ji0~ N LL A ~~_ d a E ` c~m~~ o d y S O N LL ~ W ~h c . mid V y ~ ~o~N_O E oE2 y m o~ a m~ y 0rw D d'N N mom OOT ` °5 .`CO .m_y :: NN tl ~ LL mv Un aE~3aq c dE'g O m9vym" OU C N ~_~= rn d E Ni y c0 °~E Ec'`+ p . mmc a. NO -m w,oo ~ ~O m mmE o= ¢ U l0 4 ~ a W a C g N V~~O- y N N ~ ~ai8° m vNC°~y E ° U ~ O R n . Em `o o= a° O y c y c> E u~°E = Y O N E 3W C V O N ~E o o N y d c y.-. vnm m E ~ ~m bo m ~ ~O~NO d, i> yPh...y_ -a ` ` y .. ¢v g o m c o 0 ° c ¢ D n _= D1 ~ i a a N - ~ ni ~ o ` N i V s .t'ti' rn y ~. ' • / f ._ ~ u , oo~~Em~ °~2r Pi COi DN L ~ LDS Sl '~ ~0 =y0 KOO ~ CN UK^ r 1 ~ T° w ~ S V 55 m ~ S o a m? o t~ d ... C;'i a m m m ~ o ~ ~ t 4 ~ ' '°E St U v.,ao~_ o ~ - ___ a' N fNJ N C D N y pd' N .~.. N __ Jamx( N LL p~~" ~ - 4 A-~° T f ~~® g Y' v j; U.S.DOSIAGf J. Y_ g.. % \ a % N ^~^^ ryry --- y -. ~ ~ U O p~ . ~~~ ~. ~~PB M~iEP E °N y O a ~ N y N 4 -- ~Ot . U rn N yO N ' m ~ K ~UU y m ~ o ^^^^ v ¢ a a ~ o ~ .2 E'.. ~ ¢ h w ~ m o ¢ a ¢ ~ m Z . ~ U d o ~ N ~ E w u i y ~ m U x m N p 0 o o' U ; o U m. U U ~ d, d v m ~ m m a o a m . ~=p c N ~ N = y v ~ o c ti o a d~ N ~ s m N y y m~' T d o ~ m~ r ~ Q M N W O p fn U U d' ~ ~ ~ ~ N v K °m v v m N '~ U E: p C o.a m ~ N a0 O W' m O c N rn ~ Z ` ODUZ ~ m m Q~ a _ i m oo c ~ J V o c~~ ~ ~ ~ ~ o m o= 0 N c rnm .- c m Z> opt E z m Wm pyim E~ ~ ~ ~ m m~ o 7~S s V ~0 ~ N d I- K 0 Unm H U ~ U i i C U y y NON o C N ~ d '. -C E m m a o v ~y~ ¢z L N j Ny m ~ ~ -°~ o Uv y EN, ~a Earn ca m¢.- O ~ O N m V ~ m„ Z ~ N c°) 7 tf1 CD I~ N 61 IO- =X C d a C O a_ A LO O Y C L d T T W d a E 0 U d N `o LL m [6 3 a n r ao M E `o LL 1 Wells Fazgo Bank Minnesota, National In The Court of Common Pleas of Association f/k/a Norwest Bank Minnesota Cumberland County, Pennsylvania National Association, as Trustee for SASCO Writ No. 2001-4559 Civil Term Mortgage Loan Trust 1999-BC-4 VS Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on September 17, 2004 at 4:24 o'clock PM, she served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Ronalrt 7bk~nson=a~ldu~R~vrr~id~L. Jolurson°and Catherine Johnson alk/a Cathy L. Johnson; by making known unto Ronald. Johnson, personally and. husband ofCatherine-Johnson, at 23 bVheat&eld Drive, Carlisle; Cumberland County;-Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2004 at 1:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson located at 23 Wheatfield Drive, Carlisle, 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: Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson, by regular mail to their last known address of 23 Wheatfield Drive, Carlisle, PA 17013. These letters were mailed under the date of October 06, 2004 and never returned to the Sheriff s Office. Sworn and subscribed to before me This day of 2004, A.D. Prothonotary veers: -~ R. `Thlomas Kline, Sheriff BYVO Real Esta eputy - - ~ ~: J 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County 'NO. 01-4559 Civil Term SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Ronald L. Johnson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on November 12, 2005 Bankruptcy Case No. 04-bk-06765. Mark J. Udren, Esquire UD EN LAW OFFICES, P.C. At rnev for Plaintiff 0126812 Wells Fargo Bank Minnesota, National In The Court of Common Pleas of Association f/k/a Norwest Bank Minnesota Cumberland County, Pennsylvania National Assoclation, as Trustee for SASCO Writ No. 2001-4559 Civil Term Mortgage Loan Trust 1999-BC-4 VS Ronald Johnson a/k/a Ronald L. Johnson and Catherine JohnSOn a/k/a Cathy L. Johnson Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on September 17, 2004 at 4:24 o'clock PM, she served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson, by making known unto Ronald Johnson, personally and husband of Catherine Johnson, at 23 Wheatfield Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2004 at 1:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson located at 23 Wheatfield Drive, Carlisle, 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: Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson, by regular, mail to their last known address of 23 Wheatfield Drive, Carlisle, PA 17013. These letters were mailed under the date of October 06, 2004 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs Docketing 30.00 Poundage 14.96 Posting Bills 15.00 Advertising 15.00 Prothonotary 1.00 Mileage 8.88 Levy 15.00 Surcharge 30.00 Law Journal 309.43 Patriot News 293.30 Share of Bills 30_42 $762.99 Sworn and subscribed to before me So Answ s: This ~ day of ~" ~~~ R. Thomas Kline, Sheriff 2005, A. '' Prothono BY ~~ v/U- Real Estate enuty 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL .DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive 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 Plaintiff herein. See Caption above. Citifinancial, Inc. Wells Fargo Bank National Association 1 Valley Street, Suite 103 Carlisle, PA 17013 P.O. Box 57038 Irvine, CA 92619-7038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq. Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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: June 30, 2004 n / \ Ma c J. U n, SQ. torney for Plaintiff 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 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 canceled 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.) YOU MAY STILL SE 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. YOV SHOIILD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y0II DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICB LISTED BELOW TO FIND ODT WHERB YOII CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 600-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-91D8 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. N0. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200' CHERRY HILL, NJ 08003-3620 656-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.0. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY T0: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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.) t YOU bfAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIF'F'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. YOII SHOIILD TAKE THIS PAPER TO YODR LAWYER AT ONCE. IF Y0II DO NOT HAVE A LAWYER OR CANNOT AFFORD ONH, GO TO OR TELEPHONE THE OFFICH LISTED BELOW TO FIND ODT WHERB YOII CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 6 A ALL THOSE C?