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Home My WebLink About01-06506 M_ " ~, - .. ~"J ,., ~ - Illi"~ -:....-'--~r, ;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, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Carter Harrison ~ 313 Lamp Post Lane : NO. 01- t.SOb Cl'u'tl I~ Camp Hill, PA 17011 Defendant(s} COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA17013-3387 717-249-3166 or 800-990-9108 / I'll ~ ~ --",..~~"-~~"",,~ ".- '~~ >.L '~ -'- ' ~"t;i, AYJSO 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 defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin 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 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEP'ONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 / .. ~~~-~~~~ " .. ~ ," ^ 1_- . ,""","" ~*'o>:..~~ NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 / ." >"~' ,~~~, ~ ~- .' ~ ~"~ . - ~ - ~I ) ,"~" Jl1i~~~X 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignee: Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Recording Date: 12/11/00 Book: 662 Page: 165 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: 313 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Hampden COUNTY: Cumberland DATE EXECUTED: 5/21/99 DATE RECORDED: OS/26/99 BOOK: 1544 PAGE: 886 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon / :-;>i .' ~. "iilii' ~' ."-~ .~ -,-.~~" I' .~ _I - ~ ~'" ," - ',-,- ill ~ ,"[ ~~_3JJ!Jh~'i-" breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 10/24/01 Principal of debt due and unpaid Interest at 10.99%* from 6/01/01 to 10/24/01 (the per diem interest accruing on this debt is $26.66 and that sum should be added each day after 10/24/01) $88,527.54 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 3,882.77 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $.01 and that sum should be added on the first of each month after 10/24/01) 5,416.05 Late Charges (monthly late charge of $51.38 should be added on the fifteenth of each month after 10/24/01) 205.52 Total fees Recoverable balance Attorneys Fees (anticipated and actual to 5% of principal) 46.00 1,649.59 4,426.38 _lIlI..._""-._______ ~ -~, -' ~ 1---' ,- ~ ~~ J , _r_ ^"r" '>MJt:MMi"w-Wl.};<1 TOTAL $104,683.85 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(sl have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $104,683.85 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 / ~-~ -- " "' _.."",~~"W,"M,;,' -_ ALL THAT CERTAIN PIECE OR PARCEL OF LAND, WITH IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP OF HAMPDEN, COUN'l'Y OF COMlIERLAND, STATE OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE AT THE DIVIDING LINE BETWEEN LOT NOS. 9 AND la, BLOCK "H" OF THE HEREINAFTER MENTIONED PLAN, WHICH POINT IS 627.23 FEE'!' IN A NOR'l'HWES'l'ERLY DIRECTION FROM THE SOUTHWESTERLY CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE OF THE PLAN; THENCE BY SAID DIVIDING LINE SOUTH 3S DEGREES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BtOCK "H" OF THE PLAN; THENCE ALONG LOTS NOS" 13 AND 12, NORTH S9 DEGREES, 30 MINUTES WEST 100.33 FEET TO THE DIVIDING LINE BETWEEN LOTS NO.S 10 AND 11, BLOCK "R" OF THE PLAN; THENCE BY ,SAID DIVIDING LINE NORTH 35 DEGREES, 10 MINUTES BAST 121.43 FEET TO A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE; THENCE BY SAKE SOUTH 54 DEGREES, 50 MINUTES EAST 100 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NO.9 AND 10, BLOCK "H" OF THE PLAN, 'l'HE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK "K", PLAN 4 OF PINE BROOK AS RECORDED IN TO CUMBERLAND COUN'l'Y RECORDER'S OFFICE IN PLAN BOOK lS PAGE 41. . / I , .