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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, NA . COURT OF COMMON PLEAS
as trustee : CIVIL DIVISION
c/o MOss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP : Cumberland County
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
ATTORNEY FOR PLAINTIFF
v.
Keith E. Miller
P.O. Box 591 : NO. 61 - ~l./(pl
Boiling Springs, PA 17007-0591
Defendant(s)
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COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in - the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita 0 en
persona 0 con un abogado y entregar a la corte en forma escrita sus
defenaas 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 previa 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 J:MMEDJ:ATAMENTE, SJ: NO TJ:ENE ABOGADO
o SJ: NO TJ:ENE EL DJ:NERO SUFJ:CJ:ENTE DE PAGAR TAL SERVJ:CJ:O, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFJ:CJ:NA CUYA DJ:RECCJ:ON SE
ENCUENTRA ESCRJ:TA ABAJO PARA AVERJ:GUAR DONDE SE PUEDE CONSEGUJ:R
ASJ:STENCJ:A LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
717-249-3166
800-990-9108
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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, lIlnd 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
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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: Eagle National Bank
Assignee: Delta Funding Corporation
Recording Date: 9/16/96 Book: 530 Page: 138
Assignor: Delta Funding
Assignee: Bankers Trust
Recording Date: 7/20/98
Corporation
Company of California
Book: 583 Page: 49
Assignor: Delta Funding Corporation
Assignee: Wells Fargo Bank Minnesota, NA as trustee
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: 40 North Middlesex Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township
COUNTY: Cumberland
DATE EXECUTED: 8/5/96
DATE RECORDED: 8/12/96 BOOK: 1335 PA~E: 855
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4.
Said Mortgage is in default because the required payments
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have not been made as set forth below, and by its terms, upon
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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
9/6/01:
Principal of debt due and unpaid
Interest at 11.875%*
from 12/1/00
to 9/6/01
(the per diem interest accruing on
this debt is $17.62 and that sum
should be added each day after
9/6/01)
$50,081.28
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
9,390.07
250.00
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 9/6/01)
1,413.40
Late Charges
(monthly late charge of $30.85
should be added on the fifteenth of
each month after 9/6/01)
238.60
Other Fees
Quote Fee
Satisfaction Fee
206.99
10.00
48.00
Attorneys Fees (anticipated and actual
to 5% of principal)
2.504.06
TOTAL
$64,422.40
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* This Interest Rate is subject to adjustment as more fully set
forth in the Mortgage and Note~
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The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
7 .
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 Pefendant(s) herein in the sum of $64,422.40 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. ren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
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ALL THAT CERTAIN LOT OR PIECE 01' GROtIND WI'l'B IlltIPROVlDIEN'rs THERBON BRBC'l'BD SI'1'l1ATB
IN M;tDDLBSBX TOWNSHIP, ctlMBBRLAND COllNTY, PENNSYLVANIA MORB PARTICtlLARLY BO'llJlD1I])
AND DBSCRIBED AS I'OLLOWS,
BBGINNING AT AN IRON PIN AT OR NEAR THE CEN'l'BR 01' TH1!l P'll1lLIC ROAD LEADING nOM 'l'HB'
HIGHWAY BB'l'WEE1II CARLISLB AND HARRISBURG AND 1OfOWN 'AS R01J'l:E NO. 11 TO STftRB'l'T'S
GAP; THENCE BY LAND NOW OR I'ORMERLY OF JOlIN GROSZ, SOll'rB: 73 DBGRBIilS wEsT 127,.5 FBBT
TO A POINT; 'l'BENCB BY LAND NOW OR FORMERLY 01' PAUL O.S'llJlDAY SOll'rB: 37 DBGRBES40
M:tNllTBS EAST 119.5 I'EBT TO A POINT; 'l'BENCE BY LANDS NOW OR FOlUIEl!.LY. 01' WILBUR< IIHITB
NOR'l'B 57 DEGREES EAST 119 . 5 PBET TO A POINT AT OR NEAR THE CBNTBR' 01' TIflIl ~ORBSAZD
PUBLIC ROAD; 'l'H1!lNCE BY THE ~n 01' SAZD P'll1lLIC ROAD NOR'l'B 37 DIilGRBBS WEST 82.5
PEBT TO AN IRON i/ZN, THE PLACE 01' BBGINNING. ;, /
CO~Y PARCB~ i. 21-17-2696-13.
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September 18, 2001
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
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Thi~ is an official notice that the mortgage on your home is in default, arid the lender
intends to foreclose. Specific information about the nature of the default is provided in the
attached pages.
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The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able
to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TmS NOTICE. Take
this Notice with you when you meet with the Counseling Agency.
The name, address and phone nnmber of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any Questions, YGU maY call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (persons with impaired
hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions,
representatives at the Consnmer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be able
to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LAPERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
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EXHIBIT A A
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Page 1 of6
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HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
89717110
Eagle National Bank
Wells Fargo Bank Minnesota, NA as Trustee
LOAN ACCT. Nq.:
ORIGINAL LE)'IDER:
CURRENT LENDER:
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
ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE:
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
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.
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
.
IF YOU MEET OTHER.ELIGffiILITY 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 consumer credit
counseling agencies listed at the end of this Notice. TillS MEETING MUST OCCUR WITHIN
THE NEXT (30) DAYS. . IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO
BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you 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 - Y9ur 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 insubmitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
Page 2 of6
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face- to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO ORIF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR\ /
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
. Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF TillS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMP1;' TO
COLLECT THE DEBT.
(If you have filed bankruptcy you cali. still apply for Emergency Mortgage Assistance.)
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HOW TO CURE YOUR MORTGAGE DEFAULT (Brill!?: it up to date).
NATURE OF THE DEFAULT --.The MORTGAGE debt held by the above lender on your property
located at:
40 North Middlesex Road
Middlesex Twp., PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monthly Payments of$617.02 for January 1, 2001 to September 1, 2001 = $5,553.18
Monthly Late Charges of $30.85 = $238.60
Other charges (explain/itemize): Escrow Advance = $1,413.40
Property Inspection Fee = $7.75
Tax Backsearch = $75.00
BPO Fee = 110.00
. Certified Mailing Fee = $4.29
Other Fee = $9.95
TOTAL AMOUNT PAST DUE:
$7.412.17
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable): N/A
HOW TO CURE THE DEF AUL T - You may cure the default within TIIIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7.412.17, PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE 1HlRTY (30)
. DAY PERIOD: Payments must be made either by cash, cashier's check, certified check or money order made payable
and sentto:
Mark J. Udren & Associates
1040 N. Kinlls Hillhwav, Suite 500
Cherry Hill, NJ 08034
Page 3 of6
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You can cure any other default by taking the following action within TIlIRTY (30) DAYS of the date of
this letter: (Do not nse ifnot applicable.): N/A
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within TIlIRTY (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 llot
made within TIlIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff
to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, iflegal 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. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy. '
RIGHT TO CURE THE DEFAULT PRIOR TO SHERlFFOS SALE- If you have not cured the
default within the TIlIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
rillht 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 6 months from
the date ofthis Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Phone Number:
Fax Number:
Contact Person:
Ocwen Federal Bank, FSB
P.O. Box 24737
West Palm Beach, FL 33416-4737
800-310-9229
N/A
Ed Van Sciver
Name of Lender/Servicer:
Address:
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE - You May not 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.
Page 4 of6
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NOTICE
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The amount of your debt is as stated in the attached docnment. The name of the creditor
to whom the debt is owed is as named in the attached docnment. Unless you notify us within
30 days after receipt of this Notice and the attached docnment that the validity of the stated
debt, or any portion of it, is disputed, we will assnme 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.
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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 docnment is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARKJ. UDREN
/s/MarkJ. Udren,Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
PageS of6
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)
.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TIllS
DEBT.
.
TO HAVE THIS DEFAULT CURED BY ANYTIIIRD PARTY ACTING ON YOUR BEIlALF.
.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHf TO CURE YOUR DEFAULT MORE 1HAN THREE TIMES IN ANY
CALENDAR YEAR.)
.
TO ASSERT THE NONEXIS1ENCE 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 SEEKPR01ECTIONUNDER THE FEDERAL BANKRUPfCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
CCCS ofWestemPennsylvania, Inc,
2000 Linglestown Road
Harrisburg, P A 171 02
(717) 541-1757
FAX (717) 541-4670
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, P A 17268
(717) 762-3285
FAXn/a
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, P A 1710 1
(717) 234-5925
FAX (717) 234-9459
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717)731-9589
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, P A 171 04
(717) 232-9757
FAX (717) 234-2227
Adams Connty Honsing Authority
139-143 Carlisle St.
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
Page6of6
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V F. R I FIe A T ION
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of 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 J. Udre ,
MARK J. UDREN &
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15:47
U.S. POSTAl SERVICE
bl~ 1;;l:I~ .:l4;O
,
Communleallons Exhibit 352.44a
Exhlbil352,44a .' .
Change 01 Address orBoxholder InformaCion (10 Serve Legal Process) Request Fotmal
(Suggested)
IlenBlhe.ia Opl/anall
.. UNrTEDST4TEl
I!!:(A iOSTAi.1i:/iVKE.
PosrmUle, Oall: \ \ \ \7- \0 \
BQ',_\i"';~I'"\fl().O:; I PA \\Q\:)I- '.
diY. Slall, ~ -0. 0'84 I _
RE~UEST FOR CHANGE OF ADDRESS OR SOXHOlDER INFOfIMA710N NEEDED FOR .SERVICE OF LEGAL PROCESS
Ploase turn/In Ihe new IKI4ress or me nsme .and slteol addles. (n e beI.holdsr) lot Ihe following:
Neme: \"v., ,-\-'r':) E:.. ~ '- \ \z. r-
Addros:l:P-, CK '''':\ 'Vn.
.,
N07E: 7ha nama and lasllcnOwn a~dra~ ala reqUIted. lor cI'lange 01
llOx addreSS a.e roqulled.lor be.holde, Inlormallon. . .
\
1l10101l0wlng InlormallOnl. provido~ In' ~CCCldance will\.39 CFR 265.6(d)(4111l1. Tho,e i$ no loa 10' providing ~o.holdo'
IIll0rmallon Tho lea to, providing enange 01 a~drlss In/ormalion.. wawed !n;iccotllanca "i1lr39 CI'R 265.5(d)(' I and
corresponding Adm/liiSlraljve Su. pp~nManuaI352.44a, , .
I, capacl~ 01 requ~s;o, (D.g.. proc~.. se",~,par1y lepresenlong selll:.fM-\nY' (\ t +-
'alUlll or IIg~I'bon rhal empaw~rs me 10 SeNe ptOO~'S 'lnolleq~ued when 'equesler Is an ettomey ot a pallY 101lng plO sa-
..0Dpl a OOlporallun .Ollng pro SO ",uSI o.te 5IDluI8):
3.Th.nan\.solaUIu10wnpanleSI~lheUlIgallon:~\\S~'<()o ~\,IJ,.\n0.-r~ ~"'\C>."'''\V1~~
\ J-:' 'f--...ti.. \~ (;..., \0--\\ \ kr
'4. The c:cunJJlwl>>ch Ih. case his Deeno,wJII ~e heard; c...U",,", \ol.~ \a.~
~. m. dOckel orolhollllalllrly.ng numbe...lone has been ISSued: __. _._____ _.. . ... ___. .... _.. .__. __ ,
6. Tho capaol\y ,nwlutlllhlslIUlIvrdlJllllSloDosorvad(e g .defanaanlor';"Unll$S):. d <2.~~~\::". ... .'._. .
u.. .. ',' '.' ........ - ...--...--....-..-.-.--
. WARNING
THE SUB"l'SSION OF FALSE INFORMATION emlER (I) TO OIlT"'IN AND US! CI'fANGl! OF'ADDRESS INfORMATION OR
aOXHOtDER INFORNATION FOR ANY PURPOSE OTHER THAN THESERVICEOF~GALPROC"SS)NCO~ECTION wrtH
ACTUAL OR PROSPECTIVE UTIGATlON OR (2) TO AVOID PAVMENT OF THE FEE FOR CHANGE OF "oDR~SS INFORMA.