~+TATT~.PIECB 08 PARCEL .OF LAND SITIIATE IN MIDDL8388 TOWNSHIP, . CIItIDT~+T~n1P^ CODPTY, PSNIPSYLVANIA, SNP09PN'AS LOT #31, AS DESCRIBED IN,A000HDANCE WITS , SVHDIPISION PLAN OF T88 20;AD'OWS, PLAN #2, HY',80NALD S. BAFFENSPSBGER, REGISTERED SIIRVEYO&, DATEp SEPTEMBER 18, 1986, AND RECORDED IN CDAffi'~r•nR^ COIINTY PLgN HOO& 52, PAGE -142, ffi08E PARTI~'RL•ap3•Y HOIINDED AE® DESCRIBED AS FOLLOWS TO SPIT: BEGINNING AT A POD7T ON THE EASTERN RIGHT-OF -WAY LINE OF WSSATFIELD D8IV8, SAID POI3PT HBIRG REPBRAIPCED AND LOCATED 156,00 FEET SORTS OF T88 '*SECTION OF T8E BASTERH.RIGST-OF-WAY LINE OF WSEATFIELD DRIVE AMID T88 SODTHERH RIGHT-OF-WAY~LDYR OF WILD 8058 C28CL8; THENCE-ALONG LOT NO. 30 NORTH 85 DEGREES 25 ffiIIiOTES EAST A DISTANCE OF 157.27 FEET TO A POINT AT~LOT NO. •32; THENCE ALONG LOT NO. 32 SOOTS 4 ;, REGRESS 35 MINIITES EAST A DISTANCE OF 150.00 FEET TO A POINT AT TSE NOW N08THERN 8IG8T-OF-WAY LINE OF WSEATFIELD DHIVE; T88NC8 ALONG 9AID 8IG8T-OF-WAY BRD A CQ8V8 TO THE RIGST HAVING A BADIDS OF 150:.00 FEET AN ARC~LENGTB OF.235..61 FEET TO A POINT, TS8 PLACE OF BEGIIPN22PG. - CONTAT*TTx~= 17,671 9QIIA8E FEET, ffi0R8 OR LESS BEING KNOWN AS: 23 WHEATFIELD DRIVE; CARLISLE, PA 17013 PROPERTY ID NO.: 21-05-0433-090 TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETY BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 05/27/99 RECORDED 06/17/99 IN DEED BOOK 201 PAGE 979. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTf3 OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, FI{A NORWEST BANK MINNESOTA NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, 1999-BC4, Plaintiff (s) From RONALD JOHNSON A/K/A RONALD L JOHNSON, CATHERINE JOHNSON A/K/A CATHY L. JOHNSON, (1) You are duetted to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as 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 ffie possession of anyone other than a named garnishee, you are duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest FROM 9/5/01 TO DATE OF SALE 12/8/04 -PER DIEM @ $44.58 - $53,094.78 Atty's Comm % Due Prothy $1.00 Atty Paid $420.30 Other Costs PlaintiffPaid Date: JULY 20, 2004 CURTIS R. LONG Prothonotary ~ (Seal) y~ By:~/I O / // iY b~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HH.L, NJ 08003-3620 Attorney for: PLAINTIFF Telephone:856-669,5400 Supreme Court ID No. 04302 1 ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Mazket Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Mazket Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeazed on the 19th and 26th day(s) of October and the 2nd day(s) of November 2004. 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 tme; 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 rtnan;mously passed and adopted severally by the stockholders and boazd of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County gf Dauphin in Miscellaneous Book "M", Volume 14, Page 317. ~'' ~ 11 A PUBLICATION ..............................'................................................................ COPY Sworn to and subscribed befo me 's 17 day f ov er 2004 A.D. SALE#16 NOTAR Terry L. Ruse , N i Ciry of Harrisburg, Daup n ou ~y PUBLIC My CommissionFxpfres June 6,2 Member, PennaylvaNeAasoc n ~ n expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE ' CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 309.43 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. B y .................................................................... r_._ 76 _ _ = Loan'fru ~~999- -- _ _®~-~-Fi4nald .loBiison elkJa Ronald ~. Johnson and ,,,~ Cattimr:rc*. Johnson PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OFPENN5YLVANIA 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 Joumal, 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, OCTOBER 8, 15, 22, 2004 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. Marie Cel4ne, Editor WORN TO AND SUBSCRIBED before me this 22 day of OCTOBER 2004 LOTS E. SNYDER, Notary Public Carlisle Boro, Cumberland County ~ Commission Expires March 5, 2005 Iai~Eld. E83^A"!"B 1~. 18 Writ No. 2001-4559 Civll We31s Fargo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesoffi, National Association, as Trustee for SASCO Mortgage Loan Trust 1999-BC-4 vs. Ronald Johnson, aJk/a Ronald L. Johnson and Catherine Johnson, ajk/a Cathy L. Johnson Atty.: Mark Udren ALL THOSE CERTAIN piece or parcel of land situate in Middlesex Township, Cumberland County, Pennsylvania, known as Lot #31, as described in accordance with Sub- division Plan of The Meadows, Plan #2, by Ronald 5. Raffensperger, Registered Surveyor, dated Septem- ber 18, 1986, and recorded nl Cum- berland County Plan Book 52, Page 142, more partlcularly bounded and described as follows to wit: BEGINNING at a point on the eastern right-of-way line of Wheat- field Drive, said point being refer- anced and ]ocated 155.00 feet South of the intersection of the eastern right-of-way line of Wheatfield Drive and the southern right-of-way line of Wild Rose Circle; thence along Lot No. 30 North 85 degrees 25 minutes East a distance of 157.27 feet to a point at Lot No. 32; thence along Lot No. 32 South 4 degrees 35 minutes East a distance of 150- .00 feet to a point at the now north- ern right-of-way line of Wheatfield Drive; thence along said right-of--way and a curve to the right having a radius of 150.00 feet an arc ]ength of 235.61 feet to a point, the place of begiruring. CONTAINING 17,671 square feet, more or less. BEING KNOWN AS: 23 Wheat- field Drive, Carlisle, PA 17013. PROPERTY ID NO.: 21-05-0433- 090. TITLE TO BALD PREMISES IS VESTED IN Ronald L. Johnson and Cathy L. Johnson, husband and wife, as tenants by the entirety by Deed from Charles T. Watkins and Virginia K. Watkins, husband and wife dated 05/27/99 regorded O6/ 17J99 in Deed Book 201 page 979. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. BoX 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189,325.92 Interest From 9 5 O1 77,435.46 to Date of Sale June 7, 2006 Ongoing Per Diem of 44.58 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. V' rk J. Ud SQUIRE ATTORN Y FOR PL N.TIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, FKA NORWE5T BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, 1999-BC4, Plaintiff (s) From RONALD JOHNSON A/K/A RONALD L. JOHNSON AND CATHERINE JOHNSON A/K/A CATHY L. JOHNSON (1) You aze directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You aze also duected 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 subj ect to attachment is found in the possession of anyone other than a named garnishee, you aze duected to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest FROM 9/5/01 TO DATE OF SALE 6/7/06 -ONGOING PER DIEM OF $44.58 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $77,435.46 Atty's Comm Atty Paid $1,198.29 Due Prothy $1.00 Other Costs Plaintiff Paid Date: JANUARY 24, 2006 (Seal) P thonot By: Deputy 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 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Ronald L. Johnson Cathy Johnson, Debtor(s) CHAPTER 13 CASE NO. 1-04-bk-06765 MDF Option One Mortgage Corporation, Movant, vs. Ronald L. Johnson Cathy Johnson, Charles J. DeHart III, Tmstee Respondent(s), ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY Upon consideration of the motion of Option One Mortgage Corporation for Relief from the automatic Stay, it is hereby ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided under 11 U.S.C. §362, is modified with respect to premises: 23 Wheatfield Drive, Carlisle, PA 17013 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bauluuptcy case to a case under any other Chapter of the Bankruptcy Code. EtS the Corot, B p badge 7'hrs edectronac order is sagned and fated on the same date. Dated: December 22, 2005 ~, UDREN LAW OFFICES, P.C. BY: Mark J. Udren, 8squire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National. Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O.-Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County (MORTGAGE FORECLOSURE NO. 01-4559 Civil Term 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.C. Mark Ud UI E TT F EY FOR PLAINTIF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, 8squire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 23 Wheatfield Drive 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 Plaintiff herein. See Caption above. Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. 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 23 Wheatfield Drive 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: January 23, 2006 s Mar J. n, ~`Q ~' At orney or P aijj ff ^ir ® y Yr UDREN LAW OFFICES, P.C. SY: 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/I{/A Ronald L. Johnson Catherine Johnson A/FC/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 09VNER' 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.) ,~. sAds 4 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. S. 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 SHOVED TARE 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 E UDREN LAW OFFICES, P.C. $Y: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SVITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICB OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take ia~ediate action: 1. The sale will be canceled 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 EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. if the Sheriffs 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 (101 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. YOV SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOV DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR T8L8PHONE THS OFFICE LISTED BELOW TO FIND OI7T WHERE YOII CAN G8T LHGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 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 a~F_~Fa_tdnn Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praeci~e 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 p ~ie f 18 P~:.S. Section 4904 relating to unsworn falsification to au o t'es Dated: May 19, 2006 BY: ICES, P.C. Attorney for Plaintiff 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) DATE: January 23, 2006 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County N0. 01-4559 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/R/A Cathy L. Johnson PROPERTY: 23 Wheatfield Drive, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 7, 2006, at 10:00 A.M., at the Commissioners Hearing Room, 2°d Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT ~ W' - ~: ~' .~ d •y. Ul'W - ~ o~ ~~~ ~~ Wells Fargo Bank Minnesota, National Association flk/a Norwest Bank Minnesota National Association as Trustee for SASCO In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4559 Civil Term Mortgage Loan Trust VS Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2006 at 2:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants; to wit: Ronald Johnson a/k/a Ronald L. 3ohnson and Catherine Johnson, a/k/a Cathy L. Johnson, by making known unto Ronald Johnson, personally and husband of Catherine L. Johnson a/k/a Ca4hy L. Johnson, at 23 WheatfieId Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Apri104, 2006 at 5:11 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald Johnson and Catherine Johnson located at 23 Wheatfield Drive, Carlisle, 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; Ronald Johnson and Catherine Johnson by regular mail to their last known address of 23 Wheatfield Drive, Carlisle, PA 17013. These letters were mailed under the date of April 03, 2006 and never returned to the Sheriffs Office. Sworn and subscribed to before me This day of 2006, A.D. Prothonotary So Answers: ,p. R. omas ine, Sheriff BYY~-I cSYI~tL~ l%I Real Estate Sergeant EXHIBIT B .,v~.N MARK J. IIDREN & ASSOCIATES SY: Mark J. IIdrea, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 Wells Fargo Bank Minnesota,. National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1.999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term DATED: August 24, 2001 TO: Ronald Johnson a/k/a Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249--3166 or 800-990-9108 NOTIFICACION IMPORTANTB 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 TERMING 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 PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PIIRSIIANT TO TBE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO SE A DEBT COLLECTOR AND TBIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE IISED FOR TEAT PIIRPOSE. .~, MARK J. IIDREN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHIPAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF ( ~~ 1 d~~~i / SS COUNTY OF fpJ i yr lJ~ 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: Ronald Johnson a/k/a Ronald L. Johnson Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Catherine Johnson a/k/a Cathy L. Johnson Age: Over 18 Residence: As captioned above Employment: Unknown Name : MlLC!