}' ~' "~, , ~--=''''''''M ';.. _ , -<~ ~~; "",""~" '~.~';-...au.:~~"~ ~...."~ ~- 'LOAN NO 1693340 ;.JT - (/$-I<I DATE 09/07/01 / September 07, 2001 Carter Harrison 313 Lamppost Lane Camp Hill, PA 17011- LETTER OP171 VER 014 J """"~'lW~-"'"' II ii .(jljl'"",~-k_~lia1llj:I.::!!~H,;'~"'"'"",,<,, REQ . DESCRIPT~ON DATE 10/24/01 NS3 Part 1 Pennsylvania NOI "'7dO/- /)3&0 - tJOlJJ- S"'/oJ- 99'oS' Homeowners Name: Carter Harrison Property Address: 313 Lamp Post Lane, Hampden PA 17011 Loan Account No.: 169334-0 PF : 1 SC F ,'" exhibit A ~ .....- I.~ - --'-'-'- ,"'~~~-,. & ;wJ-\li~_m:a-',,,->,,c'4'lP""'"~~_";'h,'d""" ! ' .' LOAN NO 1693340 DATE 09/07/01 LETTER VER OP171 014 REO DESCRIPTION DATE 10/24/01 NS3 Part 1 Pennsylvania NOI Or iginal Lender: OPTION ONE / Current Lender/Servicer: opiion One Mortgage Corporation \ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU ,MAY BE:ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YO~MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: PF: 1 SC F 2 SC B ," Mill" ~ ~ _._.~~-<~.. ~ II~;., '0....... ..... ,~,l ~ "~~_~............' I '"dIt~~~.- ,. 'I -iA'fln' M ~ - ~ - ~C-$~6,,,,':1';;~1-!',, ' 'LOAN NO 1693340 DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 09/07/01 OP171 014 NS3 Part 1 Pennsylvania NOI * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. Ouring'that time you must arrange and attend a "face.to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. ' THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO PF: 1 SC F 2 SC B ." ~'Il1a_ ,={~~~ ~ '~.- ~ ,~- ~"~-"-'T"" '~ .'- .I".L~~~,~ ~ '~~~,,-, ~ ^' ~,~IJ;"i.'-" -=-- ;j~ili~m~ ob~,""'jJi',._;,;t",~,,!,,. ,LOAN NO 1693340 OATE 09/07/01 LETTER VER REG DESCRIPTION DATE 10{24/01 OP171 014 NS3 Part 1 Pennsylvania NOI NOT APPLY FOR EMERGENCY MORTYAGE 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. "" .- OP 1 71 PF: 1 SC F 2 SC B ~ ,~ ., _.1 "I ~O~" ~!i!!llIIill 'J" ,.J...... ,"-" -. --~'~mY..; !i:~~.2,',.'J"U,'",>':'/I~" LOAN NO 1693340 DATE 09/07/01 LETTER OP171 VER' REQ 014 NS3 DESCRIPTION DATE 10/24/01 Par,t 1 pennsylvania NOI '/ / Re: Loan No. 169334-0 CONSUMER CREDIT COUNSEL IlliG AGENCIES - If you meet with one of the consumer credit counseling ag'encies listed at -t,he 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 PF: 1 SC F 2 SC B ;. ~ rr'~ . -~ -, :>:II """"'~~-~,- "~ - , ~~~-"""".",--~"~ , - I U.~",!t,""9 LOAN NO 1693340 DATE 09/07/01 LETTER OP171 VER 014 ,REQ NS3 DESCRIPTION DATE 10/24/01 Part 1 Pennsylvania NOI / your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the ,nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file. a completed Homeowner's Emergency, Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.' Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO '. PF: 1 SC F 2 SC B . M__~..._ " ~ ~ ~_.,-,.-"" ~....~. ;~.