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Home My WebLink About01-05957 ~ . MARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ~INGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Weils Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corp. P.O. Bo}C 57038 IrVine, CA 92619-7038 Plaintiff v. Geraldine E. Shultz Irvin L. Shultz 200 East Locust Street Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 01 - S-9S7 Cio; l... '-r~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims. set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ::"iV'lff.!#lr.,~iji, ~,~", n, ~"'" =~^~,_'! ~ _.I~~~ ., .n _,!1'mI ,~"~""~""'.,..""','""""<>\',... ~, , """""""'f'l'-I!''''''''''--''.''"'''''F,"''''''-'~' AV1SO Le han demandado a usteden la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entre gar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, SI NO TIENE ABOGADO o S1 NO TIENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 800-990-9108 "'i"i~"W'~_~ <, L T", ~ _11 p ""'... NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 I "":"""'''''''', ... ,,,,,,,,,.,.,,,,,'fJJJ .. ~ '''''i'T!M'I!'lI~ 'I - - -~ ~ .. J;"~~ ~_, 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: Recording Option One Mortgage Corporation DBA, H&R Block Mortgage Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Date: 7/23/01 Book: 679 Page: 3257 Assignor: Assignee: 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: 200 East Locust Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 6/24/99 DATE RECORDED: 7/13/99 BOOK: 1556 PAGE: 915 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon "!"'",'''''.#''''<,,",llJ!I;." "~ ,,,", "p -~"...,~, F' - ~, ,,' -- ~ . breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 10/12/01: Principal of debt due and unpaid Interest at 9.5%* from 11/1/00 to 10/12/01 (the per diem interest accruing on this debt is $19.16 and that sum should be added each day after 10/12/01) $73,629.70 6,630.70 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $77.20 and that sum should be added on the first of each month after 10/12/01) 850.72 Late Charges (monthly late charge of $37.46 should be added on the fifteenth of each month after 10/12/01) 374.60 Other Fees 1,567.10 Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 3,681 49 $87,264.31 * This Interest Rate is subject to adjustment as more fully set forth in the Mortgage and Note. ,'f'V~,'-'MT'~,! I!f ~_,. _. """""I f ~~... ~".,~ ",-, 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $87,264.31 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 Udr~/ r';_"f''-''X'\!';('M~ l"'!;'" I _~ , . I"~ ~ 1- , ~- ~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF MECBANICSBURG, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED ACCORDING TO A SURVEY MADE BY ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED MAY 24, 1974, AS FOLLOWS. BEGINNING AT A POINT BEING THE SOUTHEAST CORNER OF THE INTERSECTION OF LOCUST STREET AND RACE STREET; THENCE BY THE SOUTHERN LINE OF LOCUST STREET, NORTH 77 DEGREES 30 MINUTES EAST 32.7 FEET TO THE WESTERN LINE OF LANDS NOW OR FORMERLY OF FLORENCE SWARTZ; THENCE ALONG SAID SWARTZ LAND, SOUTH 12 DEGREES 30 MINUTES EAST 42.5 FEET TO A POINT; THENCE CONTINUING ALONG THE SAKE SOUTH 16 DEGREES 55 MINUTES EAST 152.7 FEET TO A POINT ON THE NORTHERN LINE OF ST. JOHNS ALLEY; THENCE ALONG THE SAKE SOUTH 77 DEGREES 30 MINUTES WEST 32 FEET TO THE EASTERN LINE OF RACE STREET; THENCE ALONG THE EASTERN LINE OF RACE STREET NORTH 16 DEGREES 41 MINUTES WEST 170.7 FEET TO A POINT; THENCE CONTINUING ALONG THE SAKE NORTH 12 DEGREES 30 MINUTES WEST 24.5 FEET TO THE POINT OF BEGINNING. BEING RNOWN AND NUMBERED AS 200 EAST LOCUST STREET. '-""'-"'n,w,-"~""", -~'" ,'<'~~'1-1"' ,- ~''f'' _..-..... - -~ e. February 02, 2001 OPTION ONE MORTGAGE CORPORATION Irvin ;L Shultz Geraldine E Shultz 200 E Locust Street Mechanicsburg, PA 17055 Homeowners Name: Irvin L Shultz Geraldine E Shultz Property Address: 200 E Locust Street, Mechanicsburg PA 17055 Loan Account No.: 178804-1 Original Lender: Option One Mortgage Current LenderjServicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OPl71 [_EXHIBIT A CORPORATE OFFICES" 3 ADA" IRVINE" CALIFORNIA 92618-2304.. P.O. BOX 57041 .. IRVINE" CALIFORNIA 92619-7041 @..,=."..'" PHONE 800.326.1500" 949.784.6100" FAXLlNE 949.784.6032 F~'--'-'-""""'-""">=!'~.\ ...,_ " _ ~ ~'~'I~ " _ r= .