-IAK Title: ! TH J. Sworn to and subscribed Compan / Ass' tent Secretary before me this (O day O ~~~5'~ , 20U~. SCARLERIANG Commhsim # 1277761 otary Pu li ~ ±"' O~Caunly MyCarm EapesSeP21.~04 ~w~~ ~~. «. t+tARK J, UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. IIdren, Esquire ATTY I,D. NO. 04302 1040 N, KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National 'COURT OF COMMON PLEAS Association,FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association, as -Cumberland County Trustee for SASCO Mortgage Loan - Trust, 1999-BC4 :MORTGAGE FORECLOSURE P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. - Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive 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. Prothonotary ~ Judgment by Default Money Judgment _ Judgment in Replevin _ Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOLT HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark T Udren Esquire At this telephone number: 856-482-6900 MARK J UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo $ank Minnesota, National 'COURT OF COMMON PLEAS Association, FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association, as -Cumberland County Trustee for SASCO Mortgage Loan Trust, 1999-BC4 :MORTGAGE FORECLOSURE P.O. Box 57038 Irvine, CA 92619-7038 - Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) NO. 01-4559 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $3~,~~5 -22. Interest From September 5, 2001 4 101.36 to Date of Sale December 5,?001 Pex diem @$44.58 (Costs to be added) & ASSOCIATES ,~......., .~.,x..~..L A TORNEY FOR PLAINTIFF ,.~~.~,~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. N0.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank-Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) CERTIFICATH TO THE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) ~C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: ~. An individual ~B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenant6 In Common F. A corporation and the property III. The Defendant(s) is (are): ~A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. ^ n Resident: / \ / 1 J. Wdren, ESQUIRE ss & I.D. # as above =~~.~t ,r .'~ MARK J. UDRSN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National 'COURT OF COMMON PLEAS Association, FKA Norwest Bank :CIVIL DIVISION Minnesota, National Association, as :Cumberland County Trustee for SASCO Mortgage Loan Trust, _ 1999-BC4 -MORTGAGE FORECLOSURE P.O. Box 57038 _ Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. J. Udren, ESQUIRE NEY FOR PLAINTIFF r - ~ ~i'3ARK 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, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County =MORTGAGE FORECLOSURE NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Ronald L. Johnson Catherine Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Cathy L. Johnson 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE . • ^4 •. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancial, Inc. 1 Valley St., Ste. 103, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N.Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive, 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 & ASSOCIATES DATED: September 4, 2001 rk .D. Udren, ESQ. torney for Plaintiff ~~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 RSGHTS YO AY H O R NT THT H RT S T 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: (anal 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION Cumberland County =MORTGAGE FORECLOSURE ~, YO_U MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RTGH'r'S F'~~'N TF THE SHERIFF' S SALE DOES TAKE PLnCE y 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 'Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale-never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. ,~ 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOIILD TARE TBIS PAPER TO YOIIR LAWYER AT ONCE. IF Y0II DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONB THE OFFICE LISTED BELOW TO FIND Oi1T WHERE YOII CAN GET LEGALBELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 anw-~~ l' ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESE% TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY RONALD S. RAFPENSPERGER, REGISTERED SURVEYOR, DATED SEPTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COIINTY PLAN BOOR 52,- PAGE-142, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET SOIITH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF-WAY LINE OF WZLD ROSE CIRCLE; THENCE ALONG LOT N0. 30 NORTH 85 DEGREES 25 MINUTES EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT N0. 32; THENCE ALONG LOT N0. 32 SOUTB 4 DEGREES 35 MINUTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CVRVE TO THE RIGHT HAVING A RAD IIIS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 17,671 SQIIARE FEET, MORE OR LESS. _ , BEING KNOWN AS 23 WHEATFIELD AVENUE, CARLISLE, PA 17013,;. PROPERTY ID NO.: 21-05-0433-090 jl TITLE OF SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L.JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE. DATED 05/27/1999, RECORDED 06/17/1999, IN DEED BOOK 201, PAGE 979. 4/ _, ,r _,. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 656-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term To the Prothonotary: Kindly note on the record that the above Defendant, Ronald Johnson a/k/a Ronald L. Johnson & Catherine Johnson a/k/a Cathy L. Johnson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania qn September 26, 2001, Bankruptcy Case No. 01-05206. ~~" ~ C~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff «~.~.~, Wells Fargo Bank Minnesota, National In The Court of Common Pleas of Association, f/k/a Norwest Bank Cumberland County, Pennsylvania Minnesota, National Association, et al Writ No. 2001-4559 Civil Term VS Ronald Johnson a/k/a Ronald L. Johnson And Catherine Johnson a/k/a Cathy L. Johnson R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff s Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.66 Mileage 9.10 Levy 15.00 Advertising 15.00 Certified Mail 1.83 Poundage 2.86 Postpone Sale Law Journal Patriot News $145.95 paid by attorney Sworn and subscribed to before me So Answers This :L~i day of 72vrteo-.