TlON COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OP UPTO S10,OQO OR IMPRISONMENT OF NOT MORE
THAN 5 VEARS. OR BOTH (TITLE '8 U.S.O. SECTION 1001).
I cenlly Ihallha a~ov. .nlotm IIV end \hal Ihe add,ess InlOlmalion \$ neededel>i w.11 De used solely fo' seMCe 01 legal
process III OO/'IjunclJOn wllh pro. tuvellligallon.
IgnalUra
~'(~~,~.\JctyO (-...
Pnnled Name
/'Ct.fc) 10, \L.nns lillJ", 'Sk5LX)
Adelles. --<::l
c..h..~"'(,'-I ~ \ \. 1'0,) (")'&)2>Y
Clly. Slire, zl!l1:Qdi ,
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FOR FaST OFFice USE ONLY
NEW ADDRESS OR eOXHOlOER'S POSTMARK
NAME AND STREET ADDRESS
,
No chang. 01 address Older on 1110.
Moved. lell nO lo""ardlng addreSS
No such aaa,..s.
ASIVI12, Juoe19S8
137
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06461 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK MINNESOTA NA
VS
MILLER KEITH E
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MILLER KEITH E
the
DEFENDANT
, at 1440:00 HOURS, on the 16th day of November, 2001
at ABF FREIGHT SYSTEM, INC
2001 HARRISBURG PIKE
CARLISLE, PA 17013-0591
by handing to
KEITH E MILLER
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:
18.00
3.25
.00
10.00
.00
31.25
r~~~
R. Thomas Kline
11/19/2001
MARK UDREN & ASSOC
me this .2L----
day of
Deputy Sheriff
Sworn and Subscribed to before By:
~ ;urv/ A.D.
~()~
prothonotary/~
f:j
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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
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
Bank Minnesota, NA - COURT OF COMlV.lON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller "NO. 01-6461 civil Term
C/OABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 9/7/01 to 12/21/01
Late charges per Complaint
From 9/7/01 to 12/21/01
Escrow payment per Complaint
From 9/7/01 to 12/21/01
$64,422.40
1,871.96
123.40
.Q...JLQ
TOTAL
$66,4]7 76
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.
u
& ASSOCIATES
ark J. Udr ,ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED
DATE :])E:.C- d'7 ;;)CJr) I
I
AS INDICATED ~
(31~ )12.
PRO PROTHY V
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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, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Keith E. Miller
Defendant(s)
NO. 01-6461 civil Term
DATED:
TO:
December 10, 2001
Keith E. Miller
40 North Middlesex Road
Middlesex Twp., 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 T:EN 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
NOTIFICACION IMPORTANTE
US TED 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 NOTIFlCACION,
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
NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
_:..
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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, NA as
trustee c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
ATTORNEY FOR PLAINTIFF
v.
1 COURT OF COMMON PLEAS
~ CIVIL DIVISION
I Cumberland County
.~ NO. 01-6461 civil Term
Kei th E. Miller
Defendant(s)
DATED:
TO:
December 10, 2001
Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
US TED 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 NOTIFlCACION,
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
NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DlNERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
. ~:
"'>Ii<>JL_SI.,llkOJII{ - ~~ '-'. "'_~ .
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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, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Keith E. Miller
Defendant(s)
NO. 01-6461 Civil Term
DATED:
TO:
December 10, 2001
Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION,
EL TRIBUNAL PODRA, SIN NECESIDAO 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
NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DlNERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LAOFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
,
,-,~ -.
1"-.
" __d'" "'-'.'.-\"C'''' -illi.lI.~~,
MARK J. ODREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Kei th E. Miller
Defendant(s)
; NO. 01-6461 Civil Term
DATED:
TO:
December 10, 2001
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg P1ke
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
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACIONIMPORTANTE
US TED 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) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA," CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
"""""-a;f.,, -~
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-6461 civil Term
v.
Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF AJ evv ::s e r.s ey
COUNTY OF CCA../'Vl eX. e..-..)
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon inyestigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Defendant:
Age:
Residence:
Employment:
Keith E. Miller
Over 18
As captioned above
Unknown
Over 18
As captioned
Unknown
Sworn to and subscribed
before me this;;;.. S day
of {J-ec:e r 20
c;une: (YIo..riG ,CAdr-er,J, ES'"( ,
T~t1e :Q+}o,A.) eY' Q,r Ph N ;L:~-C
Company: I I
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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,
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
c/o ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
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 YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J Udren. Esquire
At this telephone number:
856-482-6900
t ~
_,,,*j,_;ii~~~_.....',,,",,,,,,,,,"~""_-
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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
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
Bank Minnesota, NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 da~ages as follows:
As set forth in Complaint
Interest Per Complaint
From 9/7/01 to 12/21/01
Late charges per Complaint
From 9/7/01 to 12/21/01
Escrow payment per Complaint
From 9/7/01 to 12/21/01
$64,422.40
1,871.96
123.40
~
TOTAL
$66 417 76
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.
{\
I REN & ASSOCIATES
u
, ESQUIRE
Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO PROTHY
_...'
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MARK J..UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY ,LD. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Kei th E. Miller
.
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., 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 YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J Udren. Esquire
At this telephone number:
856-482-6900
,~S~
1iU~,J.j"""'''''o.d~IM&,ti!,~~""",w"~'''tlO,~~....._".""",,,~ ,~= ~.IlilliII.!IIiI;i1" ~"""""''''''''~
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller . NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001. Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 da~ages as follows:
As set forth in Complaint
Interest Per Complaint
From 9/7/01 to 12/21/01
Late charges per Complaint
From 9/7/01 to 12/21/01
Escrow payment per Complaint
From 9/7/01 to 12/21/01
$64,422.40
1,871. 96
123.40
.\LJlJ1
TOTAL
.:t6..6-. 417 76
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.
~,f\
) \ I K \J REN & ASSOCIATES
( i ark J. Udr ,ESQUIRE
~ Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO PRO THY
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MARKJ. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTYI.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
-
. NO. 01-6461 Civil Term
c/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007-0591
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
-X- Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J. Udren. Esquire
At this telephone number:
856-482-6900
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 da~ages as follows:
As set forth in Complaint
Interest Per Complaint
From 9/7/01 to 12/21/01
Late charges per Complaint
From 9/7/01 to 12/21/01
Escrow payment per Complaint
From 9/7/01 to 12/21/01
$64,422.40
1,871. 96
123.40
lLJLQ
TOTAL
$66.417 76
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.
U ~f\ REN & ASSOCIATES
ark J. Udr ,ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO PROTHY
.
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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
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
Bank Minnesota, NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
-
. NO. 01-6461 Civil Term
c/o ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$66,417.76
Interest From December 22. 2001
to Date of Sale June 5. 2002
Per diem @$17.66
2... 931 56
(Costs to be added)
$
MARK J. UDREN & ASSOCIATES
ESQUIRE
INTIFF
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
- COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 civil Term
c/o ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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.
ark J. Udr ,ESQUIRE
ATTORNEY FOR PLAINTIFF
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MARK J. UDREN & ASSOCIATES
B~: 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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Keith E. Miller
13 Front Street, Boiling Springs, PA 17007
P.O. Box 591, Boiling Springs, PA 17007-0591
C/O ABF Freight System, Inc.,
2001 Harrisburg Pike, Carlisle, PA 17013
40 North Middlesex Road,
Middlesex Twp., 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
..<<h
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4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green 'l'ree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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
40 North Middlesex Road,
Middlesex Twp., 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: December 21, 2001
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
- NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 PRF.VF.NT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate actio~
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney1s 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.)
~
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YQU~Y 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 evist 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
I~
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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
charges, costs and reasonable attorney's fees.
you may call: (RS6) 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.)
"-, ___",-"~~"".",,,,~__,~___-.k.,w'l!\I "'~""".~"_._",,~o~1 _.~ ~~
~.J........
. ..L.a....'t'~-i1o= - -~'_ :'<'tlll~~~lli4ii.!il:')ii-;"'l{!j,_,i',-"
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YOU MAY STILL BE ABLE TO SAVE~R PROPERTY AND YOU HAVE OTHER RIGgTS
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 evist 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 exc;:eptions
(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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 js scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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
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.)
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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 OOT 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SItuATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN IRON PIN AT OR NEAR THE CEN'I'ER OF THE PUBLIC ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119..5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CEN'I'ER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE ll88.
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LAWOFFICES
MARK J. UDREN & ASSOCIATES
1040 NORTH KINGS HIGHWAY
SUITE 500
CHERRY HILL, NEW JERSEY 08034
856. 482 . 6900
FAX: 856. 482. 1199
MARK J. UDREN'
STUART WINNEG**
GAYL SPIVAK ORLOFF*"
HEIDI R. SPIVAK'"
CHRISTOPHER J. FOX*"
CORINA CANIZ***
*ADMlTI'ED NJ, PA, FL
**ADMllTED PA
*uADMI1TEDNJ,PA
TINA MARJE RICH
OFFICE ADMINISTRATOR
FREDDIE MAC
PENNSYLVANIA
DESIGNATED COUNSEL
PLEASE RESPOND TO NEW JERSEY OFFICE
January 31, 2002
Sheriff of Cumberland County
Cumberland County Courthouse
Re: Wells Fargo Bank Minnesota, NA as trustee
vs.
Keith E. Miller
Cumberland County C.C.P. #01-6461 civil Term
Dear Sir or Madame:
I ~~ ~
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PENNSYLVANIA OFFICE
14 J,(JJ[TlfldElU/JJ.Y AJ'ENUE
SUITE 240
BRYN MAWR, PA 19010
115-568-9500
115-568-Il41 FAX
Enclosed please find Praecipe to Return Writ of Execution.
Thank you for your attention to this matter.
Sincerely yours,
~
Mark J. Udren, Esquire
MARK J. UDREN & ASSOCIATES
/cas
raw Judgment which you are
his matter upon receipt of
:"~.~;~~J:~:;;;~~.
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..
MAR:({ 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
. ,
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ATTORNEY FOR PLAINTIFF
.
Bank Minnesota, NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Wells Fargo
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
: NO. 01-6461 Civil Term
PRAF.CIPE TO RETURN WRIT OF EXECUTION
TO THE SHERIFF:
Kindly return the Writ of Execution to the Prothonotary with
regard to the referenced matter.
DATED: January 31, 2002
MARK J. UDREN & ASSOCIATES
~
Mark J. Udren, ESQUIRE
ATTORNEY FOR PLAINTIFF
-~
L"
FEB, 1. 2002 9: 39AM
MARK J UDREN & ASSOC 856 4822576
LAW OPFICES
MARK J. UDREN & ASSOCIATES
1040 NORTH KINGS HIGHWA.Y
SUll'E 500
CHERRY HILL, NEW JERSEY 080'#
856. 48Z . 6900
FAX: 856. 48Z . 1199
MARl!: J. C;PIlEJV"
$7/JMlT WINNEG'"'
G.4rl. .I'PlYM Ol/l.O"....
BElfJl R. SPIVAK"""
O#I1JSTOI'HER J. FOX'"
COIlINA CIlNIZ"'"
~"d.FL
--..tDM'D7EDNI"r,t
TINA MAllIe I1JCII
OFFlCBAIlM.lN1.trAllVR
EBEDPJE MAc..
PKNNSYT. V d.N.lA..
DES/GNA TRlt.CO.JlNSEL
PU"A.l'EIlE.l'I'OND ro NBW JER.l'EfOFFICE
January 31, 2002
Sent yia telefax #717-240-6397
and Regular Mail
Cumberland County Sheriff's Office
Cumberland Ceunty Courthouse
ATTN: Jodie
:J. L.~.:..,"",' ~
"'~""l~ .~ !L_~.~",,;"'"
NO, 9688-P, 1
PENNstJ.l'ANIA. OFFICE
2d ~ ~P.[_~ .JJ.~l:JtJ'8Il A J'tNtn:
SUire 040
BRYN MAII:lr.PII/~P/O
215401.9500
)15-S0B-/UI FAX
Re: Wells Fargo Bank Minnesota, NA a.s trustee
vs.