= e. OPTION ONE Re: Loan No. 178804-1 MORTGAGE CORPORATION CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the, county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY 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. OPl71 ';'r',,,"~-,~j9(., CORPORATE OFFICES" 3 AOA" IRVINE" CALIFORNIA 92618-2304" p.o. eox 57041" IRVINE.. CALIFORNIA 92.619-7041 PHONE 800.326.1500" 949.784.6100" FAXLlNE 949.784.6032 '""",," ~ ~I"""<" ~ @ e. Re: Loan No. 178804-1 OPTION ONE MORTGAGE CORPORATION ********************************************************************** NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply. for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 200 E Locust Street, Mechanicsburg PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: 1 MONTHS @ $ 701.53 2 MONTHS @ $ 701.53 $ 2104.59 (b) Previous late charges; $ 74.92 (c) Other charges; Escrow, Inspection, NSF checks $ 0.00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2179.51 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 $2179.51, 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 payable and send to: Overnight Mail Address 3 Ada Irvine, Ca. 92618 Western Union Quick Collect Pay to: Option One Mortgage Corporation Code City: Option, Ca You can cure any other default by taking the following action within thirty (30) days of the date of this letter., (Do not use if not (applicable. ) OP172 CORPORATE OFFICES" 3 ADA" IRVINE.. CALIFORNIA 92e1a~2304" P.O. BOX 57041" IRVINE.. CALIFORNIA 92619-7041 t:i:r.,..=.,..," PHONE 800.326.1500" 949.784.6100" FAXLINE 949.784.6032 ",,,. !' '~~"'!)<lI;{.~,~ __ "-,,_,~,,,~ ,,~, _,~ ~.' ~ .J!'!'!~d;>I'~' '~~~~m ~ r ~ ~, -. - - - ., e. OPTION ONE Re: Loan No. 178804-1 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY. (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to.pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. MORTGAGE; CORPORATION IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S 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 paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OP173 CORPORATE OFFICES":3 ADA. IRVINE" CALlPORNIA 92618-2304" P.O. BOX 57041 .. IRVINE" CALIFORNIA 92619-7041 t::5:r....=...," PHONE 800.326.1500 .. 949.784.6100 .. FAXLlNE 949.784.6032 .. ~~~: ',' ~. i . . ~,. -<~ ~!""~ . I ". '-~ ~="_,e""""" e. OPTION ONE MORTGAGE CORPORATION Re: Loan No. 178804-1 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Office hours: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-784-6032 Rushie Taylor x5769 Monday through Thursday 7:00 a.m. to 9:00 p.m. 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 mayor X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 CORPORATE OF~ICES" 3 ADA" IRVINE'" CALIFORNIA 92618-2304" P.O_ BOX 57041" IRVINE" CALIFORNIA 92619.7041 PHONE 800.326.1600 .. 949.784.6100 .. FAXLINE 949.784.6032 -'.-"~"n"'~-:,!""-,;-*~,_~" e. ~,:mwW"1lfHI!, ,'", _l!''''It><l,j_~ ,,' "~_ , ~~,_ ~,_ ~~ @ ""'""" _'_"""0 Z-\._ ?"- m Cl co ..D , a- ., .-'l " LI1 m Cl Cl Cl Cl m LI1 .-'l Cl Cl Cl I"- - ;,,-..l"''''*''iJ''!'i'~ . , , .~ r ::J co postage $ ..D Postage $ a- .-'l Certified Fee LI1 Certified Fee Return ReceIpt Fee Postmark Return ReceIpt Fee Poslmarl< H... m (Endorsement Required) Cl (Endorsement RequIred) H... Resbicted Delivery Fee Cl Restricted Delivery Fee ., (Endorsement Required) Cl (Endorsement Required) Total Postage & Fees $ Cl Total Postage & Fees $ m Sent To LI1 Sent To .-'l si;.eei;Aj;i:No:;-o;-P(;-ijajtNO:..--~-~-_..~--~..._-------~-_.~._-----~.~------~~..~- ciiy;siai~:-zjp;:i"-.~--_..._~---~~--".__.~_.--._---";----....~---_..._---_.....-_.... PS Form 3800, May 2000 'See Reverse for In"st(Uctlons AHY\1 &.~tt Lh t:f- . ~, ' - ~I CI Si;eei;Apt."iio::;,i;;;ijBOi-No.-.--........~-~~-----_._~._-~.._.~.-._--.~------- Cl ?: ciiy;siai~:-z,p;4.~--~----_.__.....~..--~~----~-----~.._._~....._..~---~~~----_.~~~. PS For'V 3800, Mav 2000 ' See ReVerse fOI lnstructcons " Luv oth~ Dt WlurkJ . U BreVi 'f/A 1788041 , ~= > ~> V F. R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleaqing 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.; Tl),e undersigned understands that this statement here:in' is made: subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES (' f--',~.Y<~f'''"j-""W:; ~ ~, _ " r,-__'~, 1Il!i,..~,",_~""", - ~ -~'.-~' ~",,,,,,,,,,,,,,,,fm1 m.I!:.","",,,~~ .- ""'I' ~ ,- -<. -, - , . -~, " t1] ~. ~ :::: ~ ~ ~ ~~ ,~<,~",. ~""",,,,,.~,,,~, ""I'" _I 1. ull~lIilI"llrtrn:rr' 'IQ ~ .t- o ~ a ~o~ I ? () rr~ --t:- "'" "~!1I!f.ji:,~~~__!f~_4t_~"!I'!,!!!>)Rt~~'~1-'Hi"~1?'-';\lc'I""",,,,<~%!,j!i1\'l~~'l'j;,"F"".:--,'-t._" <,",-;,-.-'",,-,-, o c:: :;':'" -or-t G}cri z,:::::c: c;Q r:: :;',- zC) <;c~o .PC:: Z ::? o ,- ..0 -q C> ,:-) --l "T1 i= ..~" ~T1 _ _c,'; [--1 ~~~~B :i~ :x::; -< cr, ....., 't? N en '-.-- "'-,.--~-,\-';;,;-'-0f,',;-"j~~""';'i"";r-'fWJ''1'-'!-];'P;''-~!1if,,:\!:~_1r~'1!jlg-!i!~~' SHERIFF'S RETURN - REGULAR ~,- ... CASE NO: 2001-05957 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS SHULTZ GERALDINE E ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHULTZ GERALDINE E the DEFENDANT , at 2013:00 HOURS, on the 18th day of October ,2001 at 1137 COLUMBUS AVE APT 4 LEMOYNE, PA 17043 by handing to GERALDINE E SHULTZ a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.40 .00 10.00 .00 38.40 ~~ ~~~~ R. Thomas Kline 10/22/2001 MARK UDREN Sworn and Subscribed to before By: ~~g. ~ Deputy Sheriff me this 3(AA- day of @~ ;Uo( A.D. ~Q 'rtr";,,,~- P othonotary . "--"'-"'~'.'''';'~~\llJl.