--~-~ ~%~s~'"'~•t•C ~,~"~tt 'p<- R. Thomas Kline, Sheriff 2001, A.D. Q. ~.~~ ~'Y`~ `~ BY~t9e Prothonotary Real Est e Deputy ~c,12 3`+~?P /1 ~~q~d~ 4 TxIARR ~J. UDREN & ASSOCIATES BY:' Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Ronald L. Johnson Catherine Johnson 23 Wheatfield Drive, Carlisle, PA 17013 A/K/A Cathy L. Johnson 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 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County =MORTGAGE FORECLOSURE ~, .4. Name and address' of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancial, Inc. 1 Valley St., Ste. 103, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N.Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive, 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 & ASSOCIATES DATED: September 4, 2001 uuren, nab. 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, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION .Cumberland County =MORTGAGE FORECLOSURE 'NO. 01-4559 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BF. O R .NT THT H RTF ' T To prevent this Sheriff's Sale, you must take immediate actions 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: (8551-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~~:;:;. vOt7 'any SmTr•L• BE ABerE m0 SAVE YuUR PROPERTY AND YOU HAYS OTHER RIGHTS EVEN rF THS SHSRIFF~S SALE DOES SAKE PLACE 1. If the Shexiff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 656-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOIILD TA&8 THIS PAPER TO YOVR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAS9YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOV CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 600-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ;` ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESEX TOWNSHIP, CUMBERLAND COIINTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, BY RONALD S. RAFFENSPERGER, REGISTERED SIIRVEYOR, DATET! SEPTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COIINTY PLAN BOOK 52, PAGE 142, MORE PARTICIILARLY BOUNDED, AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00 FEET SOUTH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF-WAY LINE OF WILD ROSE CIRCLE; THENCE ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINIITES EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT N0. 32; THENCE ALONG LOT NO. 32 SOIITH 4 DEGREES 35 MINUTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CVRVE ~, TO THE RIGHT HAVING A RADIIIS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 17,671 SQIIARE FEET, MORE OR LESS. BEING KNOWN AS 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 / PROPERTY ID NO.: 21-OS-0433-090 j TITLE OF SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L.JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE. DATED 05/27/1999, RECORDED 06/17/1999, IN DEED BOOK 201, PAGE 979. _, ,~ ,-. . _ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :,Cumberland County MORTGAGE FORECLOSURE 'NO. 01-4559 Civil Term Defendant(s) NnmTCE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5,2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RSGHTS VO n B T TO RE NT THT aH TFF S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, .late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: IaK51 ae2-a9oo 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop thesale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~OrJ any STTLr SE A$rr? m0 SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS 7ECrnn -rrr THE SHERIFF' S SALE DOES TAILS PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 'Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. ~~ 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed., 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELHPHONE THE OFFICE LISTED BELOW TO FIND OIIT WHSRB Y0II CAN GET LEGALHELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 .` ALL THOSE CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESE% TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS LOT #31, AS DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF THE MEADOWS, PLAN #2, HY RONALD S. RAFFENSPERGER, REGISTERED SIIRVEYOR, DATED SEPTEMBER 18, 1986, AND RECORDED IN CUMBERLAND COUNTY PLAN BOOK 52,' PAGE-142, MORE pARTICVLARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: BEGINNING AT A FOINT ON THE EASTERN RIGHT-OF -WAY LINE OF WHEATFIELD DRIVE, SAID POINT BEING REFERANCED AND LOCATED 155.00. FEET SOIITH OF THE INTERSECTION OF THE EASTERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE AND THE SOUTHERN RIGHT-OF-WAY LINE OF WILD ROSE CIRCLE: THENCE ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINUTES EAST A DISTANCE OF 157.27 FEET TO A POINT AT LOT NO. 32; THENCE ALONG LOT N0. 32 SOIITH 4 DEGREES 35 MINU'S'ES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORTHERN RIGHT-OF-WAY LINE OF WHEATFIELD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CURVE F, TO THE RIGHT HAVING A RADIIIS OF 150.00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 17,671 SQIIARE FEET, MORE OR LESS. BEING KNOWN AS 23 WHEATFIELD AVENUE, CARLISLE, PA 17013,__. PROPERTY ID NO.: 21-OS-0433-090 j TITLE OF SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L.JOHNSON, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE. DATED 05/27/1999, RECORDED 06/17/1999, IN DEED BOOK 201, PAGE 979. -~.,. . ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-4559 CIVIL ~ TES COUNTY OF CUMBERLAND) CIVIL ACTION -LAW 70 THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Wells Fargo Bank Minnesota, National Association, FICA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage -L~rTrust,~99°-f~4 PLAINTIFF(S) from Ronald Johnson A/K/A Ronald L. Johnson and Catherine Johnson, 23`Wheatfield Drive, Carlisle, PA 17013 (1) You are directed to levy upon the properly of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as follows: and to not'rfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or othervvise disposing thereof; (3) If property olthedefendant(s)notlevieduponansubjecttoattachmentisfoundinlhepossessionofanyoneother than a named garnishee, you are directed tonotify him/he r that he/she has been added as a garnishee and )s enjoined as above stated. Amount Due 5189,325.92 fran 9/5/01 tot - er rem Interest @Sq4 58 - $4,101 ~6 Atty's Comm °f° Atty Paid; 5119.90 Plaintiff Paid Date: September 7, 2001 L.L. 5.50 Due Prothy $1.Q Other