~_~ l~~~~~~,."".~'F""""" LOAN NO 1693340 DATE 09{07{01 LETTER VER REQ DESCRIPTION DATE 10{24{01 OP171 014 NS3 Part 1 Pennsylvania NOI OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FOREClOSURE MAY PROCEED AGAINST YOUR ~OME 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 not if ied directly by the Pennsylvania Housing Finance Agency of its" decision on your application. OP 1 71 PF: 2 SC B ,. .....,- -- ~ ..."""-'" "-Ib.ol ,,1._ ~ 'W"!1l:l!lf.BMtif7''''''~" "!(,"-~"'<0c-i^'_','J, / LOAN NO 1693340 DATE 09/07/01 LETTER OP172 VER 024 REO NS3 DESCRIPTION DATE 10/24/01 Part 2 Pennsylvania,NOI Re: Loan No. 169334-0 .********************************************************************* NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY,AND SHOULD NOT 'BE CONSIDERED AS_AN ATTEMPT TO COLLECT THE DEBT. ' .. '(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) ********************************************************************** .'. ~ ' HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). PF : 1 SC F ," iJr ~ "'~".~I:~- ".~ ~" .. " , ~,- = .~'-~ ~~ L ~~ '....~1"'~ "0,...(,\_,_-_.1.." LOAN NO 1693340 OATE LETTER VER REO DESCRIPTION DATE 10/24/01 09/07/01 OP172 024 NS3 Part 2 Pennsylvania NOI NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on / \ your property located at: 313 Lamp Post Lane, Hampden PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHL YMORTGAGE PAYMENTS for months and the following amounts are now past due: (a) Monthly payments: 1 MONTHS @ $ 856.42 2 MONTHS @ $856.4~ the following $ 2,569.26 (b) previous late charges; , $ 102.00 (c) Other charges; Escrow, Inspection, NSF checks $ 00 (d) Other provisions of the mortgage obligation, PF: 1 SC F 2 SC B ," - ~, -~ . ~ - - "~.~-~, '-1. .J N~_ liitiiiilf1"~"" -'~llil"~mj.M.,-,1i,',,~>,>~c~',,.,,-,:;- LOAN NO 1 6g334 0 DATE 09/07/01 LETTER VER OP172, 024 REQ DESCRIPTION DATE 10/24/01 NS3 Part 2 Pennsylvania NOI if any $ 00 / (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2,272.02 B. YOU HAVE FAILED TO TAKE THp FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAuLT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $2,272.02, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified :,,-,' " "i . check or money order made payable and send to: PF: 1 SC F 2 SC B ." ~6l! ,,<"~O -, _.,- -~~" '." -" ~.L<i"'--"'~~'~l7"'"'" '" .W~ ~ I~~~"~[ '"",-", ~ ~~!I:iiI;i"i'i-<'K~J,{ic';'M;'",-""" LOAN NO 1693340 DATE 09/07/01 LETTER VER OP172 024 REQ DESCRIPTION DATE 10/24/01 NS3 Part 2 Pennsylvania NOI Overnight Mail Address Western Union Quick Collect 3 Ada Irvine, Ca. 92618 Pay to: Option One Mortgage Corporation Code City: Option, Ca You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (DO not use if not (applicable.) , OP172 PF: 2 SC B ," ""......... .....