__1JI\, ~_~.. ",_ I' J'~ ". ~ .~"~. ~" ~ ~~ ,- _~'_~~""l'-_"""'- SHERIFF'S RETURN - REGULAR . CASE NO: 2001-05957 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS SHULTZ GERALDINE E ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHULTZ IRVIN L the DEFENDANT , at 2013:00 HOURS, on the 18th day of October ,2001 at 1137 COLUMBUS AVE APT 4 LEMOYNE, PA 17043 by handing to IRVIN L SHULTZ 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 Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r-~~~ R. Thomas Kline 10/22/2001 MARK UDREN Sworn and Subscribed to before By: CJQLu~ g - VA Deputy Sherlff me this 3 JA..k- day of QJU;::C.. :LikJ ( A.D. n~ a~ P~tary ,~ !"'~'''''''''"''''''''''''''''_~i'~_ 1"_" "~,,'~~~"' ""'~"r!'I' , - - """""'" _'I__".~''@1' jf ~"" - . . '" MARKJ. 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 F/K/A Norwest Bank Minnesota, National Association, as. Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County . NO. 01-5957 civil Term v. Geraldine E. Shultz Irvin L. Shultz Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. MARK J. UDREN & ASSOCIATES DATED: November 23, 2001 Mark J. Udren, Esquire Attorney for Plaintiff -""",!,~",,,,,"!IQ~._ ,l1il. l."._~.,.," _~ - ~" -,~ ~.~ ~__"Il"'_""""I"'':tm: .' . " . V E R I FIe A T ION 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: /0~ RIAN BURNETT ant Secretary '-PI'<"':-'--"''''':'''''''c;'''i''lljn ~ ~""'.I r """"",,",-=r --.,.,...,-~~'""""_. . - (5 (Jy~ ',iliiI/Il -~ ~". ~. ..",.~ --~ " '''''''-'''''^''''~' --,)&c '("_ ". "",.-';l~~""." '.',,' ,. .I! :'WY"Ifmi'!~~,;!'Wc'lffi'h,"-.;,,- "'~~--r><_- ,.,...~~I,~Ji?"ffi't"!,!",,,,-'O'["!''\''_''-+,r' '_;;"",,,,,- <'<,~<<. < <~,17'" ~ ~ ~~ff &3S-- _.."',; r-==c:,: j;;c=. (::::(,) ....-r~- :2 =< lit _'0 C," "'"'ilil r I . " , . C) " --n ""'" ;:,:J .,;;:-.: ~n f'.,) \.() ~< ~~; -"1-1 "--j:U C'D csrn S'J :v -< -on t;? !:""" co ""-;1'" """'i~H,i<.t5"<H":-'\CIi~;""'4"""'W,""'ilrli"!-\10"2'~~~f'!~~I~~~,.",~t~,.~~ 0"," '\ ~ ~ J. UDREN & ASSOCIATES dY: 'Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . Geraldine E. Shultz 'NO. 01-5957 civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association F /K/A Norwest Bank. Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 East Locust Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Geraldine E. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE I"-O'f<'" ~,'"'''Of''~m ~ "~'",~",~ ,,, 'ffi>1lm,~ ~T~' --'" --"""""''''''''''''''''--=<< ."~ ~,=- <, ~~ ~_~m~'lIi'RI ~ _ ,!'fflmll.llIl mil ',<",,--,~ - -....- - A . ~t. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Eagle Nat'l Bank 8045 West Chester Pike, upper Darby, PA 19082 Banc One Consumer Discount CO. 5001 Honin Dr., 2nd Floor Mechanicsburg, PA 17055 Nat'l Bank of PA 4401 Market St., Camp Hill, PA 17011 Penn Housing Finance Agency 2101 N. Front St., Harrisburg, PA 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 Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 200 East Locust Street, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 23, 2001 REN & ASSOCIATES M rk J. Ud en ESQ. Attorney for Plaintiff '1""" ".,o;",O""","",,!ffl'lli '.." ~~~~" ~ '~. r " ,~"', ,-~~~- ~~ ~~ JII!lIliIll!l_ __~'" " <-'''''~ .. _1, _J. :~",~~,_,?"~-i!.J\fjll$!_,~~,...,- ~ ,. "'" """~""'''N'''h'''fl!''Y!1'1In """niIfT"'illj"ilR TTTf""li.'IT"i""f""n'.!'9' ..., -~ 0 t;:~::} C s:: Z .. -0 0:- C::) m rT ---. .. ~ --'- " j"",) , r:n (/) C- 1.,0 .. .. -' --< L , :::; C) r- .. --ri <:: -1::; -'::;:, ~~1 > c 2': " " :> 0 N (~S .,. C -I "7 ~ ~ .. 0) =< !['3lI!'.~J""""~"tF!t!;!_'I~'!'-::r&""-,y"~q,-"",,~->:,,,,:"_~,':r:t''''' "'i;'_<!"'f-~"'" :"'t,r;[\1''':''~''~''i''!P;;?"'''1'\-'''ffl'1W--j!!I1i~f~~JJJ_h_''',f~L?ft,-j "--~-. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. . Geraldine E. Shultz .NO. 01-5957 Civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE. TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 10/13/01 to 11/23/01 Late charges per Complaint From 10/13/01 to 11/23/01 Escrow payment per Complaint From 10/13/01 to 11/23/01 TOTAL $87,264.31 804.72 74.92 77 20 $88.221.15 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. & ASSOCIATES --_/ rk J. Uen, ESQUIRE ~ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED DATE: .t1 ~(). ;2Q. :2.6('"> ( AS 'ND'eATEn ~. ~-b~ K PRO OTHY to,";'~',''','m""",''~~IlW, ,~,~, - L~~. I~ r ..,,"~""~ I' - -,~- -''''''''.~ ~.,<".II\!lRl~ "."",-" MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Geraldine E. Shultz Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(sJ NO. 01-5957 civil Term November 12, 2001 Geraldine E. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 IMlW~O'l'LCE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NQ'UFICACI_OX_IM~'l'AN'l'E DATED: TO: USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAB DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTARSENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES . DEBELLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LA~~ER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. AlITY INFORKATION OBTAINED WILL BE USED FOR THAT PURPOSE. :f"-'"cu._- ~C!'<,."''"'''''''' ,~~~, ' Y' . '''''~~I --I~-- , - ,-~ ~ , '",~~ ~, 0== . MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank . Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Geraldine E. Shultz Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) NO. 01-5957 Civil Term November 12, 2001 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 IMEO~TANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCB 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 TaIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NQTIF~CACIOlLIMPQR'1'.AN'l'E DATED: TO: USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGAnO IMIVlEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FJi.IR DEBT COLLECTION PRACTICES ACT ,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AIm THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORY.ATION OBTAINED WILL BE USED FOR THAT PURPOSE. ';F"-"P'-~""':""""''''~T<;J~..,.., ,~ , o. "~ I' T e."", - " ""~.~~. - 'Jill"" T'-";'~-'-' --"W''',*,''!R''"''"~ . . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-5957 civil Term v. Geraldine E. Shultz Irvin L. Shultz 200 East Locust Street Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF CJ4 COUNTY OF ~, THE UNDERSIGNED beJ.ng 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: SS Defendant: Age: Residence: Employment: Geraldine E. Shultz Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Irvin L. Shultz ~ Over 18 \ As captioned above 1.'1 Unknown ~ Sworn to and subscribed before me this day o , 20 "'/';'....., SCARLaT LANG _ Co...........I' 1277761 ~ NaIay NlIIc- Culf".... f i ~ County - _ _ _ ~~~~21.:~f """""""'I T ~- .." "'''''''''',~""", -_ .~ _ ~_'_"~...,..m~_~ , 1~- "'r" - - ., .,., . .~..,,' ~"','""++' +"".~ "rI r . T n'~"rlr1f'.'''rlrn '"':'1 Iml:.ili~jfii+,1~ t ~ (J -IcQ. ft. ~ :--0 B .... (") C) '~: r [g r- ~ ~ ~ -CJt~.. ;'::; ~ l'lr :::::-) '{) Z:-.t' - ) ~2';'~ "'J N W '10 IV Ci ~ ~0 -'on - -;;,~ ~' ,,-> :_-:)' '--C. L: ~:""" :::::~ ",I ~ -<. co -< _r" " '''~ ~ -""""<~_"'.J__ ~?,~;w.>P:;;'f";l'''t~t'!II''!o1'e''''''l2r'-'~~~'fik,","'r.i:~''i-'''U>;:ii1'''f;iJ.''';;:-,;( ,,,,~,,:,,;;:,-_,c--,,..- :"'V "'7-'~"'f";"+~"V"'* ;''''''''?l1I'1~~~lJi'll'~llf!l{~'!f.,_8~,.J~~;'':', ,'",,,,~~ MARK J. UDREN & ASSOCIATES ~Y: . Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF - . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County : MORTGAGE FORECLOSURE . Geraldine E. Shultz 'NO. 01-5957 Civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: '/ Issue Writ of Execution in the above matter: Amount due $88.221.15 Interest From November 24, 2001 to Date of Sale March 6, 200] Per diem @$19.16 ].973.48 (Costs to be added) $ ~"}'--~I""'~"~"'l ~ "~~, ,~ ,-~~~ IT M k J. U en ESQUIRE TORNEY FOR PLAINTIFF -- y .-, ~,~~~,~ ,~ ~ , > I""""'".....,-~._~~ ,~" ,~-~'f"'1!""'....-1' ??(J ~i :::- ~ ~ l...T ~ C. ~ .~ ..: :!BJ 1ft ~", . ~- > _~ ~~O' ~~ '1 0 I) 0 f-(0 "",--""","~-"",)",~,,,,~.,.,, U") ,,_,~~_,~, ". '~'~,-.~.'Jr""C . ._ ...... 1v r- . ~ iO. >>v ~~tIv~ . :-'l~. :'\J.;( ~8~8~8 . j I :~ 'f~ ~~'~~~ , "" ~"~~V,"""'i.>;';o;""", ~~f~ '-"--"""0 -':'-'<'rVJ~~;'iY'"~t'~IT~~ e >-"''''T'il'Iif~'TIii\t!l11IDI!J'HI7'l~ (") C ~ -0(5 tpq,: ~~~'" GC ~~8 )>c: ;;..:. =< o n ..::n Z 1::3 --. 1'0 ';::0 ,i,' ---;C] -~~J '~~ _c__ -r, ~~~ ~ '-0 -''''' r:? ;:- tOP """,1' '''' "'" . - V,-~JJj_Hmr:-:' .jC;\""!:,P';'''':~,.''''\t",~<:"qp'';'*''~''''''5;:;':'I'(:"~,,f,,"h"'~.~ 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 Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. . Geraldine E. Shultz 'NO. 01-5957 Civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 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. REN & ASSOCIATES '--~'''''',''''''".'''''J1';''''''" , ~,1 0__ ",~" -- .~ 1'"""1 .- ,~ - 1" .~, ..~" -~"""""~"_ f:!!i,~,~ ..~ . .~ '1"1' -"'-,. ~ ~ j"''''''' ;0" "___"'_'""'~"~"',' '_'-'""'-" ,,-, '_~ '"'000 .. T ~ [ 11"'flfillllJ"i'lli""fn"~T 0 CJ 0 C "T1 s: ~ -"0 0':-> '::? -- m SF ,,-::::: '-'...; pD z 1'0 , 1----:"1 Z g , '-:':) en 'D ::::; -~ ;,~) ~~ ~. -,:~5 '-n Z ".." ('5 t-. 6 rn 5: ..' N c:: --{ z (:"" )> ~ 0::> ~ ~~~_ U ,wn " 1'l!";JtilW;li1!~I~>r-<:l!r'J!h'iW'Fvm~ J;l~JiJ_F;:l!l;~~"''''-j!'",~",til<_~~'W__>r;!\,f~~-:&~'t1''''~''f'-''~>t1'f''''''''1", 'j"-~'"- ');",' ,-- w_'!,,';"'-r;i_ ,o~1'''';:\''''?'',1'_W''0W~\\€'1\1!i1111f'1P~>10!4RI~~~~,~ :'\' ~,,"'p, ',~~' ~"'" " . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Geraldine E. Shultz Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-5957 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Geraldine E. Shultz 1137 Columbus Ave., Apt.