Costs Curtis R. Prothonotary, civil Division REQUESTING PARTY: Name Mark J. tklren, Address: 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Attorney tor: Plaintiff Telephone: 856-482-6900 Deputy Supreme Court ID No. 04302 MARK J. UDREN & ASSOCIATSS ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SIIITE 500 CHSRRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, 'COURT OF COMMON PLEAS National Association, :CIVIL DIVISION FKA Norwest Bank Minnesota, -Cumberland County National Association, as - Trustee =_MORTGAGE FORECLOSURE for SASCO Mortgage Loan Trust, 1999-BC4 - P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson "NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA ,17013 . Defendant(s) PRAECIPS TO ISSUS WRIT OF EXECUTION TO THS SHERIFF: Issue Writ of Execution in the above matter: Amount due $189,325.92 '~ Interest From 4~5~2001 40,612.38 to Date of Sale March 3 ^2004 Per di@m @$44.58 (Costs to be added) $ MARK J. UDREN & ASSOCIATES ka~ren, ire ~~ ATTORNEY FOR PLAINTIFF MARR J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, 'COURT OF COMMON PLEAS National Association, -CIVIL DIVISION FKA Norwest Bank Minnesota, -Cumberland County National Association, as - Trustee =MORTGAGE FORECLOSURE for SASCO Mortgage Loan Trust, . 1999-BC4 P.O. Box 57038 _ Irvine, CA 92619-7038 Plaintiff - v. Ronald Johnson "NO A/K/A Ronald L. Johnson . Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) 01-4559 Civil Term TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 23 Wheatfield Drive Carlisle, PA 17013 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From 9/5/2001 to Date of Sale March 3 2004 Per diem @$44.58 ~` (Costs to be added) $189.32__92 40,~~? ~S Prothonotary By Clerk Date ~~ . ALL THOSE CERTAYN PIECE OR PARCEL OF LAND SITIIATE IN MIDDLESES TOWNSHIP, CIIMH*;*+T•a*m COIINIR, PENNSYLVANIA, RNOWN AS LOT #31, AS DESCRIBED IN'ACCOHDAHCB WITH SIIBDIYISION PLAN OF THH MEADOWS, PLAN #2, HY',RONALD 3. RAFFENSPERGER, REGISTERED SIIRVEYOR, DATED SEPTEMBER 18, 1986, AND RECORDED IN CIIMB~+T•s*n+ COIINTY PLAN B008: 52, PAGE •142, MORE PARTICIILARLY BOIINDED APU7 DESCRI88D AS FOLLOWS TO WIT: BEGINNING AT A POINT ON TSE EASTERN RIGHT-OF -WAY LING OF WHEATFIBLD D$IYE, SAID POINT BEING RSF$TtANCED AND LOCATED 155.00 FEET SOUTH OF THS INTERSECTION OF TH8 EASTERN. RIGHT-OF-WAY LIMB 08 WHEATFIELD DRIVE AND THS 90IITHSR~T RIGHT-OF-WAY LINE OF 9PILD ROSE CIRCLE; T88NC8 ALONG LOT NO. 30 NORTH 85 DEGREES 25 MINOTES EAST A DISTANCE OF 157.27 FEET TO A-POINT AT LOT NO. •32; T8ENC8 ALONG LOT NO. 32 SOIITR 4 DSG8E8S 35 MINOTES EAST A DISTANCE OF 150.00 FEET TO A POINT AT THE NOW NORT88RN RIGHT-OF-WAY LINE OF WHEATFISLD DRIVE; THENCE ALONG SAID RIGHT-OF-WAY AND A CIIRYE TO TH8 RIGHT HAVING A BADIII3 OF 150c00 FEET AN ARC LENGTH OF 235.61 FEET TO A POINT, THS PLACE OF BEGINNING. CONTAINING 17,671 SQIIARS FEET, MORE OR LESS. BEING IMPROVED WITH A DWELLING HOIISE, HNOWN AS AHD NWD3ER8D 23 WHEATBIELD DRIVE, CARLISLE, PA 17013. BEING KNOWN AS: 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 PROPERTY ID NO.: 21-OS-0433-0:90 a TITLE TO SAID PREMISES IS VESTED IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE AS TENANS BY THE ENTIRETY BY DEED FROM CHARLES T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 5/27/99 RECORDED 6/17/99 BOOK 201 PAGE 979. -~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE Plaintiff (s) From RONALD JOHNSON, a/k/a RONALD L. JOHNSON AND CATHERINE JOHNSON a/k/a C ATHY L. JOHNSON, 23 WHEATLEY DRIVE, CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 23 WHEATLEY DRIVE, CARLISLE PA 17013 (SEE LEGAL DESCRIIPTION) . (2) You are also duetted 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 aze directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest 9/5/01 TO 3/3/04 @ $44.58 PER DIEM = $40,612.38 Atty's Comm % Due Prothy 1.00 Atty Paid 278.95 Other Costs Plaintiff Paid Date: NOVEMBER 21, 2003 CURTIS R. LONG Prothonotary ~ ,. (Seal) By: ~I ~Q U Dep REQUESTING PARTY: Name MARK J. UDREN, ESQUHtE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856 482-6900 Supreme Court ID No. 04302 ~N ~~~z~5~ IN THE UNITED STATES BANK~2UPTCY °~ COURT FORTHE MIDDLE DISTRICT OF PENNSYLV ~ 6('2/~`~?E 2, IN RE: Ronald L. Johnson '_ CHAPTER 13 ~~t~-'J Cathy Johnson •.,~ ,- CASE NO.Ol-05206 MDF -----• ""`~ Wells Fargo Bank Minnesota, National 11 U.S.C. SEC. 362 Association, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Movant _ vs. Ronald L. Johnson Cathy Johnson Debtor(s) and OCT 2 2 2003 Chazles J. DeHart, III, Esquire ~ Clerk, U.S. Bankruptcy Court Trustee RESPONDENTS ORDER MODLFYING SECTION 362 AUTOMATIC STAY AND NOW, this _ 22'~ day of ~(~(jj~t2-- ~ , 20~,itis ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (Th? Code), 11 U.S.C. 362, is modified with respect to premises: 23 Wheatfield Drive Carlisle, PA 17013 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purckaser's assignee) to take any legal action for enforcement of its right to possession of said premises. The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Banla~uptcy Code. !SI Mu~RY D. FAANCE Banknzptcy Judge E:\WP52\SKY\2D02\0233115. COD MARK J. UDREN & ASSOCIATES BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. BOx 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS ;CIVIL DIVISION .Cumberland County =MORTGAGE FORECLOSURE Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson _ Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) - C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & SSOCIATES t J Ud. en, squire ATTORNEY FOR P .TIFF ~~ _.. MARK J. UDREN & ASSOCIATES SY: Mark J. Udren, 8squire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 ,=un 2. Name and address of Defendant(s) in the judgment: Name Address Same as #1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Citifinancial, Inc. Citifinancial, Inc. See Caption above. 1 Valley Street, Suite 103 Carlisle, PA 17013 Address to follow 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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. MARK J. UDREN & ASSOCIATES DATED: November 11, 2003 ~ ^ M k/ '. U re/n,'Esquire ttorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Eequire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SIIITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee . for SASCO Mortgage Loan Trust, . 