Keith E. Miller
Cumberland County C.C.P. Ne, 01-5461 Civil Te~
Premises: 40 North Middlese~ Road, Middlesex Twp., PA 17013
SS Date: June 5, 2002
Dear Jodie:
Please Stay the Sheriff's Sale s~heduled for ~e 5, 2002.
Sale is Stayed for the following reason:
Defendant(s) filed Chapter 7 Bankruptcy en NOvember 29, 2001 in the
Middle District. Case #01-06350.
Thank YOu for your attention to this matter.
Sin~erely yours,
1L--
Mark J. udren
MARK J. UDREN & ASSOCIATES
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
01-6461 TERM
CIVIL 19
CIVIL ACTION - LAW -
TO THE SHERIFF OF
Cumberland
COUNTY
To satisly the debt, interest and costs due _.we_]Js__F~:r:go Bank Minnesota, NA as trustee c/o Moss,
Codilis. StawiarskL Morris, Schneider & Prior, LLP PLAINTIFF(S)
from ___Keith_E. Miller, C/O ABF Freight System, Inc., 2001 Harrisburg Pike, Carlisle,
PA 17013, P.O.Box 591, Boiling Springs, PA 17007-0591
---.-.
DEFENDANT(S)
(1) You are directed to levy upon the property of the detendant(s) and to sell See Leqal Description
(2) You are also directed to attach the property ot the detendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (al an attachment has been issued; (b) thegarnishee(s) is/are enjoine.f:Ur()mparing any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otheiwise'di~posing
thereof; .
(3) .If pro.p!lrt~oUhedef~ndant(s) not!evi~upon an subject to atlaCh!l1enli~f()undint~e po~es~i\>'l!~~ti~~ther
than a named garnishee. you are dlfectedto notny hlmlher that he/she has been addeCl'as a'garnlsheeand IS'llIlJqilfij1i1lrsraoove
stated, . ..' ,
Due Prothy
Other Costs
$.50
51.00
Amount Due 566,417.76
from 12/22/01 to date of sale
Interest 6/5/02 Per diool e$17 hh_$?,Q11 "i6
Alty's Comm %
LL
Atty Paid
Plaintiff Paid
$101.2<;
Date: llPrF>lTlhPr 7.8. 2001
Curtis R. Long
/l~, _ p""""~~::' r
Deputy
-Qy:
REOUESTING PARTY:
Name Mark J. Udren, Esq.
Address: ..1Q!Q. N. Kinos Hiqhway, Suite 500
Chp.rry Hill. NJ 08034
Attorney for: P1 "Ii nti ff
Telephone 856-411?-6900
Supreme Court 10 No, 043M
E COpy FROM R
In Test whereof, \ II to ~t my hand
l:IOO the _ rt at Carlisle, Pa.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
01-6461
TERM
CIVIL 19
CIVIL ACTION. LAW -
TO THE SHERIFF OF _~ Qum~J::.J.gnd
.COUNTY
To saUsfy the debt, interest and costs due .WelJs.F~o Bank Minnesota, NA as trustee c/o Moss,
..._Codil~Stawiarski, Morris, Sctme~der & Prior, LLP PLAINTIFF(S)
tram ___Keith.E:, Miller, C/O ~F Freight ~s1:<=l1\' Inc., 2001 Ha=isburg Pike, Carlisle,
_.YA.17013, --".a.Box 591, Boiling Spr~gs~--"-~Y007-0591
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to allach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and 10 notny 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 ot the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof: .
(3) II property ot thedefendant(s) not levied upon an subject to attachment istound in the po~essiorrolj:jpy.Q04Qther
than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and isenjOJi\"Ei#':jl~ibove
slated.
Amount Due $66,417.76 II
from 12/22/01 to date of sale
Interest 6/5/02 Por diOOl €,$J7 hh_$7 q"l1 'i6 Due Prothy
AllY'S Comm % Other Costs
$.50
$1.00
Ally Paid
Plaintiff Paid
$103.25
Date J1prPlTlhpr 28. 2001
Curtis R. Long
4". 20"'~;~:'A J
Deputy
-.!2y
REOUESTING PARTY:
Name Mark J. Udren, Esq.
Address ..lM.Q... N. Kinqs Hiqhway~ui te_~.Cl.O
..che~Hill,- NJ 08034 _.~._.__
Attorney for: 1'1 "inTiff
Telephone 85h IlR7 hqnn
TRUE COPY FROM RECORD
In TestImOnY whereof, I here unto set my hand
... "" "" " .... ~.isle.. Pa.
~Tbm ~m; >~~fR:}
Supreme Court 10 No.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6461 C TERM
IVIL 19
CIVIL ACTION - LAW ~
TO THE SHERIFF OF __Cum~rland
COUNTY
To satisly the debt, interest and costs due _We1ls_FClI'go Bank Minnesota. NA as trustee c/o Moss,
.. __.c;odil~ Stawiarski, Mo=is, Schnei..c!eE_& Prior, LLP PLAINTlFF(S)
from ___Keith_E. Miller, C/O ABF Freight Sys!E'lTl' Inc., 2001 Ha=isburg Pike, Carlisle,
H_PAJ7013, Y.O.Box 591, Boiling Sprin~s~~~17007-0591
DEFENDANT(S)
(1) You are directed to levy upon the property 01 the defendant(s) and to sell See Leqal Description
(2) You are also directed to attach the property 01 the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
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 ofthe defendant(s) notlevied upon an subject to attachment is found in the possession:<il~~j)~other
than a named garnishee. you are directed to notffy himlherthat he/she has been added as a garnishee and is eilfilJi(&:l'as"above
stated.
Amount Due S66,417. 76 LL
from 12/22/01 to date of sale
Interest 6/5/02 Por dil3ll 1;1$17 66-$7. Q,1 % Due Prothy
$.50
S1.00
Atty's Comm
Atty Paid
Plaintiff Paid
%
Other Costs
$101.7.5
Date
f)prPlTlhpr ?R, 2001
Curtis R.. Long
~,< it'77;~~ L
Deputy
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address: ~ N. Kinqs Hiqhwa~Su:i:tE"_50Q.
iJlE>rry Hill~ NJ 0801i......____.___ _ _.
Morney lor: p1 "i nti ff
Telephone 856-.:IR7.-(;QnO
Supreme Court 10 No. 04307.
TRUE COpy FROM RECORD
III lsstlmo\1Ywl1erlllJ1, I \lllrs \lntG,~ my hand
3,od the ol said r. at Camsle. Fa.
This day of
ry
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
01-6461 C TERM
NO. IVIL 19
CIVIL ACTION. LAW -
TO THE SHERIFF OF ~Cumber1Q!1d
.COUNTY
To salisty the debt, Interest and costs due ..WelJ8 Fi3J:9.0 Bank Minnesota, NA as trustee c/o Moss,
__Codil~Stawiarski, Morris, Schneider & Prior, LLP PLAINTIFF(S)
Irom .Keith_E. Miller, c/O ABF Freight Sys!EID' Inc., 2001 Ha=isburg Pike, Carlisle,
u_.X~.17013, P.O.Box 591, Boiling Springs, PA 17007-0591
(1)
DEFENDANT(S)
You are directed to levy upon the property 01 the delendant(s) and to sell See Leqa1 Description
(2)
You are also directed to a<<ach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows
and 10 nol~y Ihe garnishee(s) that: (a) an allachmenl has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof; ,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the po$Sessio,I'!Ql:all1<<!Q~ other
than a named garnishee. you are directed to notify him/her that he/she has been added as a garnishee andisenlOliij((asiibove
stafed.
Amount Due $66,417.76 LL
from 12/22/01 to date of sale
Interest 6/3/02 Por diem E'$17 ""-$?,Q'1.')6 Due Prothy
Any's Comm % Other Costs
$.50
$1.00
Any Paid
Plaintiff Paid
$101.2'5
Dale [)p"PrTlhpr ?R. 2001
Curtis R. Long
~rt~;~~L
Deputy
REQUESTING PARTY;
Name Mark J. Udren, Esq.
Address 1040 N. KinQs Hiqhway , Suite 500
.llierry Hill----1'l..L080~__._._._._ _.
Attorney for: P1 Ai nti ff
Telephone: 8""-IlR?-"Q()()
Supreme Court ID No. 0430?
TRUE COPY FROM RECORD
Ii! f(j~ whMeof. I here llrl~tl set my !land
Md tM . ~ zall.1 -" rt at Carlisle. Pa.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
01-6461
TERM
CIVIL 19
CIVIL ACTION. LAW -
TO THE SHERIFF OF
Cumberland
COUNTY
To satisfy the debt, interest and costs due _We],Js__F<g:go Bank Minnesota, NA as trustee c/o Moss,
. ___C;odilis, Stawiarski, Morris, SclmeideE3_Prior, LLP PLAINTIFF(S)
lrom ___Keith.E:-... Miller, C/O ABF Freight Sysl:.an, Inc., 2001 Harrisburg Pike, Carlisle,
____ PA_p013, P.O.Box 591, Boiling Springs, PA 17007-0591
DEFENDANT(S)
(1) You are directed 10 levy upon the property 01 the defendant(s) and to sell See LeGal Description
(2) You are also directed to anach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from defivering any property of the defenclanl(s) or otheiwisedisposing
thereof; .
(3) If property of the defendant(s) not. levied upon an subject to allachment is found in the po$eSsio~'olil~YQ/J6QUler
than a named garnishee. you are directed to IlOtify him/herthat he/she has been added as a garnishee anclisenlOiifelfas'8bove
stated.
Due Prothy
Other Costs
$.50
51. 00
Amount Due 566,417.76
from 12/22/01 to date of sale
Interest 6/5/G2 Per diOOl 'C$17 6h-$?,Q11 '16
Any's Comm %
LL
Any Paid
Plaintilf Paid
$101.7.'1
Date f)prPmhPT 7.B.
2001
Curtis R. Long
400<. i:r~;~~ L
Deputy
..))y
REOUESTlNG PARTY:
Name Mark J. Udren, Esq.
Address. .liMO N. Kinqs Hiqhwa~Sui1:.E"_500
J:herry HillL NJ_Q.8034 ________ _..
Anorney for: P1 ,Ii nri ff
Telephone: 85h-4R?-hQ()()
Supreme Court 10 No. 00l30?
TRUE COPY FROM RECORD
li,i@!'tif!\lll'lV 'wIW~. ! here utm set my hand
I:illd thl' j of said ."11 at Carlisle, Pa.
T day of
,- - , -
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
01-6461
TERM
CIVIL 19
CIVIL ACTION. LAW -
TO THE SHERIFF OF ~Cu!nberland
COUNTY
To satisfy the debt, Interest and costs due _.Welles. .FCi!"9:o Bank Minnesota, NA as trustee c/o Moss,
.. __Codilis, Stawiarski, Morris, Schnei.9~.r & Prior, LLP PLAINTIFF(S)
Iram..Keith_Eo. Miller, C/O .ABF Freight Sys1:em, Inc., 2001 Harrisburg Pike, Carlisle,
. PA.17o.!.l.-..Y.O.~x 591, Boiling Springs, PA .17007-0591
(1)
DEFENDANT(S)
You are directed to levy upon the property 01 the defendant(s) and to sell See Leqal Description
(2) You are also directed to attach the property of the detendant(sl 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/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) \I property of the detendant(s) not levied upon an subject to attachment is found in the posseSSi!l,o,()!;jlllfl?~other
than a named garnishee. you are directed to notify himlher that he/she has been added as a garnishee and islihlOi/fdc1'ils'above
stated.
Amount Due $66,417.76
from 12/22/01 to date ot sale
Interest 6/5/02 Per di€llll 0$17 6h-$?, CJ11 <;6
Atty's Comm %
l.l.