#4 Lemoyne, PA 17043 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Your house (real estate) at 200 ,East Locust Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 6, 2001, at 10: 00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $88,221.15, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABT,F, TO PREVENT THIS SHERTFF' S SALE TO prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (8SG) 482-6900 mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,{,...-". ~"\'~,"'~-~~ "."""''''''P1:\$I~4~- "= _. ~~, ,~J .. ~"'''''''''.''*'''" ~"U.~dlllgl'!."'-"l!.'I", ""~ r . __~~ ~ ,'"~"'-'-"1'1 'N __~~~r ~o,~' ,_ , I . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN --GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 > ..,-----.,' "''''''"'"'''--nB1!jWi'l111HI ,~ _~ "- -~ " 1- "~ ~ '" '''~ ~1II1'J.~ '., ~._.~ , ",.~"",,,~.;,,,,,,",I""~ ~v~ ""@\:J'\ :.L-. _ ",---0-- ~- ~" ~'- ,~,;, ~"'>,",'~'" -,,,,-"/--,,,,,,,-, '_v-_'''''~'' ,.,;;,"'",' rr' -~"'~~ - '""~''''~'I'tr'\1'r'' "Tii4P'lIlrnir"j\'~rliil'r'a:l1"1 .. Ii .. , 0 '-" ::-~) F -n v G_; , C!J -- ,-0-' .'-'- -' :"0 ..,;-: c.~ ~~J ;,', '.D :::> () r" Co,: .c' " , ~-: C~ ~n ;?: C~ ('"5 ,-. ,--' N c~ rn .> c ":/ "'. > :.) OJ ~ , fl '_f""<~m~"''W'\''~"l1''i~JJWI~lllN!~~'W,~':;;r!I''J!?''''~(~F,';sr-,--"r,,;,o'' "-'1 ,!,--, ,,,-,, i__:I'-!'P"-:",1~'~:-'f-<?;1:;H)J;F~;-""\li\~~';fjl-W"~~~~~C; #},&fis~i)1it;1"f;;;{l~:giM~~ 'i~ 'c .,' 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 Association F/K/A Norwest Bank Minnesota, National Association1 as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-5957 civil Term v. Geraldine E. Shultz Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) DATE: December 7, 2001 , TO: ALL PARTIES IN INTEREST ANn CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): GERALDINE E. SHULTZ & IRVIN L. SHULTZ PROPERTY: 200 East Locust Street, Mechanic sburg , PA 17055 Improvementss RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the C~erland County Sheriff's Sale on March 6. 2001, at 10:00 A.M., at the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBit A ,-,,;>.,.'Ct~~p.:l !'i'-'"'~.....",,,,,--""")'W.F"""""~"""'~""'f~"-"'" ~~ ", .~,~-,~~ -~~, ~.~.=,'~#,~ ~~"~!~-""'rrc""'~- [ , 'MARKJ. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Geraldine E. Shultz Irvin L. Shultz :NO. 01-5957 Civil Term 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 4, 2002 BY~- UDREN & ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff , f-y,n"-c""~"'.""'!'~, _ J,'_~ I,f . I " "" ~~..,,,,, :r , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County " : MORTGAGE FORECLOSURE Plaintiff v. Geraldine E. Shultz "NO. 01-5957 Civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association F /K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 East Locust Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Geraldine E. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE ,'"--~.~"-J""1ilM'" ,. . -, , ,- , - ~ - I, I - " -'..,-, , 4.. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Delta Funding Corporation 1000 Woodbury Road, Woodbury, NY 11797 Banc One Consumer Discount CO. 5001 Honin Dr., 2nd Floor Mechanicsburg, PA 17055 Nat'l Bank of PA 4401 Market St., Camp Hill, PA 17011 Penn Housing Finance Agency 2101 N. Front St., Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 200 East Locust Street, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: February 4, 2002 Mark J. Udren, ESQ. Attorney for Plaintiff 1-;-'1*'''''''''''''''''''~ '''''''<-I - ~- ,-"', ,J 1_ 1 " I' , f~:' "''''''"''''~J~'''''J~_""",,_> lJ c--; ~ ~ ~ ~ ~ ~ <0 Ol ..... Ol a. .... w '" ~ c- Ql>~ (JJ Ci)' S. a. .... w '" ~ 0 5' [!!!. . . ~ en Co 3 "T1 0 ~~E CD Q- CD ~ '<3 . ZO l> ~ enl "'" " 3 Co"'" (/l~ oc r- I ~0o. ~ ~ s:: ('i '" c €'> w , ~ ... 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STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler f I, ________________________________________ ______________________________________ Recorder 0 needs in and for said County and State do hereby certify that the Sheriff's need in which nnn_n_n____ _ __ _ ~_e_~ ~~ _!:. :':~.?__~~ _~~'!:'~_"_ ~~~ _'_ _~! ~_~ _~_o_:.'.':: ~:__~~_~_~~'!:_s_~~~_' u~_!' _'u~:: __ _ __ _ is the grantee 6th the same having been sold to said grantee on the _______h__U__U___u___n_n_nn___nn_nn day of __nn~'!:'~!>n_n__nn______n_nnnn A. n., ~~Q!l_L_, under and by virtue of a wriL_n___n___n execution . d th 29th ___ __ ____ __ __ ___ __ ________ ___ __ __ __ _ __ __ ___ __ ___ ISSue on e _ __ _ __ ___ __ _ ____ ______ __ __ __ ______ ___ Novell\ber day of __u_____h__nU_________ A. n., :ll1l-.200J" out of the Court of Cornman Pleas of said County as of civil ________ n_________h n _h n __.. __ u__ _ ________ _ _ n n _n n ___ ______ n u n___ n_ __ _ Tenn,~2JlO.L 5957 . Wells Fargo Bk Minnesota, N A f/k/a Norwest Bk Minnesota Nnmber ___________u_, at the SUIt of _n_nn_nn_______nnh__________h________u_______________ N A, Tr Geraldine E Shultz & Irvin L ___ _____ __ _ ________ __ __ _____ _____ __ against_ __ _ __ __ _ ______ __ _____ _ __ __ ____ __ __ __ __ __ ____ __ __ __ _ is 250 4729 duly recorded in Sheriff's Deed Book No. n__n__u__' Page _n_________. IN TESTIMONY WHEREOF, I have hereunto ~ set my hand and seal of said office this __c:2.Z..