- - . ....IJI'<'.' ,~. '-'--" ~~ ~"M-'L""'.... " _~ ~.i .J.,"'"""'lli:J "-"~-'-~'iliI,,*,"W-~,,"\q" LOAN NO 1693340 DATE 09/07/01 LETTER VER OP173 012 REG DESCRIPTION ,DATE 10/2~/01 NS3 Part 3 Pennsylvania NO! / Re: Loan No. 169334-0 IF YOU DO NOT C~RE THE DEFAULT - If you do not cure the default within THIRTY (30) Dp,.yS of the date 'of this Notic.e, the lender intends to exercise its rights to accelerate the mort~age debt. This means that the entire outstanding balance of this debt will be considered due immeqiately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your PF : 1 SC F ." ~,_. -~ ~' ~ ' ___",,_J. L ~ '" L~, "" ~, "--liIii!i:"""'';-'<'ilii!IlI&~h'_J,." LOAN NO 1693340 DATE 09/07/01 LETTER OP173 VER 012 REQ NS3 DESCRIPTION DATE 10/24/01 Part ~ Pennsylvania NOI 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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are_started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed '$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. PF: 1 SC F 2 SC B ," - ~--, ~~"'J._ ~~ ~. ~-_"",~g; ~ 'ii~"" "'-.;..~ t'1!1~' !l:iJ.l~'!r~~l,.'O-,'_:\:,--",\,,"" LOAN NO 1693340 DATE 09/07/01 LETTER OP173 VER REO 012. NS3 OESCRIPTION DATE 10/24/01 Part 3 Pennsylvania NOI / OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. ,You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the PF: 1 SC F 2 SC B ," iilli!l\al""'" 'I" L ,~ '" - i>Iillil:.A "I iilid' -"-""'-"1il!i~~BIIjf'~~"'-~~iJ.~;W;']Mi"'~-:;"_'^ LOAN NO 1693340 DATE OfJ/07/01 LETTER OP173 VER 012 REO NS3 DESCRIPTION DATE 10/24/01 Part 3 Pennsylvania NOI lender and by pe~forming any other Curing your default in the manner restore yo~r mortgage to the same defaulted. requirements under the mortgage. / , \ set forth in 'this notice will position as if you had never EARLIEST POSSIBLE SHERIFF'S SA~E DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notic~. A notice of ~he actual date o~ the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required 'payment or action will be by contacting the lender. OP173 PF: 2 SC B ," ..,,,,,,,,,, ,.~ LOAN NO 1693340 -, , .' ~",~ ~_"O DATE 09/07/01 LETTER VER OP174 020 Re: Loan No. 169334-0 HOW TO CONTACI THE LENDER: Name of Lender: Address: Attn: Address: Phone Number: Fax Number: PF : 1 SC F , 01 ,~ '~'''~~"' =-- " "" ..~ j~"-'1!I~ ~~ 'tJ -",,""''''-'=~~~ / -- .....&,~~)I;,h"~:O,,,;-'" REO DESCRIPTION DATE 10/24/01 NS3 Part 4 Pennsylvania NOI / Option One Mortgage Corporation 7515 Irvine Center Drive Kerry Delahunty Irvine, CA. 92618 800-326-1500, Ext. 8001 949-784-6033 ," ~ ~... . " ~,~"~ - , ~ O"~"~..................__ ,....~" .1. -,~ ..""-~ ~~-"~' 'M' h;.'li.o-.'_~;",,,,;_,,,w""~ . LOAN NO 1693340 DATE 09/07/01 LETTER VER OP174 020 REO DESCRIPTION ~ DATE ,10/24/01 NS3 Part 4 Pennsylvania NOI Contact Person: Office hours: \ / NONA SPENCER EXT 8001 Monday through Thursday 7:00 a.m. to 9:00 p.m. PST Friday 7:00 a.m. to 6:00 p.m. PST. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor x may not (CHECK ONE) sell or transfer your home to a,buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneY's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: PF: 1 SC F 2 SC B ~ - - ~ ~ - ...~...~ ~, , ~ -.~~~ J......-. J -"""'l-- ~~-'-"-{~ltiOl~~~4li""i~,",,-,,/ , . LOAN NO 1693340 DATE LETTER VER 09/07/01 OP174 O~O REO DESCRIPTION DATE 10/24/01 NS3 Part 4 Pennsylvania NOI / \ * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORtGAGE DEBT OR TO'BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT, CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OQCURRED, IF YOU 'CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE 'THAT THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH PF: 1 SC F 2 SC B ," <"-",,""""""'''''''-'' ''''''''"",'''''~~ .' ~'---.""