Due Prothy
Other Costs
$.50
$1.00
Atty Paid
Plainlitl Paid
$101.25
Dale n"f"PrTlnpr )8. 2001
Curtis R. Long
4,<. 2"~;:'A r
Deputy
~y
REQUESTING PARTY:
Name Mark J. Wren, Esq.
Address ...lQ.4Q.. N. Kings Hiqhway-"""Suite_SOQ
..Cherr;L Hill,. N.;L 0803.i......._~.__
Morney for: P1 ;,inti ff
relephone: 851> 4R? I>qnn
Supreme Court 10 No, 0430?
TRUE COpy FAOM RECOAO
111 TlIst!mony whereof. I here unto set my hand
~"~~_~.le.Pa.
~h~ ~!! . . ff4e--
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
01-6461
TERM
CIVIL 19
CIVIL ACTION - LAW -
TO THE SHERIFF OF
Cumberland
COUNTY
To salisfy the debt, Interest and costs due ..WelJs.I':i'l:I:9:o Bank Minnesota, NA as trustee c/o Moss,
...__Codil~StawiarskL Morris, Schneider & Prior, LLP PLAINTtFF(SI
from ___.!<eith_.E:. Miller, C/O ABF Freight Sys!em, Inc., 2001 Harrisburg Pike, Carlisle,
PA 17013, P.O.Box 591, Boiling Springs, PA 17007-0591
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Leqa1 Description
(2) You are also directed to allach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereot; .
(3) II propelty of lhe defendanl(s) nollevied upon an subject 10 attachment is found in Ihe pol;Sessk!.QQt!lPmOtl,Olher
than a named garnishee. you are directed 10 notify himlherthat he/she has been added as a garnishee and is'enjOlr(e'i'{ils"lIbove
slated.
Amount Due $66,417.76
from 12/22/01 to date of sale
Interest 6/5/02 Par diem filSJ7 6h-$?,Q11 'i6
AllY's Comm %
LL
$.50
Due Prothy
Other Costs
51.00
Ally Paid
Plaintiff Paid
$101.25
Date: f)p""",hf>r 28. 2001
Curtis R. Long
J=,.p'"~;~r
Deputy
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address ...lIWL N. Kinqs HiqhwaL-Suite __500.
...cherry Hill~NJ 08034 __~._._
Allorney tor: ?l ",inti ff
Telephone: R<;<;-dR?-6QOO
Supreme Court ID No. 0430?
TRUE COpy FAOM RECORD
111 T8$timony whereof, I r,'!1rl) imto set my hand
and tile of said at (:i:1fHsle, Fa.
day of
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYL V ANtAl
COUNTY OF CUMBERLAND)
NO.
01-6461 TERM
CIVIL 19
CIVIL ACTION - LAW -
TO THE SHERIFF OF
Cumberland
COUNTY
To satisfy Ihe debt, interest and costs due _We_l}s_.F:~o Bank Minnesota,
_~Codil~Stawiarski, Mo=is, Schneider & Prior, LLP
lrom ___J<eith__E. Miller, C/O ABF Freight Sys~E:ffi' Inc., 2001 Ha=isburg
PA 17013, P.O.Box 591, Boiling Springs, PA 17007-0591
-----._---
NA as trustee c/o Moss,
PLAINTIFF(S)
Pike, Carlisle,
(1)
DEFENDANT(S)
You are directed to levy upon lhe property 01 the delendant(s) and to sell See Leqal Description
(2)
You are also directed to allach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to nolijy 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 proper\yof thedefendant(s) not levied upon an subject to attachment is found in the poSSessioA_R!~~Q~Qther
thana namedgamishee. you are directed to notify hinVherthat he/she has been added as a garnishee andisehlOli'i:lllf:as"above
stated_ - . -.
Amount Due $66,417.76 LL
from 12/22/01 to date of sale
Interest 6/3/02 Por diem @$17 6h-$? Q'll 'i6 Due prothy
AllY'S Comm % Other Costs
$.50
$1.00
Ally Paid
Plainlif1 Paid
$lO'l.'}'i
Date
DPrPmhpr ,}R, 2001
Curtis R. Long
~'cPOO~;:~L
Deputy
<..Qy
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address ~N. Kings Hiqhway, Suite 500
J::berry Hil1~ NJ 08034 ______ _ _
Anorney lor: Pli'lint-iff
Telephone: R"6-Ll87-h'lnn
Supreme Court 10 No_ 043n7
TAUE COPY FROM RECORD
lfi T~wliMl>a1, I mre Ull-m.set mv hand
Md tilt) of said C,"rt at C<\,lis!fl. Pi.
ay of
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller . NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Pefendant(s)
AFFIPAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, Plaintiff in the above action,
by its attorney, Mark J. Udren, ESQ., sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property located at: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owqer(s) :
Name Address
Keith E. Miller
13 Front Street, Boiling Springs, PA 17007
P.O. Box 591, Boiling Springs, PA 11007-0591
C/O ABF Freight System, Inc.,
2001 Harrisburg Pike, Carlisle, PA 17013
40 North Middlesex Road,
Middlesex Twp., PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
Same as #1 above
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
None
,
;;$
,~"".;'_~"'Ohill.~"--","""'h'.,~-<,~-'~ ~ ~~"""--j' ~,'~, .~ .,. ~~
~~~~= _". ".w~
J ~......_ .~~- '.........~--tB1.tJiIj~-'!'!!'€!'.t\ll;r~db'_,_,"'_",,'
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
6. Name and address of every other person who has any record interest in
the property and whose intere'st 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
40 North Middlesex Road,
Middlesex Twp., PA 17013
I verify that the statements made in this affidavit are true and correct
to the best of my personal krlOwledge 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: December 21, 2001
MARK J. UDREN & ASSOCIATES
. +G~~Q
. " A torney for Plaintiff
-',---,/
"
~=-.~~"'""""_""":.6",,,,,,,,",,,,,,,,~,,~~,,,<,.6,,,,,--..l!,,-' ",..
'--=r'lIilr.~iIW"-_~~"~W'_' <--... - - _~Lb~. ,~~ ~''-Ili
- - I .~~ u "~~~~Nr..' - ";:'C"!ifI1&w.w..q;b';l1idt,,
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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller . NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owqer(s) :
Name Address
Keith E. Miller
13 Front Street, Boiling Springs, PA 17007
P.O. Box 591, Boiling Springs, PA 11007-0591
C/O ABF Freight System, Inc.,
2001 Harrisburg Pike, Carlisle, PA 17013
40 North Middlesex Road,
Middlesex Twp., 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
.
,1_~..J'I""_'illEfci.!Li"-"-<iJ"",'",=C-""-~""'_-'w'"'n'_l<'''''"","~''' ~."-. ,,-, ."
._~ ,,,-,, ~->--~
~I -
"- ........~"""'- .,.~,-~ -~~
,- ~~ ~,
E_ ~
"', !J:t;_'JL.~t~-''Wj-H.,i
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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
40 North Middlesex Road,
Middlesex Twp., 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.
DATED: December 21, 2001
MARK J. UDREN & ASSOCIATES
,m
'. MClJ k J. Udre'R....,. ESQ.
\, AJtorney for Plaintiff
"----"
_""""""""_~"'i'ill""""'~''''~~_''--,^~__,-'.."d'''''-'",",:d.",",,,l'=~''',,,"'''='''i'''''';'''~ij~ _0 _, ~ _ ""',_.......J.~~~.~
, ~ ~ ~"'
",I
~,.>.~\ll~U>i<~O"'1').<-"u,"',^',.
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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owqer(s) :
Name Address
Keith E. Miller
13 Front Street, Boiling Springs, PA 17007
P.O. Box 591, Boiling Springs, PA 17007-0591
C/O ABF Freight System, Inc.,
2001 Harrisburg Pike, Carlisle, PA 17013
40 North Middlesex Road,
Middlesex Twp., 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
"__~~"""""",&r;g;;'''M,,,,,,,,,,-~~,,,,,,,,,,"_~''''''''''~''''-~~I'Il.l~~~~'- ..~,.- ~ "'~,~""
I,~
I.........."""~-~<~. I'~'_''''-ti --" "'l~''1f~IW&.- -"-"'~'lfIi_"~";:',1i,,,~'_-_D'-
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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 Ta~ 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
40 North Middlesex Road,
Middlesex Twp., 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 subj~ctto .the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: Decembe~ 21, 2001
MARK J UDREN & ASSOCIATES
\~~ .
Malfk J. Udre~ESQ.
. Ajtorney for Plaintiff
~
,. ~="~-~"",,",,=""____0"""""" ,- ,_.~--"",,,;~~.uJ;,_ ~~",",>'J.ii,." _ [~!K !,'~~iO!lj;ilItt~"".'-"'-'"~~"""- ~.
L...,
.~~.~ u"'~~"BMM' ~'ll!il:~"- "iJM~~l%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
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
Bank Minnesota, NA - COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed owqer(s) :
Name Address
Keith E. Miller
13_ Front Street, Boiling Springs, PA 17007
P.O. Box 591, Boiling Springs, PA 17007-0591
C/O ABF Freight System, Inc.,
2001 Harrisburg Pike, Carlisle, PA 17013
40 North Middlesex Road,
Middlesex Twp., 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
~"-""~""~",",_'''''''''''J''''~~,'b.<.-i>'>J""=<"~..--"..."",-".~~,,,,,,,._"~ - ,
, w'" ''''""~'*Il'
-~
"' ~
oI..J-~~"__ ~. ,_. ~.
-~<'-'''ill[fr~l!il!il!dJj t!ilt' "- J. <' -~~~fiJ;;i:;;5~'"
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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
40 North Middlesex Road,
Middlesex Twp., 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.
DATED: December 21, 2001
MARK J. UDREN & ASSOCIATES
. ~ESQ
',.ytorney for Plaintiff
-
"'""""~"~""!ill!ill""_,"-,_"_llJl_~'^-;''''''''''''"''''e;;;il&<l~~~~,+
~ .........,~~ ,
..
~ ""'.........., ., j"~~,~-"
k== -" ~'~~!I\'iU~~iim_""'''"
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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10;00 A.M. in the Commissioners Hearing Room, 2nd Floor; Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BF. ABLE TO PREVENT THTS SHERIFF'S SALE
To prevent chis 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: (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 ente'red. 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 obcain an attorney.)
fe!
~"""'~~_~"-II""~"'='.,,,,,",,,,, '."-"""'~''''-~f,'J~" ""~~, """fl'~~r~'
---~-~
"~I
-
.,,-,
"I t1 -.
~"~""'~i'_1l.,"""",<~,,-,-\-,-r~,',
YOU MAY STILL BE ABLE TO aAVE 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 eviqt 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
n'j;~~~~",J,-",i.~"'''';~''~~'!'''''''''''~'''~~'..~~~~''~''-''''"~'''-I<ll:~1il!j;:,W "
..J
. I~~
" ,I" .~ ~~'-~ili.:~~~_Jld.i;>'1"k+k\",,,
}>,'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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABI.J': TO PRF:VF.N'I' THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate a~tion:
1. The sale ~ill be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (SS6) 482-6900
mortgagee the back payment, late
To find out ho~ much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
"""
;d-::t~.-;~t-';"~~.ll!!iilIi;~~.il'~liOtM"i>\,!~'k.'<l'$''''''-'-',-;,Yiij,''''''",!_,i',''','J;;_;<IO'i....-,)i\--,\,:?*''~I.~>i.\-..''''''''"iI1, ~~,"~~_",~.i
.."."" ,,,,,,,,,,-,,,,,,"',",,,< ~-
^~_<,.~"'__~~,,' -,,",-.. ,,,-,-4"'f''''_~,.....,. ,,__ ,,-.-," ,"''''''~, .