____ day of _u_ :~:~~~;: . IIoa!Irder DeocIo ~ . MrQlmn' .....II1IAIl=~~::. f~(l<i';T~~ '''', ,<", " .""." , 1 ,~ I" ,-- ~, '''~ l' ---, ", - I) _r :"" . Wells Fargo Bank Minnesota, et al VS Geraldine E. Shultz and Irvin L. Shultz In The Court of Connnon Pleas of Cumberland County, Pennsylvania Writ No. 2001-5957 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 12, 2001 at 1 :00 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Geraldine E. Shultz, by making known unto Irvin Shultz, adult in charge, at 1137 Columbus Ave., Apt. #4, Lemoyne, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 12, 2001 at 1 :00 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one ofthe within named defendants, to wit: Irvin Shultz, by making known unto Irvin Shultz personally, at 1137 Columbus Ave., Apt. #4, Lemoyne, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on January 07, 2002 at 10:53 o'clock AM., E.S.T., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Geraldine E. Shultz and Irvin L. Shultz located 200 East Locust Street, Mechanicsburg, Pennsylvania, according to law. , R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Geraldine E. Shultz, by regular mail to her last known address of 1137 Columbus Ave., Apt. #4, Lemoyne, PA 17043. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Irvin Shultz, by regular mail to his last lmown address of 1137 Columbus Ave., Apt. #4, Lemoyne, PA 17043. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly swom according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Peunsylvania, on March 6,2002 at 10:00 o'clock AM., EST. He sold the same for the sum of$1.00 to Attorney Mark Udren for Wells Fargo Bank Minnesota, flkJa Norwest Bank Miunesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1 999-BC4. It being highest bid and best price received for the same for Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for :l;,"n+""""""""-'~ , ~ ,,,_ c >._ ,~ ,[ I" " " f ~ ~....~ -,. , SASCO Mortgage Loan Trust, 1999-BC4of3 ADA, irvine, CA 92618, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$848.58, it being costs. Sheriff s Costs: , Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Out of County Dauphin County Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 30.00 16.64 15.00 15.00 30.00 10.00 .50 1.00 16.90 1.34 15.00 30.00 321.20 270.30 24.20 25.00 26.50 $848.58 paid 3/18/02 Sworn and subscribed to before me ~~: r. ~.;..-:.-~ ~ R. Thomas Kline, tt;e;ftt This S~dayof ~ 2002, AD. C)yL (] JhJ.i. , ~ Prothonotary Y"f""'W""'''''''''''''-''''''-~ ~ L, ",' 1~1 ' BY '- Jc f!tti SVVl~ Real Est te Deputy -, 1 ~ I ~ ~' mlo? ~o. I~ , u..- 3:;qq1 ~, },<3 7tt' --- ~ ,~,' " -~, i. '-"'_~, ,., I , ....,' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. . Geraldine E. Shultz .NO. 01-5957 civil Term Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association F /K/A Norwest Bank. Minnesota, National Association, as Trustee fol;' SASCO Mortgage Loan Trust, 1999-BC4, Plaintiff in the above action, b:y its attorney, Mark J. Udren, ESQ.,' sets forth as of' the date the Praecipe for the Writ of Execution was filed the followi~g information concerning the real property located at: 200 East Locust Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Geraldine E. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4, Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 1!'" -,--_~_".c,__...,,,,-"l"'_~ ,..,1~~i:,. I--F1J. 'r- 81.~ """",. .-,-~ -='-" ...., .. 4" Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Eagle Nat'l Bank 8045 West Chester Pike, Upper Darby, PA 19082 Banc One Consumer Discount CO. 5001 Honin Dr., 2nd Floor Mechanicsburg, PA 17055 Nat'l Bank of PA 4401 Market St., Camp Hill, PA 17011 Penn Housing Finance Agency 2101 N. Front St., Harrisburg, PA 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 Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address TenantS/Occupants 200 East Locust Street, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 23, 2001 M rk J. Ud en. ESQ. Attorney for Plaintiff "it' "_.C'-"'''.''-f'''''"'~~l1r " ~.r'-~~>'-' "~'~~f"'9~' .'" ,- "~""" ~ """""'''~~'~~''''''''''''~,-.:Il~~,,,,,,,,,,,, "" . 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 Association F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O.' Box 57038 Irvine, CA 92619-7038 : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Geraldine E. Shultz Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 , 'NO. 01-5957 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Geraldine E. Shultz 1137 Columbus Ave., Apt.