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) NO'~'TCE OF SHERIFF'S SALE OF REAL PROPERTY' TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU AY B TO R V NT THT H RT ' TE To prevent this Sheriff's Sale, you must take immediate actioa• 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (8551 482-6900_ 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) - YOU Ain`r STILL SE AELE TO S,~lVB YOUR PROPERTY AND YOII HAVE O~T~ ER RIGHTS EVEN IF T~~$HSRTFF'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 656-482-6900. 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 556-482- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you~will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOIILD TA&8 THIS PAPER TO YOS1R LASRYBR AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH8 OFFICE LISTED SSLOW TO FIND Oi1T WH8R8 YOII CAN G8T-LEGAL HELP. - LAWYBR REFERRAL SERVICE Lawyer Referral Service Cumberland Covnty Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Sexvice Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 -r ww.~* -, .. __ MARK J. UDREN & ASSOCIATES HY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Ronald Johnson 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant(s) NOTICE OF S~$RIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, 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 YO A S RT TO R NT THT H RT F~ TF To prevent this Sheriff's Sale, you must take immediate-actioa: 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: (esel-482-6gnn r 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.) XQSJ MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVFN TF mAF. SHERIFF' S SALE DOES mARE pr.ACE 1. Tf 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 656-482-6900. 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. 7f 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 unl@ss 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 SHOIILD TARE THIS PAPER TO YOUR LAWYER AT ONCE. 'IF Y0II DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TBLEPHONS TH8 OFFICE LISTED BELOW TO FIND OUT WHERE YOII CAN G8T LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 - 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or B00-990-9108 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, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA -92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4559 Civil Term To the Prothonotary: Kindly note on the record that the above Defendants, Ronald- L. Johnson & Cathy Johnson,. have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 26, 2001, Bankruptcy Case No. 01-05206. Bankruptcy was reinstated December 4, 2003. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Wells Fargo Bank Minnesota, In the Court of Common Pleas of National Association, f/k/a Norwest Cumberland County, Pennsylvania Bank Minnesota, National Association Writ No. 2001-4559 Civil Term As Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS Ronald Johnson a/k/a Ronald L. Johnson and Catherine Johnson a/k/a Cathy L. Johnson R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriff s Costs Docketing 30.00 Poundage 2.49 Advertising 15.00 Mileage 4.14 Levy 15.00 Surcharge 30.00 Law Library Prothonotary 1.00 Share of Bills 29.32 $ 126.95 paid by attorney 01/13/04 Sworn and subscribed to before me So Answers d This /y ~ day of `~ ~~~~'T "~ ~- R. Thomas Kline, Sheriff 200 A.D. ~` _ ' BY Prothonotary Real Es to Deputy ~,~ L 43 ~ MARK J. UDREN & ASSOCIATES SY: Mark J. Udrea, Esquire ATTY I.D. NO. 04302 ~ 1040 N. KINGS HIGHWAY, SIIITE 500 CHERRY HILL, N7 08034 856-482-6900- Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 , Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 'NO. OI-4559 Civil Term AFFIDAVIT PURSIIANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 23 Wheatfield Drive Carlisle, PA 17013 *~~~~. _ 2. Name an_d address of Defendant(s) in the judgment: Name Address Same as #1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address. None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Citifinancial, Inc. See Caption above. 1 Valley Street, Suite 103 Carlisle, PA 17013 Citifinancial, Inc. Address to follow 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13' North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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.. MARK J. UDREN & ASSOCIATES DA'xED: November 11, 2003 k U ren, Esquire ttorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udrea, 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, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS ;CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff _ v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 NO. 01-4559 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald Johnson A/K/A Ronald L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold a:t the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to; enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTSCS OF OwNER'S RT[-HTc v0 ny g YE m0 P FVF'NT THr HF 7FF'4 SALE To prevent this Sheriff's Sale, you must take immediate action- 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (8561 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BS~LFi TO SAVE YOUR P$O~ RTX AND YOU HAVE OTHER RIGHTS EVEN IF THB SHERIFF'S SALE DOES TAKE PLACE 1. if the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be-able to petition the Court to set .aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, youwill 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. YOII SHOULD TAEE THIS PAPER TO YO[JR LAWYER AT ONCE. _ IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONH, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND Oi1T WHERE YOU CAN GET -LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 600-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9106 r NARR J. UDREN & ASSOCIATES BY: Mark J. IIdrea, Esquire ATTY X.D. NO. 04302 1040 N. RINGS HIGHWAY, SIIITE 500 CHERRX HILL, NJ 08034 856-482-6900 We115 Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee _ for 5ASC0 Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 .- Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ronald Johnson- 'NO. 01-4559 Civil Term A/K/A Ronald L. Johnson _ Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive _ Carlisle, PA 17013 Defendant (~) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Your house (real estate) at 23 Wheatfield Drive, Carlisle, PA 17013 is scheduled to be sold a.t the Sheriff's Sale on March 3, 2004, at 10:00 A.M. in the Commissioners Hearing Room, 2nd. Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $189,325.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. *:OTrCE OF OWNF=R' rr_srmG vOU NLny BE TO R t~'1~~'T' THTS H Rr F 7 F To prevent this Sheriff's Sale, you must take immediate actioa• 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: 55)-4e2-6900 2. You may be able to stop the-sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered.' You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOi7 MAY STII~Ja $~AB7 E TO SAVE YOIIR P$,pPERTY AND YOII HAVE OTHER RTCSHT$ EVEN SF THE SHERSFF' ~$~E 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 856-482-6900. 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, Che buyer may bring legal proceedings to evict you. 6. You may be entitled io 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 (1D) 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. YOII SHODLD TARE TH25 PAPER TO YODR LAWYER AT ONCE. 'IF Y0II DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPS®N8 TH8 OFFICE LISTED BELOW TO FIND ODT WHERE YOD CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 - 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 600-990-9108 u ALL TSOSB CBSTAIN P28C8 O& PASCSL.OF LAND SITIIATE IN -ffiIDDLES88 TOWNSHIP, CyNgta&r.nxo CODNTY, PENNSYLVANIA, ENOWN A3 LOT #31, AS DSSCSI88D IN-A000SDANCB WITH SIIHDIVISION PLAN OF THH MEADOWS, PLAN #2, SY',RONALD 3. SAFFENSPESGBS, SSGISTESBD SIIRVEYO&, DATED SSPTBMBES18, 198E,AND-SBCOSD80 IN CQMHgpT•nM^ COIIETY PLAN HOO& 52, PAGH-142, MOSB PASTICDLASLY BOIINAED BND DESCSIHED AS FOLLOWS TO WIT: BEGINNING AT 8 POINT ON T88 SASTBSN SIGHT-OF -WAY LINE OF WSEATFISLD DRIVE, SAID POINT SSING °T'W'~nMCED AND LOCATED 155.00 FSST SORTS OF THE T~'TrT+~ECTION OF TH'8 EASTSSN. SIGHT-OF-WAY LINE 08 WHBATFIBLD DSIVH AND THS SOIITHSR2I SIGHT-OF-WAY LINE OF W,SLD 8055 CISCLS; THBNCE ALONG LOT NO. 30 NOSTS 85 DSGSES3 25 4IINOT83 BAST A DISTANCE OF 157.27 FSST TO A-POINT AT LOT NO. •32; T88NCS ALONG LOT NO. 32 SOOTS 4 DSGS883 35 MINDTBS EAST A DISTANCE OF 150.00 FEET TO A POINT AT T88 NOW NOST88SN SIGHT-OF-WAY LING OF WHSATFISLD DRIVE; T88NCE ALONG SAID SIGHT-OF-WAY AND A CIISVE TO THS SIGST HAVING A SADIIIS OF 150.00 FEET AN ASC LENGTH OF 235..61 FEET TO A POINT, T88 PLACE OF BEGINNING. CONTAINING 17,671 SQIIASE F88T, MOSB OS L8S3. BEING IMPSOVSD WITH A DWELLING HOIISE, SNOWN AS AND NOMHSSBD 23 W88ATFISLD DS1;V8, CASLISLE, PA 17013. BEING KNOWN AS: 23 WHEATFIELD AVENUE, CARLISLE, PA 17013 PROPERTY ID NO.. 21-OS-0433-0s90 TITLE TO SAID PREMISES I5 VESTID IN RONALD L. JOHNSON AND CATHY L. JOHNSON, HUSBAND AND WIFE AS TENANS BY THE ENTIRETY BY DEED FROM CHP12LE5 T. WATKINS AND VIRGINIA K. WATKINS, HUSBAND AND WIFE DATED 5/27/99 RECORDED 6/17/99 BOOK 201 PAGE 979. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4559 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: , To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, FKA NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE Plaintiff (s) From RONALD JOHNSON, a/k/a RONALD L. JOHNSON AND CATHERINE JOHNSON a/k/a C ATHY L. JOHNSON, 23 WHEATLEY DRIVE, CARLISLE PA 17013. (1) You are duected to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 23 WHEATLEY DRIVE, CARLISLE PA 17013 (SEE LEGAL DESCRIIPTION). (2) You aze also duetted 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 duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $189,325.92 L.L. Interest 9/5/01 TO 3/3/04 @ $44.58 PER DIEM = $40,612.38 Atty's Comm % Due Prothy 1.00 Atty Paid 278.95 Other Costs Plaintiff Paid Date: NOVEMBER 21, 2003 CURTIS R. LONG Protho tart' (Seal) By: ~ Depu REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856 482-6900 Supreme Court ID No. 04302 UAREN LAPI OFFICES, P.C. BY: Mark J. Udren, Esquire. ATTY I.D. NO. 04302 NTOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term PRAECIPE TO ISSUE PiRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $189.325.92 Interest From 09/05/01 53,094.78 to Date of Sale December 8, 2004 Per diem @$44.58 (Costs to be added) $ UDREN LAW OFFICES, P.C. ar J U r QUI E A TO Y FOR LA NTIF IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Ronald L. Johnson € CHAPTER 13 Cathy Johnson '•. CASE NO.Ol-05206 MDF Wells Fazgo Bank Minnesota, National Association, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Mavant vs. Ronald L. Johnson Cathy 3ohnson 11 U.S.C. SEC. 362 Debtor(s) and Chazles J. DeHart, Ili, Esquire Trustee RESPONDENTS FILED MAY 2 52004 Clerk, U.S. Banlwpt~y ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this ~~_ day of ~~ , 20 ~ ~ , it is ORDERED ~' AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.C. 362, is modified with respect to premises; 23 WheatfeldDrive Carlisle, PA 17013 as to allow the'Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. The relief granted by this order shad survive the conversion of this banlatrptcy case to a case under. any other Chapter of the Bankuptcy Code. /~L` .~ Bankruptcy Judge E: \WP51 \BKY\2002\0233115cod.wpd UDRF'N LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856669-5400 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee foz SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term C S R T I F I C A T fi 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.C. Mar} J. U n, ESQ RE ORNEY F R PLAINTIFF T 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 Wells Fargo Bank Minnesota, National Association, FKA Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4559 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association,FKA 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: 23 Wheatfield Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ronald Johnson A/K/A Ronald L. Johnson Catherine Johnson A/K/A Cathy L. Johnson 23 Wheatfield Drive Carlisle, PA 17013 23 Wheatfield Drive 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 Plaintiff herein. See Caption above. Citifinancial, Inc. Wells Fargo Bank National Association 1 Valley Street, Suite 103 Carlisle, PA 17013 P.O. Box 57038 Irvine, CA 92619-7038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq. Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 23 Wheatfield Drive 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: June 30, 2004 ^ ~~ /'~ / \ Ma J. U n, SQ. torney for Plaintiff