. -~"_. , ,p~"",",' ,,,,",,,, .--' .",
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,",
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"~I
--"r- H'" ="J,,,,,..L..,~,, ~
~~'1!W""'>lf- ,.,' -~'='~g;.~'iJ~j';'
YOU MAY STILL BE-A~E TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RLQHTS
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 evi~t 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 l?APER 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 HELl?
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
8({0-990-9108
""
<'~~'"~~~"""""".".""""" .""""',"",.b'""'"""-'I.."..."'.M'~'.f~I'~~ . ,~-"~ .~.. ~~1lI~~---"~~-., ~ ~~~",,"~, "~..
~ -,' ~
L -~'~~~" -. _.......~t,I";;;~",,;;,,--"_,.!.,f'..,
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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., FA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNE~'S RIGHTS
YOU MAY BE ABLE TO PREVENT THTS SHERIFF'S SALF.
To prevent this Sheriff's Sale, you must take ~ediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (R56) 4R2-6900
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 \o?as 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.)
,~~~..."""""""-=","~"""",,..".,<-c',,~",;.,""""'__"'~~ -" - < ~< ~.._~
.~ ",""ill"",~' . ~~--" ~~ .~
<"I~~. ~."..
~~" ~ ".- ",,' '"'
lL ~-- ~~li""4_jl'~,;j~""-IC'~liir~"''''<'-)_''--''_C'
YOU MAY STILL BE ABLE TO SAVE YOUR PROEERTY 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 evi~t 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 APFORD ONE, GO TO OR TBLEPHONE THE OFFICE LISTED BELOW TO FIND OU'!' 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
~"f""W!~""""",~~Jiijlli,dill-c*,_,,,_","',""""'""'~~~~' -"""""''''~.' .....~- ~"
~"
.., ,.
~=
m~~iwdJjil!i$i.}j,J'I:W@~~tmi-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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
p . O. Box 24 73 7~:"MORTGAGE-FORECLOSURE
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
plaintiff
v.
Keith E. Miller
.
. NO. 01.-6461. Civil Term
C/O ABF Freight system, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI,E
To prevent this Sheriff's Sale, you must take 1mmediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: jE56) 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.)
...",~,~=",."""""""",,,,,.,il"""'C,"",,,,,---,,,"",;~,,,~,,~~" H .~=~'".&~ .~, ...""""",,-,,,,,-- "~- - '
l""
~ c,~ nc.""""""='
.
. " ur~~Ell ~!t'",';0iIM,*W;\W_,"~
YOU MAY STILL-B~BLE TO SAVE YOU~~RTY AND Y~VE 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 evic;t 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 wich 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
_'"""""--___~~"~'"',J."__'__' _ ".."'=o..,_....,~'".,~""",_I,."""
~~ -J.,_ . "~..b
~.
,,~~ ; L, '~~_'~~' ,_. ='r.,,~,-,
"""'&.~,;oi;>
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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00' A. M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856) 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
"",~~.""",
:_~,;,""'_:-'--~""'.''''''~-~~!ll~'''''''<''~"' -. "'. ~ ~.......- ~~~'l/r-'"'"' '~h "
._" """""_"",,I~.....J~ ~~~.IIIIailI. .J ~ ..~"" '. .J.","j'J"
~~ll.Ml
, '~"~'~I$-~!i~~;,
YOU MAY STIL~ ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIG~
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.
2. 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 eviqt 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 20 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 17012
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
,-
-'.iI<M"""i~~",,-"V~"-'"_''''''''~"'~'<~ r ~.'-""
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"'~IIl1~1 ~ ~lJElll-'-"'''''''''
tl:Ii<l~~"!~~-tH"L~
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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 PRRVENT 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
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.)
~__M~ !Ill .~ '~
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~-~ -~
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YOU MAY STILL BE ABLE TO $AVE 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 LAWYBR 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 FlLADELFIA
Cumberland county Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
"""'~~~i<J)~"",",..w.l1,"..:",,~..,,-,~~--'rIt"j '''~~~-~~~ 1iIil!lll!~"-" ._-
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
'.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor,. Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 ABI,e; TO PRRVENT THIS SHERIFF'S SAT,R
To prevent this Sheriff's Sale, you must take immediate a~tion:
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.)
"1;
.._~"'''''"'''''~''o'~ill_".,""",~"".~,,,,,,,,,,~~''''''-"'''- " - . -""'"'~,....._"_.-
,~_>L~~., ~
'~~1 'Ii - j. ~ '~ ~',~- "~.~~r.lOiili\!MIlli_""~\,:,,-,",-o~ti","i-~',,
YOU MAY ETILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PL~
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 evi~t 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
__ ~_~=_=""",".lli,,, ~""~~ ^'~~"
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~ 'l 1flI.~~""'" ""'~'" Jw.__~:k>~(-cl;,-".:',1\"\_"""
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAYE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
l. 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 eviqt 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
(lO) 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 l70l3
n 7-249-3l66
800-990-9l08
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue__
Carlisle, PA 17013
717-249-3166
800-990-9108
,
""-"-"=-="~""""""'tII<:~,:;;~,;""",,...I-";I"llil~_~.li!Il~iilIIl '" '.- .....~'=...,"l
~
.^'~,~.- -.".J~~!iOO'tillliali!ii'~""W\!!~-,;!i&f4"'"",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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. BOx 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
C/O ABf Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABFFreight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 Js scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 '1'0 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
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.)
","--";Will'!i~~Oi..:l;~",,~,____'.i'_~"""
~, ~"
-=
~- '"~ _.I.. ~_,,"-_ ._F" ''''~~~~~>l.li;;'!!;j''B~'"''',i'~:';',;,''''~''
YOU MAY STILL-B~E 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 eviqt 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
7l7-249-3166
800-990-9108
o","-,,;--',M\~-"----","'''''illi'')~II,,;,,~~_,,,,~~~' L
" ~ III I
~< ~~- ~j ; j Il!Ilii '='''"''''f''~ ~ III li~~dl'~','''''.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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
'.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002,at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 SALF:
To prevent this Sheriff1s Sale, you must take ~~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.)
~_~_ "_"'~'M-,,,",",,,,,,:;,",_.......~
. ~~._"_.",..~""
~'" .
I~ ~
~ ~
iI~mw~M-'lfu~-Mi1f<lk;r=~~:"";"""-,._",,,_,,,",,,_",
Y~~-Y-STILL-BE-ABLE TO SAVE YOUR PROPERTY AND YOU HAYE 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 eviqt 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 fAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEfHONE THE OFFICE L.ISTED BELOW TO FIND OUT WllERE YOU CAN
GET LEGAL HELf.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
~
,,-'.'"''
--"'''~''~--'I
"~ ~. ~~.~'"'
" J__ l '.~' ,. "~._
"
,'~~ .~ I,"""",,"~~....,.. i\'fl'ft1~~~~~~:';:>!<W-M'{il!jj,:".
MARK J. UDREN & ASSOCIATES
BY: Mark J. udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS EIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
"
NOTICE OF SHERIFF'S SALE OF REAL PROPER~
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 .is scheduled to be sold at the Sheriff I s Sale on -June 5 ,':c002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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. '1'0 PRF.VF.N'r 'rHIS SHERIFF'S SAT,F.
To prevent this Sheriff's Sale, you must take ~ediate aotion~
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (8S6) 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
J""""""""'__.....~"''''.. ~'~'~- '"~ !lij
".~~-"""', '. ~;.- - bl
ilii!lll!il>l.~ L ~~.."-~~~~
"' ~.I '>~-'-'- - "'"""'". ~Iiiliil 1iiIIIll'.... ,~~ ~ J 'll:Iil ~, .' ~!lliidliJiW.i!~if~,,,-,"J
::L~TILL BE ABLE TO S~VE~RQEKRTY AND YOU-H,AVE OTHER RIGHTS
EYEN 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 eviqt 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 schedul~ 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 FINO 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
; Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
~OTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 ;is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 Tn PREVENT THIS SHERIFF'S SALE
To prevent this She~iff'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: (8"6\ 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 j~dgment, if the judgment was improperly entered, You may also ask
the Court to postpone the sale for good cause.
3. You may also De able to stop the sale through other legal proceedings.
You may need ~n 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
'''''''''''''_-'''''''''''''''''--<>'''''''~~"1~,,--,,",,,---,~~' ~~. ">>i!'"~~
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Bo}C 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 Js scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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
yon MAY Be: ABLE 'I'O PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immedia~e ac~ion:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (8S6) 4R2-69DD
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.)
"""di.""'.,..!..,""\",ll','~"_,m!""~~-"-""',.~""""""';;;~~~~~"''"~'~. .- '"ii1lJllO ~~l .~,,-' "~
~, "-.~ -
M~'"" ,~' l!iiilill!!l~H.!i!,rn,,"'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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 civil Term
Defendant(s)
\\
. --.1\
/;,"--,:>
\g~ .
~~
Clo ABF Freight system, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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.
i
I .
( J
\ Mark J. Udr ,ESQUIRE
~ATTORNEY FOR PLAINTIFF
& ASSOCIATES
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Eeach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, FA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
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)
" -LC. In Mortgage Foreclosure
____D. On a Note accompanying a purchase money mortgage and the property
being exposed to sale is the mortgaged property.
II. The Defendant(s) own the property being exposed to sale as:
--LA.
____B.
____C.
____D.
____E.
F.
An individual
Tenants by Entireties
Joint Tenants with right of survivorship
A partnership
Tenants in Common
A corporation
III. The Defendant(s) is (are):
-LA.
____B.
____C.
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:
i~~JifAl~~,~i.;'WT'tiiilll.."''t'g1liU!',~i-il,t:l'W''P-*,i<l~,d,,"\i;;'0C-T-,-h',"";'tc,,,,,,",.'~j;,;':*,,"""r;,'fd~#I6,,,;-'lii:"'ji-~J~IiI_~.a&!! -" . j"~'N ' it::'iii!liliniiftiiwil!!IlI."~
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Keith E. Miller
.
. NO. 01-6461 Civil Term
c/o ABF Freight system, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, ?A 17007-0591
Defendant(s)
ii
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(Q)<.--\ I '15,
(1"-, " )
(~---/ -/
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'-.~
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$66,417 76
Interest From Decemb~r 22, .2001
to Date of Sale June 5, 2002
Per diem @$17.66
2,931 56
(Costs to be added)
$
MARK J. UDREN & ASSOCIATES
,....4E-'''''- -,-~^~ , ~ 1 .&~" -'lO~1
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ito-":i<I'ljii".iYll!!lfl,;j;l\~<''''',t''':S~",Jl.'''jl''",''tW'''_-'
YOU MAY STILL~~LE TO SAVE YOUR PROPERTY AND YOU ~ OTHER RIGHTS
EVEN IF TH~ 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 S\'l.eriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to eviqt 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 T~E 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 Cl\N
GET LEGAL HEL:P.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
carlisle, PA 17013
717-249-3166
800-990-9108
'~"<_"'W""""''''''',*~ll!!'W'__l~,;..'',~,-,,,",,,,,,- ~~'.'~"_-"_'_'"'~"~ "",'. ~ .~
"
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i~"''"~- ~~~~lilli!ll';T "iMoJi;JW,,,,,,I<c!'^Y,,,-;-;-,,_
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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
- NO. 01-6461 Civil Term
C/o ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
'.
NOTICE OF SHERIFF'S SALE OF REAL PROPERT)!:
TO: Keith E. Miller
C/O ABF Freight system, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013.is scheduled to be sold at the Sheriff's Sal<=onJune 5,2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 RR ART,R 1'0 PRRVRNT 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: (856) 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
. ,
""J""~~"""'",="' '_=,~o it!i!llii:lllll"^'""""' '1iI'=
1DilIIIII!II!" ,f.