#4 Lemoyne, PA 17043 Irvin L. Shultz 1137 Columbus Avenue, Apt. #4 Lemoyne, PA 17043 , Your house (real estate) at 200 East Locust Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 6, 2001, at 10:00 A,M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $88,221.15, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGH~ YOU MAY BE ABI,F. TO PREVENT THIS SHF.RIFF' S SAI,F. To prevent this Sheriff's Sale, you must take imm@diate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 mortgagee the back payment, late TO find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ---,'."r"l~"ri""'''~-<J_~~Ili<'W~F''l~~'~ I" "~m'T"--~ """""'~"1'" '~'"""""'~~':r'''''''l' I!llIi ~ ~ .~, "~~^ ~~,~ _ ,,_ '. . ,~,'i;'" " Y~Y STILL BE-ABLE TO SAVE YOUR PRQEERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHER~ SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS I?APER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEI?HONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN --GET LEGAL HELl? LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, I?A 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FI~ELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, I?A 17013 717-249-3166 800-990-9108 !' i'I""""~'-^'---'''''''''1''<''''''"'~~'''''''.~.",..r__~'.,.,~,~".)iJli\'<!]!!F&'r ,,~_. j'_ r ~~, ~r"""'''Il.",,,, I - ~- ~~. 'f~~"""""""" ,\'!l!II~ ~~ ~e' ,_ =...~ "'~O. 1 '~._ " ,_-", v_ ALL THAT CERTAIN ~IECE OR PARCEL OF LAND SITUAT~ IN THE BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED , ACCORDING TO A SURVEY MADE BY ERNEST J. WALKER, PROFESSIONAL'ENGINEER, ,DATED MAY , 24, 1974, AS FOLLOWS: BEGINNING AT A POINT BEING THE SOUTHEAST CORNER OF THE INTERSECTION OF LOCUST STREET AND RACE STREET; THENCE BY THE SOUTHERN LINE OF LOCUST STREET, NORTH 77 DEGREES 30 MINUTES EAST 32,7 FEET TO THE WESTERN LINE OF LANDS NOW OR FORMERLY OF FLORENCE SWARTZ; THENCE ALONG SAID SWARTZ LAND, SOUTH 12 DEGREES 30 MINUTES EAST 42.5 FEET TO A POINT; THENCE CONTINUING ALONG THE SAME SOUTH 16 DEGREES 55 MINUTES EAST 152.7 FEET TO A POINT ON THE NORTHERN LINE OF ST. JOHNS ALLEY; THENCE ALONG THE SAME SOUTH 77 DEGREES 30 MINUTES WEST 32 FEET TO THE EASTEfN LINE OF RACE STREET; THENCE ALONG THE EASTERN LINE OF RACE STREET NORTH 16 ~EGREES 41 MINUTES WEST 170.7 FEET TO A POINT; THENCE CONTINUING ALONG THE SAME NORTH 12 DEGREES 30 MINUTES WEST 24.5 FEET TO THE POINT OF BEGINNING. BEING KNOWN AS 200 EAST LOCUST STREET, MECHANICSBURG, PA 17055 PROPERTY ID NO.: 17-23-0565-163 LTITLE OF SAID PREMISES IS VESTED IN GERALDINE E SHULTZ AND IRVIN . SHULTZ, MOTHER AND SON BY DEED FROM . DATED 1/13/99, RECORDED 1/14/99, IN DEE~E~KI~~2E.. :=T;28~IDOW. - - '""""'lw'n'~~'l1~.'~r:r~_'~I~'r~ ~- I~- "-,-~,,-~ , r~~ - "~" ~1~ f','"-r~' ~ ,. ,~,JH" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUN1Y OF CUMBERLAND) NO. 01-5957 CIVIL ~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Wells Fargo Bank Minnesota. National Association F/K/A No:rwest Bank Minnesota. National Association. as Trustee for SASen Mortgage Loan Trust 1999 13C4 c/o Optioo 0flC rlortgagc Corpor-atiSR ' PLAINTIFF(S) from Geraldine E. Shultz and lIVID L. Shultz. 1137 Columbus Avenue. Apt. #4. Lemoyne. PA 17043 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leoal Description (2) You are afso directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attachment has been issued; (b) thegarnishee(sjis/are enjoined from paying any debt to or for the account of the defendant(s) and frgm deliveringl\ny prop!!rty of the defendant(s) or otherwise disposing thereof: (3) If property 01 thedelendant(s) not levied upon an subj~ to attachment is found inthepo,ssessiol'l of anyone other than a,named garnishee, you are directed to notny him/herthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due $88.221.15 from 11/24/01 to 3/6/01 Intere~ Per diam @~19.16 ~1.97).4S Atty's Comm % L.L. Due Prothy Other Costs $.50 $1 00 Atty. Paid Plaintiff Paid $17/;.40 Date: NovP.fT1hp.r 29......-2Q01 Curtis R. Lona Prothonotary, Civil Division ...by' ~~~ 2. '77{dlA.;y,r- Deputy REQUESTING PAR1Y: Name Mark J. Udren. Esq. Address: 1040 N. Kings Hiqhway. SUite 500 Cherry Hill. NJ 08034 Attorney for: Plaintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 ,,,",,,,.,:,"""~-"~<~~-.\lIW_~~\_,_~."_>" -., , """'-@>'W', '_'~__.""'~=" ,~ REAL ESTATE SALE NO.3i On December 7, 2001, the sherifflevied upon the defendant's interest in the real property situated in Borough of Mechanicsburg, Cumberland County, PA, mown and numbered as 200 East Locust Street, Mechanicsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 7, 2001 By: Q~~ Real Estate Deputy ~ i:;;il c:::;ra ~ tta \ s,,\~?,a ...t 1>\,', ," ~\"'\~ I'.. ,-,..\\: '..' \ .~" ' . ",.,(\ -, . ~'U \(\ '~~~\\ \\\ .\\,.1\1';) 0 III ." ,:,J",\~\~~ ".'