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,L~,,""~
"" -~--""~-ils: '"- ~'*,,!i;:""'-~~~,'i~~'"A~
YOU MAY STILv BE ABLE TO SAVE YOUR PROPERTY AND YOU EAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If t:he 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 eviqt 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty A"I.'enue
Carlisle, PA 17013
717-249-3166
800-990-9108
"';:,~~~~~""-''''''''''~~ ",-,-~,~-~=~,~
,.''''~'
~-~" ~. - J ,1
~_1d1 ~ """",,,,-. - d'
---'''''~tM.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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
- NO. 01-646~ civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 Js scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NQrICE OF OWNER'S RIGHTS
YOU MAY BE ABLE '1'0 PREVENT THIS SHERIFF'S SALE
TO prevent this Sheriff's Sale, you must take immedia~e ac~ion:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856) 482-6900
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.)
L
',~i.ru~iiE~"'j~,,,,,>,,~--' r'--"~" ,",". ~"~-~~'~_,_"""",,",,,,,, L
.l.."~..
_-J,:i,~~
~ - ~_W' -j.
-
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 eviqt 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 schedul~ 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
_t&o:,.~i~H,__'_
m;
"~'_~11lI1!l - ~ <:'fl ",,",' h'ilI!!.">'" ~,""'~ ", "'_,,'., ~" ' ,~.....',.- , ~~ -
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,-, 1 'iMiOl;~il'~I"!I~ij;-iilj!lilAl;ai~~~"""";;'-"i~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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTX
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA { to enforce the court judgment of $66,417.76, 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 ABl.!i: TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immedia~e action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (8<;6) 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.)
_tJ;~
-
~, "
~-, "
L~
-
)r'
<~,~
,~ """'!:>.iii.?,:""'''''''''~'- ,,'
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.
~ 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
,'"...~,ilillW;EO;M;1.jjj~-"".....Aili..,~~~~"'''''''~ ~'I;ir'l~- >-"'""""'~iIIlI~ J..,. -""-
-
~ ".MiJill.'-
-
~I~
dI~Ul:~_)'l"",q,:,-,_",_,,_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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P. O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
- NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF. REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthous~,.
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 RIGffIS
YOU MAY BE ABLE TO PREVF.NT 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
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.)
~
~~~>lJIilll~>il7-'<"i&"'_=,,,;l"Plt'.,~, ,........."<".....-.
_...._ -'W~,'-
'"
, I
,,'...
" _L~."" -~ - j ~ "_~""'''''''''''~~"'~;",,"_-'-r:''i;'U''
YOU MAY STILL ~ABLE TO SAVE YO~ROPERTY AND~U 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 evi~t 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 ex~eptions
(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 y~ur 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
.~..u}r,ih"k~~~~'M""'''-',"b.'''-~
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-
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'lMfu':L""'$;;'i\I,w'
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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, CourthousE;!,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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
charges, costs and reasonable attorney's fees.
you may call: (8,6) 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.)
..
","~~~""',!iI-:>J""'<1i:-'!~"I"""",-"""""...__"",,_._,=~,~"= ~" -~. ~~'1IiJi!lilIl:=~-"~.
~~~ ~,I ~
~~.' "",, ,--
.1 M~""'j!;jll."'~. ~'~oo~_.'--"""'--'-d-Lillh,,','J:'''_>-<-
YOU MAY STILL BE ~LE 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 tind 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 evist 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 aut 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
d"'i,"",~~~,"""'l~"'''",''''liO~.'~_'''''~'''''''-''- iIiMI' '
-.........;
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'''(~iilIM~,_"",,",',",:~'''''''''li'T''''''
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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
. NO. 01-6461 Civil Term
C/o ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
.Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10: 00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthous~,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take ~ediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (806) 482-6QOO
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. Ybu may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
,f
,__-,',,,w-
"......~~'"",,~___"'N~' ~
. ~'""'..,'~ ~ ~ liiliIltiI~.......~- - -.
I.........:~
"~
"L..~ Ulr '~W!iii!ij~~..1ill:!__~-,;>>,'..,
YOU MAY STILL B~ABLE TO SAYE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EYEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2, You may be able to petition the Court to set aside 'the sale if the bid price
was gro$sly 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 evist 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
=,,,,,,,,,,., ~__,~,;;li'Jiii.i~-""~~~f"i;JIII-~~~"'~'
~-,~
I....-~~~"
.
L.~. _
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
. NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relistedfor the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAT,E
To prevent this Sheriffrs 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.)
-'
_~~~"=~~~,_--=w;;"=~""""",,-,,,-,,,,~~~,_,,;,,,,~,.
Ill' A"~'~I__ ~ ~~
"",~~~.1 ~~ ,_
,
-,' -~~':t~-_liii!I-="""- :r>'- al'i!l~~~1i!I;.I!t~!Y"""_4"
YOU MAY STILL BE ABLE TO~:eRQPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE-SHERIFF'SSALE 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 evist 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 witll 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
_~,_,_,-",~,~;MA<i;<liL~~.JaI~li<i!"",,b...,-,,",,~~~,"1II"'"""''''''"llf".ll '-~d. ~OI~ .~=.h,"-, ~.
~lIh'"~"U ..l~~....
- ~ ,,~~ ~llll"
~"""~~,"",;""",""-,,,,',,,",,- '
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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
- NO. 01-6461 Civil Term
C/O ABF freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $66,417.76, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (8"6) 482-6900
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping' the sale. (See notice on page two on how
to obtain an attorney.)
'''k"'l"".~~~~''''',d.",,,,"-.~,",",,,,~,",,,'''''IfW..i~
~"~~
--.
~.. ~ _ k~ ..I.. ~'~~ ""
~~~IillU!IJ~i'~~~'~<I$_';~li,~,"'_M..t~' ,
YOn MAY STILL BE ABLE TO SA~OUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE-DOES TAKE PLACE.
1, If the SheJ:"iff' s Sale is not stopped, youJ:" pJ:"opeJ:"ty will be sold to the
highest biddeJ:". You may find out the pJ:"ice bid by calling 856-482-6900.
2. You may be able to petition the CouJ:"t to set aside the sale if the bid pJ:"ice
was gJ:"ossly inadequate compaJ:"ed to the value of youJ:" pJ:"opeJ:"ty.
3. The sale will go thJ:"ough only if the buyeJ:" pays the SheJ:"iff 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 fJ:"om the BuyeJ:" is not paid to the SheJ:"iff, you will J:"emain
the owneJ:" of the pJ:"opeJ:"ty as if the sale neveJ:" happened.
5. You have the J:"ight to J:"emain in the pJ:"opeJ:"ty until the full amount due is
paid to the SheJ:"iff and the Sheriff gives a deed to the buyeJ:". At that time, the buyeJ:"
may bring legal pJ:"oceedings to evist you.
6. You may be entitled to a shaJ:"e of the money which was paid fOJ:" your house,
A schedule of distJ:"ibution of the money bid for youJ:" 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 y~ur 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
.
- NO. O~-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at
10:00 A.M. in the Commissioners Hearing Room, ... 2nd Floor, Courthoust;;,
Carlisle, PA , to enforce the court judgment of $66,417.76, 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 BR 1'.BT.E TO PREVENT THIS SHRRTFF'S SALE
To prevent tnis 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: (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.)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RlGHTS
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 evi~t 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 witll 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 FlLADELFIA
Cumberland County Bar Association
2 Liberty. Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
. NO. 01-6461 Civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
DATE: December 21, 2001
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Keith E. Miller
PROPERTY: 40 North Middlesex Road
Middlesex Twp., PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on June 5. 2002, 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.
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
-
- COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
. NO. 01-6461 Civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
DATE: December 21, 2001
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Keith E. Miller
PROPERTY: 40 North Middlesex Road
Middlesex Twp., PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on June 5. 2002, 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.
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
. NO. 01-6461 Civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
DATE: December 21, 2001
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Keith E. Miller
PROPERTY: 40 North Middlesex Road
Middlesex Twp., PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on ~e 5. 2002, 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.
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IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLV~IA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS,
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BEGINNING AT ~ IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC .ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY rD NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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GAP; THENCE BY LAND NOW OR FORMERLY OF JOaN GROSZ, SOUTH 73 DEGREES WEST ~27.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST ~~9.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST ~~9.5 .FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; T~NCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO lIN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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MINUTES EAST 1L9.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER .OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
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AND DESCRIBED AS FOLLOWS:
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H.MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK l43,
PAGE 1188.
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AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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AND DESCRIBED AS ~OLLOWS,
llEGINNING AT AN IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC. ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT, THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS .VESTED IN KEITH E. MILLER BY DEED FROM
. BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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AND DESCRIBED AS FOLLOWS:
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GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
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BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 2l-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/l2/96, IN DEED BOOK 143,
PAGE ll88.
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GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST .127.5 FEET
to A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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AND DESCRIBED AS ~OLLOWS:
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GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
. FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS ~OLLOWS:
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GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
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BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SITUATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS ~OLLOWS:
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llEGINNING AT AN IRON PIN AT O,R NEAR THE CENTER OF THE PUBLIC. ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SITUATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS rOLLOWS:
llEGINNING AT AN IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC. ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP, THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF '!HE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SITUATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS ~OLLOWS:
BEGINNING AT AN IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC ROAD LEADING FROM THE'
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP, THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MISSLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
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LA W OFFICES
MARK J. UDREN & ASSOCIATES
1040 NORTH KINGS HIGHWAY
SUITE 500
CHERRY HlIL, NEW JERSEY 08034
856. 482 . 6900
FAX: 856. 482. 1199
FREDDIE MAC
PENNSYLVANIA
DESIGNA TED COUNSEL
December 21, 2001
Office of the Sheriff
Cumberland County Courthouse
Re: Wells Fargo Bank Minnesota, NA as trustee
vs.
Keith E. Miller
Cumberland County C.C.P. No. 01-6461 Civil Term
Dear Sir:
Please serve the Defendant (s), Keith E. Miller at ABF Freight
System, Inc. 2001 Harrisburg Pike, Carlisle, PA 17013, 13 Front
Street, Boiling Springs, PA 17007 and at 40 North Middlesex Road,
Middlesex Twp., PA 17013. Please post property at 40 North
Middlesex Road, Middlesex Twp., PA 17013. Thank you for your
assistance in this matter.
Sincerely,
a
Christa Pietrzak
Foreclosure Specialist
.
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LA W OFFICES
MARK J. UDREN & ASSOCIATES
1040 NORTH KINGS HIGHWAY
SUITE 500
CHERRY HIU, NEW JERSEY 08034
856. 482 . 6900
FAX: 856. 482. II99
~
PENNSYL VANIA
DESIGN A TED COUNSEL
December 21, 2001
Office of the Sheriff
Cumberland County Courthouse
Re: Wells Fargo Bank Minnesota, NA as trustee
vs.
Keith E. Miller
Cumberland County C.C.P. No. 01-6461 civil Term
Dear Sir:
Please serve the Defendant (s), Keith E. Miller at ABF Freight
System, Inc. 2001 Harrisburg Pike, Carlisle, PA 17013, 13 Front
Street, Boiling Springs, PA 17007 and at 40 North Middlesex Road,
Middlesex Twp., PA 1.7013. Please post ,property at 40 North
Middlesex Road, Middlesex Twp., PA 17013. Thank you for your
assistance in this matter.
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Christa Pietrzak
Foreclosure Specialist
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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
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
Bank Minnesota, NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: NO. 01-6461 civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
PRAECIPE TO WITHDRAW JUDGMENT
TO THE PROTHONOTARY:
Kindly withdraw the Judgment entered on December 28, 2001
upon Keith E. Miller in the amount of $66,417.76. Defendant(s),
Keith E. Miller filed a CHAPTER 7 BANKRUPTCY ON November 29, 2001
- #01-06350.
MARK J. UDREN & ASSOCIATES
.~
Mark J. Udren, ESQUIRE
ATTORNEY FOR PLAINTIFF
DATED: January 31, 2002
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-6461 Civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Keith E. Miller
has filed Chapter 7 Bankruptcy in the Middle District of
Pennsylvania on November 29, 2001, Bankruptcy Case No. 01-06350.
~
Mark J. Udren, Esquire
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
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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
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Wells Fargo Bank Minnesota, NA
as trustee
v.
Keith E. Miller
Defendant(s)
.
. NO. 01-6461 Civil Term
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
DATED: May 3, 2002
& ASSOCIATES
Mark J. Ud en, Esquire
Attorney f Plaintiff
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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.
W
Name: \NiI\\,Qh') 1lt.~Q",d
Ti tle: \).'r~c..~\":. L.m.h ~sol.l{4-w,,'S
Company: ~W-e;-., t 'rat &tfJt f57j
Date:
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
,l.NSWER 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 9/7/01 to 5/3/02
Late charges per Complaint
From 9/7/01 to 5/3/02
Escrow payment per Complaint
From 9/7/01 to 5/3/02
$64,422.40
4,220.74
246.80
.D....JLQ
TOTAL
.$--6JL 889.94
I hereby certify that
Defendant are as shown above,
accordance with Rule 237.1, a
esses of the Plaintiff and
notice has been given in
's attached hereto.
K J.
ASSOCIATES
Ma k J. Udren, SQUIRE
~" Attorney for PIa
DAMAGES ARE HEREBY ASSESSED
DATE: fY/.';J..., 1'1 ::(1'Jt'J J.
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IN THE UNITED STATES BANKRUPTCY
COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE: Keith E. Miller
CHAPTER 7
CASE NO. 01-06350
111 U.S.C. SEC. 362
Wells Fargo Bank Minnesota,
N.A., As Trustee
Movant
vs.
Keith E. Miller
Debtor(s)
and
Leon P. Haller, Esquire
Trustee
RESPONDENTS
o ) '()/?~O C\
fvl
ORDER MODIFY~NG SECTION 362 AUTOMATIC STAY
AND NOW, this c=;p'/T;:/day of /'J?t~ ,2010~
Motion of Movant above, it is .
,upon
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:
40 North Middlesex Road
Middlesex Township, PA 17013
as to allow the Movant to foreclose on its mortgage and allow the
purchaser of said premises at Sheriff's Sale (or purchaser's
assignee) to take any legal action for enforcement of its right to
possessiOn.of saidpremisesr and it is
FURTHER ORDERED THAT: The relief granted by this order shall
survive the conversion of this bankruptcy case to a case under any
other Chapter of the Bankruptcy Coder and it is
FURTHER ORDERED THAT: The relief granted by this order shall
be effective immediately and shall not be subject to the ten day
period set forth in Bankruptcy Rule 4001 (a) (3) .
Js/ Robert J. Woodside
___"1
Bankruptcy Judge
FILED
J
HARRISBUP.G
PA
MAR 20 2002
L~ .',
Clerk, U.S. Bankruptcy Court \
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MARK J. ODREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Keith E. Miller
Defendant(s)
NO. 01-6461 Civil Term
DATED:
TO:
April 22, 2002
Keith E. Miller
40 North Middlesex Road
Middlesex Twp., 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
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 .
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-61100
Wells Fargo Bank Minnesota, NA as
trustee c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Keith E. Miller
Defendant(s}
NO. 01-6461 civil Term
DATED:
TO:
April 22, 2002
Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
rMPORTANT NOTrCE
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
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DEN'I'RO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
8~6-482-6900
Wells Fargo Bank Minnesota, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Rei th E. Miller
Defendant(s)
NO. 01-6461 Civil Term
April 22, 2002
Kei th E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg P~ke
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 FINn 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
NOTIFICACION IMPORTANTE
DATED,
TO:
us TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIlUl IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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MARK J. UDREN & ASSOCIATES
BY: Mark J. udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHBRRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota, NA as
trustee c/o Moss,Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
~ COURT OF COMMON PLEAS
~CIVIL DIVISION
Cumberland County
Keith E. Miller
Defendant(s)
NO. 01-6461 civil Term
DATED:
TO:
April 22, 2002
Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
IMPORTANT NOTiCE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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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, NA
as trustee
c/o Moss, codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-6461 civil Term
v.
Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT OF' NON-MILTTARY
STATE OF YevV'\~\\JQt)iCL..
COUNTY OF ~b~rlQ.t')cJ
SERVICE
SS
THE UNDERSIGNED being duly SWorn, deposes and says that the
averments herein are based. upon investigations made and records
maintained by us either as Plaintiff qr as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Keith E. Miller
Over 18
As captioned above
Unknown
Defendant:
Age:
Residence:
Employment:
Over 18
As captioned
Unknown
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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
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
Bank Minnesota, NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s) .
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$68.889 94
Interest From May 4. 2002
to Date of Sale September 4, 2002
Per diem @$17.66
2.., 189.84
(Costs to be added)
$
ark J. Udre
ATTORNEY FOR
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6461 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NA AS
TRUSTEE, Plaintiff (s)
From KEITH E. MILLER, C/O ABF FREIGHT SYSTEM, INC., 2001 HARRISBURG PIKE,
CARLISLE, PA 17013 AND P.O.BOX 591, BOILING SPRINGS, PA 17007-0591
(1) You are directed 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 the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $68,889.94 L.L. $.50
Interest FROM MAY 4, 2002 TO DATE OF SALE SEPTEMBER 4, 2002 - PER DIEM @$17.66 -
$2,189.84
Atty's Corum %
Atty Paid S 133.25
Plaintiff Paid
Date: MAY 14, 2002
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary, Civil Division
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REQUESTING PARTY:
Narl,e MARK J. UDREN, ESQUIRE
Address: MARK J. UDREN & ASSOCIATES
1040 N. KINGS IDGHW AY, SIDTE 500
CHERRY HILLS, NJ 08034
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ill No. 08034
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERR1 HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 falsificat' n to authorities.
ASSOCIATES
Ma k J. Udren, SQUIRE
ATTORNEY FOR P~NTIFF
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West palm Beach, FL 33416-4737
.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. BOX 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike, Carlisle, PA 17013
P.O. Box 591, Boiling Springs,
PA 17007-0591
13 Front Street, Boiling Springs, PA 17007
40 North Middlesex Rd.,
Middlesex Twp., 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
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~4. Name and address of the last recorded holder of every mortgage of
record:
. Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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
40 North Middlesex Road
Middlesex Twp., PA 17013
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge. or inf mation and belief. I
understand that false statements herein are m e s ject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn f lsific tion to authorities.
M rk J. Udren, ESQ
Attorney for Plaint'ff
DATED: May 3, 2002
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
plaintiff
v.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight system, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on September 4, 2002,
at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $68,889.94, 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 SAI,E
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: (A56l 4B2-6900
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.)
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.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
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MARK.iJ.. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
i 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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
"
" COURT OF COMMON PLEAS
CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller "NO. 01-6461 Civil Term
C/O ABF Freight system, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
.Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on September 4, 2002,
at 10:00 A.M. in the commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $68,889.94, 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 PRJ<:VENT THIS SHERIFF I S SAT,E
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: ~l-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.)
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Y9U 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 PAPBR 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 HEl-P.
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
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
. CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
Your house (real estate) at 40 North Middlesex Road, Middlesex
Twp., PA 17013 is scheduled to be sold at the Sheriff's Sale on
September 4, 2002, at 10:00 A.M. in the Commissioners Hearing Room,
2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $68,889.94, 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: (S56) 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.)
-
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,If.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKEP~
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.
amount due
6900.
The sale will go through only if the buyer pays the Sheriff the full
in the sale. To find out if this has happened, you may call 856-482-
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 e~ceptions (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 TH!S 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
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
p,O, Box 24737
west Palm Beach, FL 33416-4737
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
40 North Middlesex Road
Middlesex Twp., PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex
Twp., PA 17013 is scheduled to be sold at, the Sheriff's Sale on
September 4, 2002, at 10:00 A.M. in the Commissioners Hearing Room,
2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $68,889.94, 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
YClTr 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)-4R2-6900
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.)
~~
~...."
-
, '~,
.b... J~~-~ f ',- ~~,- >",;r&f~"...j"",l'_"'~';'"
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DQES TAKE p~
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.
amount due
6900.
The sale will go through only if the buyer pays the Sheriff the full
in the sale. To find out if this has happened, you may call 856-482-
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 PJlPER 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 LICENCIDADOSDE FILADELFIA
Cumberland county Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SITUATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC ROAD LEADING FROM THE
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
TITLE TO SAID PREMISES IS VESTED I~ KEITH E. MILLER, BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MIDDLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Mo~ris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Keith E. Miller
C/O ABF Freight System, Inc. :NO. 01-6461 Civil Term
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
40 North Middlesex Road
Middelsex Twp., 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 YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J. Udren. Esquire
At this telephone number:
856-482-6900
'l'
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l'ii"-~~Ia..,""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
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O, Box 24737
West Palm Beach, FL 33416~4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller 'NO. 01-6461 civil,Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 9/7/01 to 5/3/02
Late charges per Complaint
From 9/7/01 to 5/3/02
Escrow payment per Complaint
From 9/7/01 to 5/3/02
$64,422.40
4,220.74
246.80
-'LJl(l
TOTAL
$68.889.94
esses of the Plaintiff and
notice has been given in
's attached hereto.
I hereby certify that
Defendant are as shown above,
accordance with Rule 237.1, a
J.
ASSOCIATES
Ma k J. Udren, SQUIRE
.""". Attorney for Pla
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO,PROTHY
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'~"<'~ 'lIlIlt'flo"'_iii'iiM'""c
.
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller . NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
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 J
At this telephone number:
Udren. Esquire
856-482-6900
'r
,~'-" ~""!,,<
, .
'-~ 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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 9/7/01 to 5/3/02
Late charges per Complaint
From 9/7/01 to 5/3/02
Escrow payment per Complaint
From 9/7/01 to 5/3/02
$64,422.40
4,220.74
246.80
~
TOTAL
$68.889.94
I hereby c;ertify that
Defendant are as shown above,
accordance with Rule 237.1, a
esses of the Plaintiff and
notice has been given in
's attached hereto.
ASSOCIATES
Ma k J. Udren, SQUIRE
Attorney for PIa
DAMAGES ARE HEREBY ASSESSED AS. INDICATED,
DATE:
PRO PROTHY
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Keith E. Miller
C/O ABF Freight System, Inc. :NO. 01-6461 Civil Term
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
13 Front Street
Boiling Springs, PA 17007
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
-X- Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J Udren. Esquire
At this telephone number:
856-482-6900
l,
.
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
-
Keith E. Miller 'NO. 01-6461 civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, FA 17007-0591
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 1 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 9/7/01 to 5/3/02
Late charges per Complaint
From 9/7/01 to 5/3/02
Escrow payment per Complaint
From 9/7/01 to 5/3/02
$64,422.40
4,220.74
246.80
~
TOTAL
$68,889 94
I hereby certify that
Defendant are as shown above,
accordance with Rule 237.1, a
esses of the Plaintiff and
notice has been given in
's attached hereto.
ASSOCIATES
Ma k J. Udren, SQUIRE
',_", Attorney for Pla tiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO PROTHY
- ~'"
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
TO: Keith E. Miller
P.O. Box 591
Boiling Springs, PA 17007-0591
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that a Judgment has been entered against you in the above
proceeding as indicated below.
Prothonotary
~ Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY
Mark J. Udren. Esquirp.
At this telephone number:
856 482-6900
<>J"""-!l'_
-
~.
.
.
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1-.. ~~
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.
I
.
MARK J. VDREN & 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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
.
Keith E. Miller 'NO. 01-6461 Civil,Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
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 9/7/01 to 5/3/02
Late charges per Complaint
From 9/7/01 to 5/3/02
Escrow payment per Complaint
From 9/7/01 to 5/3/02
$64,422.40
4,220.74
246.80
.tL.QQ
TOTAL
$68.889.94
I hereby certify that
Defendant are as shown above,
accordance with Rule 237.1, a
esses of the Plaintiff and
notice has been given in
's attached hereto.
K J.