\' <J ,-. "live 1"\:" ' ~~\\\-;\\'O ~~ _;_;;m ''\W~!li''.tm>~"""l+,..w:-*1*"'ff~'iW,,~0f',,'''''-I>'''''');[''lf~il!tilli'iffi'!~;1'il--;~~tWf-;,!,kl't'.iI'i;f~"';."~""'.:"; !"j.',';'"'O;', - """---,""!,::",-,'";':"''''''iC:''f'''~<~.~",!,-"#,[,,,,,;>;j'E",!1!":I;~mriijil~~~.l_~~!,.";' ,,,><-.,,,,-,,.~ ." ~> ~- ., j ~ " 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 Ass!. 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 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and~ Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequentiy duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COpy 5 ALE #31 Notarial SaaJ Teny L. RUSlfll, Notary P Harrisburg, Oauphln County MyCommlsslonElljliresJunos,2OOl! NARY PUBLIC Member, Penn,ylVanla ASSOCIation 01 Notaries .. , '~y commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO" Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 268.80 1,50 270.30 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. By............,.",...............",..,..........""",..........,., :;G;-q:~";;;~'''''w'_'''.w~l'll~ ~" "',~, ".-."..,..." 1"1 "-- !--"""'""' ~,", ~-!lIl"lQIlIIIJI "1 ~ r-<<"~" ~-'", REAL ESTATE SALE No. 31 Writ No. 2001..957 . Civil Term Wells Fargo Bank Minnesota, National Association flkla/ Norwest Bank MInnesota, National Association - - as Trustee fDr SASCO MortgagE' Loan Trust, 19~-BC4 >VS Geraldine E. Shultz Irvin L, Shultz Ally: Mark J, Udran DESCRIPTION ALL THAT CERI'AIN piece or parcel of land situate in the Borough of Mechanic~burg, County of CumberJand and Commonwealth of Pe.nnsylvania, bounded and described according to a survey made by Ernest J. Walker, Profe!>Sional Enginecc, dated May 24, 1974, as follows: BEGINNING at a point being the southeast comer of the intersection of Locust Street and Race Street; thence by the southern line of Locust Street,. north 77 degrees 30 minutes east 32.7 feet , to--the western line of lands now or formerly of __Florence Sw~; thence along said Swartz land, ,south 12 degrees. 30 minutes ea:.;t 42.5 feet to a , fl.Oint; thence continuing along the same soulh 16 aegrees 55 minutes east 152.7 feet to a point on the northern line of 51. John~AUey; thence along the same south 77 degree.; 30 minutes west 32 --" feet to the eastern line of Race Street; thence .;aloog the eastern line or'Race Street north 16 degrees 41 minutes west 170,7 feet to a point; '~thence continuing l4iJng the same north 12 I"_degrees 30 minutes west 24.5Jeet to lhe point of. "beginning. BEING known ~ 200 East Locust Street, Mechanicsburg, PA 17055, 'PROPERTYIDNO., 17.23~OS6S.163. l'TI'I1.Eofsaidpremises is vested in Geraldine E,'- :.' -Sbultz and Irvin L. Shultz, mother and son, by deed from Geraldine E. Shultz, widow, dated 1/13.122,_ recorded 1114199, in Deed Bookl92, "':~e_a28, ..- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esqnire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being dilly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regillar editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 N SEAl LOIS E, SNYDER, Notary Public Call13Ie Bora, Cul'l'lber.ilIllI County My Commis&Icn Expires Marl:h 5, 2005 '!"""'"-1""""'.'"'-'M'!"""'''''~~_c, I ~ ~""~""""".' ,.... , I ~-" ~, y,~,.t~'13r,)l_'~'__;r_,"', REAL ESTATE SALE NO. 31 Writ No. 2001-5957 CIvil Wells Fargo Bank Minnesota, National Association f/k/ a Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 vs. Geraldine E. Shultz and Irvin L. Shultz Atty.: Mark J. Udren ALL 1HAT CERTAIN piece or par- cel of land situate in the Borough of Mechanicsburg, County of Cumber- land and Commonwealth of Penn- sylvania. bounded and described according to a survey made by Er- nestJ. Walker. professional engineer. dated May 24, 1974, as follows: BEGINNING at a point being the southeast comer of the intersection of Locust Street and Race Street: thence by the southern line of lo- cust Street. North 77 degrees 30 minutes East 32.7 feet to the west- e;rn line of lands :pow or formerly of Florence SWai1:z; thence -along said Swartz land, South 12 degrees 30 minutes East 42.5 feet to a point: thence continuing along the same South 16 degrees 55 minutes East 152.7 feet to a point on the north- ern line of St. JOMS Alley; thence along the same South 77 degrees 30 minutes West 32 feet to the east- ern line of Race Street; thence along the eastern line of Race Street North 16 degrees 41 minutes West 170.7 feet to a point; thence continuing along the same North 12 degrees 30 minutes West 24.5 feet to the point of beginning, BEING KNOWN AS 200 East Locust Street, Mechanicsburg. PA 17055, PROPERTI ill NO.: 17-23-0565- 163. TITLE OF SAlD PREMISES IS VES1ED IN Geraldine E. Shultz and Irvin L. Shultz. mother and son, by deed from Geraldine E. Shultz. wIdow. Dated 1/13/99, recorded 1/14/99. in deed book 192, page 828. - I""'" """""'II!f1II~" ,'" i ~~ --''[1- ~- -~