ASSOCIATES
Ma k J. Udren, SQUIRE
',,~ Attorney for Pla
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
PRO PROTHY
_,X _'_'-"~'~<" '_.' " ^_~"
-
.' MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren
ATTY LD. NO.
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West ,Palm Beach, FL 33416-4737
Plaintiff
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
: NO. 01-6461 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
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
relating to unsworn falsification to a
ies of 18 Pa.C.S. Section 4904
ies.
Dated: August 9, 2002
MARK J. UDREN & ASSOCIATES
BY:
rk J. Udren, Esquire
Attorney for Plaintiff
~
, ,j=-'-, "-".:'~-,',~~,-
, , "'"~':';""'''",'''''i~Ji",_,i "-,'... ',__ - J, ,- .,.-'-, ~",~" ,~,';I-j"',iik~..",-,,'>Il'''''~'ill!Il!ltkf.'''~,"\;~,,-u..,,),
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,
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
.
NA . COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
.
. NO. 01-6461 Civil Term
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road,
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Keith E. Miller
13 Front Street, Boiling Springs, PA 17007
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
.c' .
Ii-'--
-"""
".,g::,&}~ '~'o"",',;"-',0_" "'d,.',~ ". _"",,'." .,~ ,"" .'MiJ-.A'M"",,:t;*-,,-,,-,>c--'-c.,-,,.",,,~ .,~",,-~
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
Green Tree CDC
332 Minnesota Street, Suite 610
ST. Paul, MN 55101
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
350 N. Middle Sex Rd #1
Carlisle, PA 17013-8488
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, FA 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
40 North Middlesex Road,
Middlesex Twp., 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 herei ar made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to or falsification to authorities.
DATED: August 9, 2002
J. UDREN & ASSOCIATES
Mark J. Udren, ESQ.
Attorney for Plaintiff
1,_
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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, NA
as trustee
c/o Moss, COdilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-6461 civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.'
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
DATE: June 5, 2002
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Keith E. Miller c/o ABF Freight System, Inc.
PROPERTY: 40 North Middlesex Road, Middlesex Twp., PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on Saptember 4. 2002, at 10:00
A.M., at the Commissioners Hearing Room, 2nd FI, 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 A
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Wells Fargo Bank Minnesota, NA
As Trustee
VS
Keith E, Miller
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6461 Civil Term
".
.
This _ day of
t'JJJC1.s~,<~
R. Thomas Kline, Sheriff
ByJ(}~~Ctl
, Real Estat eputy
Sworn and subscribed to before me
2002, A.D.
Prothonotary
E.XHIBIT B
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberlapd County
NO. 01-6461 civil Term
v.
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Keith E. Miller
has filed Chapter 13 Bankruptcy in the Middle District of
Pennsylvania on September 3, 2002, Bankruptcy Case No. #02-04771.
M~dren, Esquire
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
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Wells Fargo Bank Minnesota, NA as
Trustee
VS
Keith E. Miller
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In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No, 2001-6461 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Mark 1. Ddren,
Sheriffs Costs:
Docketing
Surcharge
Law Library
Prothonotary
Mileage
Levy
Advertising
Posting Handbills
Share of Bills
Poundage
Postpone Sale
Law Journal
Patriot News
Certified Mail
30.00
20.00
.50
1.00
6.90
15,00
15.00
15.00
25,20
11.46
20,00
228.20
193,75
2,67
$ 584,68 paid by attorney
12/11/02
Sworn and subscribed to before me
This .2 7 liP day of j fl.,,~ t.......J
2002, A.D.Y-r' (), '"Jhd'#".-, ~
Prothonotary
S~~~
R. Thomas Kline, Sheriff
BvJ(J~ ~
Real Est te Deputy
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~ARK J. UDREN & ASSOCIATES
~Y: Mark J. Udren, Esquire
ATTY LD. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
.
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller "NO. 0~-646~ Civil Term
C/OABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank Minnesota, NA as trustee, 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: 40 North Middlesex Road
Middlesex Twp., PA 17013
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg Pike, Carlisle, PA 17013
P.O. Box 591, Boiling Springs,
PA 17007-0591
13 Front Street, Boiling springs, PA 17007
40 North Middlesex Rd.,
Middlesex Twp., 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
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4~ . Name and address of the last "recorded holder of every mortgage of
:r.ecord:
Name Address
.,
Plainciff herein.
See Caption above.
Green Tree CDC
Address to follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
Middlesex Township
Municipal Authority
Address to follow
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 gstate 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
40 North Middlesex Road
Middlesex Twp., PA 17013
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge, or inf ation and belief. I
understand that false statements herein are m e s ject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn f lsific tion to authorities.
M rk J. Udren, ESQ
Attorney for Plaint"ff
DATED: May 3, 2002
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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, NA
as trustee
c/o Moss, Codilis, Stawiarski,
Morris, Schneider & Prior, LLP
P.O. Box 24737
West Palm Beach, FL 33416-4737
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
.
Keith E. Miller . NO. 01-6461 Civil Term
C/O ABF Freight System, Inc.
2001 Harrisburg Pike
Carlisle, PA 17013
P.O. Box 591
Boiling Springs, PA 17007-0591
Defendarit(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith E. Miller
C/O ABF Freight System, Inc.
2001 Harrisburg pike
Carlisle, PA 17013
Your house (real estate) at 40 North Middlesex Road, Middlesex Twp., PA
17013 is scheduled to be sold at the Sheriff's Sale on September 4, 2002,
at ,1,0:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA , to enforce the court judgment of $68,889.94, 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
charges, costs and reasonable attorney's fees,
you may call: (856) 482-6900.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
mortgagee the back payment, late
To find out how much you must pay,
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to 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.)
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, .- y.olrr MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
~VEN IF THE SHERIFF'S SALE DOtS 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
800-990-910B
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ALL THAT CERTAIN LOT OR PIECE OF GROUND WITH IMPROVEMENTS THEREON ERECTED SITUATE
IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN, IRON PIN AT OR NEAR THE CENTER OF THE PUBLIC ROAD LEADING FROM THE
HIGHWAY BETWEEN CARLISLE AND HARRISBURG AND KNOWN AS ROUTE NO. 11 TO STERRETT'S
GAP; THENCE BY LAND NOW OR FORMERLY OF JOHN GROSZ, SOUTH 73 DEGREES WEST 127.5 FEET
TO A POINT; THENCE BY LAND NOW OR FORMERLY OF PAUL O. SUNDAY SOUTH 37 DEGREES 40
MINUTES EAST 119.5 FEET TO A POINT; THENCE BY LANDS NOW OR FORMERLY OF WILBUR WHITE
NORTH 57 DEGREES EAST 119.5 FEET TO A POINT AT OR NEAR THE CENTER OF THE AFORESAID
PUBLIC ROAD; THENCE BY THE CENTER OF SAID PUBLIC ROAD NORTH 37 DEGREES WEST 82.5
FEET TO AN IRON PIN, THE PLACE OF BEGINNING.
TITLE TO SAID PREMISES IS VESTED IN KEITH E. MILLER, BY DEED FROM
BETTY H. MILLER, DATED 8/5/96, RECORDED 8/12/96, IN DEED BOOK 143,
PAGE 1188.
BEING KNOWN AS 40 NORTH MIDDLESEX ROAD, MIDDLESEX TWP., PA 17013
PROPERTY ID NO.: 21-17-2696-013
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WRIT OF EXECUTJ"ON and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 01-6461 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NA AS
TRUSTEE, Plaintiff(s)
From KEITH E. MILLER, C/O ABF FREIGHT SYSTEM, INC., 2001 HARRISBURG PIKE,
CARLISLE, P A 17013 AND P.O.BOX 591, BOILING SPRINGS, P A 17007-0591
(1) You are directed 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 the possessiou
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee aud is enjoined as above stated.
Amount Due $68,889.94 L.L. $.50
Interest FROM MAY 4, 2002 TO DATE OF SALE SEPTEMBER 4,2002 - PER DIEM @$17.66-
$2,189.84
Atty Paid
$133.25
Due Prothy $1.00
Other Costs
Atty's Conun %
Plaintiff Paid
Date: MAY 14, 2002
CURTIS R. LONG
Prothonotary, Civil Division
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REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: MARK J. UDREN & ASSOCIATES
1040 N. KINGS mGHW AY, SillTE 500
CHERRY IDLLS, NJ 08034
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ill No. 08034
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Real Estate Sale # 62
On June 17,2002 the sherifflevied upon the
defendant's interest in the real property situated in
Middlesex Township, Cumberland County,
PA known and numbered as 40 North Middlesex Rd.,
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: June 17,2002
By:JOdL{J~
Real Estate Deputy
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THE PATRIOT NEWS
SUNDAY PATRIOT NEWS
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THE
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Frank J. Epler being d~ly 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 Market 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 Market Street, in the
City, County and State aforesaid; th~t The Patriot.News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, re~pectively, and all have been continuously published ever since;
That the printed notice or pu!:>lication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ M~tro editions which appeared on the 23rd and 30th day(s) of July and the 6th
day(s) of August 2002. That neither, he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the all~gations 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 beMIf of The Patriot-N~ws Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
,
adopted severally by the stockholderS and board of directors of the said Company and subsequently duly recorded in
,
the office for the Recording of Deeds! in and for said County of Dauphin in Miscellaneous Book "M",
V;I~:L11~:~~~~7. ~....~..........,...............,....:........,..,........
COpy . e . 14th day Aug 002 A.D.
Notarial Seal
S ALE #62 Teny L, Russell, Nota"! Public
City Of Harrisburg, Dauphin County
My Commission Expires June 6, 2006 NO ARY PUBLIC
Member, Pennsylvania Association OfNolaries My commission expires June 6, 2006
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 $
192.00
1.75
193,75
, Advl!lrtislng Cost
., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
e receipt of the aforesaid notice and publication costs and certifies that the same have
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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,Esquire, Editor of the Cumberland Law Joumal, of the County
and State aforesaid, being duly sworn, accorcling to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 26, AUGUST 2, 9, 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.
:lM~:;:;
SWORN TO AND SUBSCRlBED before me this
9 day of AUGUST. 2002
NOTARIAL .........
LOISE. SNYDER.,= r_
Cat1lsI8 Boro. CIltl CounIY, '
My ClANtd81110n Expil88' Man:ll5. 2006
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REAL ESTATE SALE NO. 62
.
Writ No, 2001-6461 Civil
Wells Fargo Bank Minnesota, NA
as Trustee
vs,
Keith E. Miller
Atty.: Mark J. Udren
ALL THAT CERTAIN lot or piece
of ground with improvements
thereon erected situate in Middlesex
Township, Cumberland County,
Pennsylvania more particularly
bOtUlded and described as follows:
BEGINNING at an iron pin at or
near the center of the public road
leading from the highway between
Carlisle and Harrisburg and known
as Route No. 11 to Sten-ett's Gap;
thence by land now or formerly of
John Grosz, South 73 degrees West
127,5 feet to a point: thence by land
now or formerly of Paul O. Sunday
South 37 degrees 40 minutes East
119.5 feet to a point; thence by
lands now or formerly of Wilbur
White North 57 degrees East 119.5
feet to a point at or near the center
of the aforesaid public road; thence
by the center of said public road
North 37 degrees West 82,5 feet to
an iron pin, the place of beginning.
TITLE TO SAID PREMISES IS
VESTED IN Keith E. Miller, by Deed
from Betty H, Miller, dated 8/5/96,
recorded 8/12/96, in Deed Book
143, Page 1188.
BEING known as 40 North Mid-
dlesex Road, Middlesex 1\vp., PA
17013.
PROPER1Y ID NO.: 21-17-2696_
013,
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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
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank Minnesota, NA
as Trustee c/o Moss, Codilis,
Stawiarski, Morris, Schneider,
& Prior, LLP
COURT OF COMMON PLEAS
CIVIL DIVISION
County
Plaintiff
NO. 01-6461 Civil Term
v.
Keith E. Miller
Defendant
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT
WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment
of your costs only.
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
DATED: Julv 10, 2006
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