..."'~<, ""'/Ol~~...............~" _~~ ~=.' I" l ~ .~~ _~J~~_. j_,~_" ""'-ilLl1~~h.;,.e:'-'-''',_^",., LOAN NO 1693340 DATE 09/07/Q1 ~ETTER VER REQ DESCRIPTION DATE 10/24/01 OP174 020 NS3 Part 4 Pennsylvania NOI ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 '" PF: 2 SC B ," ~ "'~- ~.~- ., ~,-~-~~~-_..~. ' 1-.", 11lflil1J:K - .'.w..",-j,;",f~"'" "'w~^~~, . ~ E R I FIe A T I ~ 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. Udr n, ESQUIRE MARK J. UDREN & ASSOCIATES / ~',::'L"::o-@ldi~~1iJ)(~li<~'H:'i:-ifuj\:;jW.j,~:t~'i,l;'O_>!""<;li'{,i'ljf~lli{",ii,,},j];bJ';"k,~H!.1,;jj,-'ji"'''~__?;~1t,W>il~~'~~.!J'M~iiiOi~~~~~ii; '.It~Mf'~-"~- 'l~----"" p ('! I.:J ~ -&0. ~[c,.~ ..l:: tea ~ ~ ~ c ~ 'S'\) (90 ~ ~ Y.J 'vJf- ~ ~ CA t ~-1 e,..; (') c 2m 2"~ (5)> ;:$ ~~ <,..J ~C) >0 c ~ rP~i . o o .., '";:e"" t3 OJ.'::: ,:,;l It , ~,:-I :,-~l -.-,. --. (S,t -'--{\..) 7:':+~ ~dc) ('-=-~m .':::j 2- 2:? 8 0'. '-"" """'-' ~. ;'0 (n ""<.-.""""""'~"". . ~~ I-"L .......,," J~ ~mfllll~....-.L..." ._r. , "~"~-. ll~'~ - L!MIi~"",j(;,C"~.",d"-" SHERIFF'S RETURN - REGULAR CASE NO: 2001-06506 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER CPL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HARRISON CARTER the DEFENDANT , at 2103:00 HOURS, on the 19th day of November, 2001 at 313 LAMP POST LANE CAMP HILL, PA 17011 by handing to JOETTA MURIS LEGAL ADULT RESIDENT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.80 .00 10.00 .00 35.80 r~r#4[~ R. Thomas Kline 1l/20/200l MARK UDREN & ASSOC Sworn and Subscribed to before By: ;2. t>.o me this .2'1...... day of ~ obvl A.D. Q~. Q >ru;~,~ rothonotary . '~~D"~ . I MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.V. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ08034 856-482~6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff v. Carter Harrison Defendant(s) ',- , - ';iiit~~~ -- . "\1\tilI,y,!"",',>!,,-,,"'i-',.;,"' ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County - . NO. Ol-6506 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: December 29, 200l MARK BY: '" J. UDREN & ASSOCIATES ry Mark J. Ud en, Esquire Attorney fo Plaintiff r_"~~ ~. ,~ ~ ~ ~,- ~,,~'""~"', "0' ~ ~ "- ..-:4 -'~, ,o_~ L~~rl':Il.I ----~:~~"__..,.,,,:,t,._.~". .. . I V F. R 1FT CAT TON 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 l8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1/-30--fJ( ~4; N'arrle : - FARAH TORRES Title: FORECLOSURE SM:CI^UST Company: ".., ~;~,::;,-":;,,,:.rli:ll~~Jli:!li~i!1'~'*jf1~M1""&"'i;",';i.,~t-'L"-~&>A,""'Y:;<-o~"",:..:.\;;;:'&~',-il;",C;;1,.:.,l""-W-"€"",~'U[,,,,fi[i_-Miiw'I>~"!@'f'~,;&,,~ll;,(i1J&Jm~'~~ili1ii,;.M' ~'''''~:IW''liI--r~'''Ic.'~' - IUlIf) '1' ~, ". " Jill_I, ~ . \ (") 0 Cl C N <:' " -Om C- i~~i!;! mlTl l,.-", z~, z ze I -,',",l'l- (J)J> N ',,' ~ -<' ""7 ~f5 (--j .,L 1> ;e.. '~:~: 2:0 ::.:: ,--:; :!] 5>0 C:;-:;.C) \.0 ;:-O--=::;fn C ~ ~ :n "" -~ -< 01 ::rJ -< .,;, - ~~o.~. ,~_ '''''''"it'.' ,"'~~""~..-'~"~~" - ,- ,-0-0"'" ~<o,~ ..~,,,~~,.,o - ... MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 l040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 Plaintiff v. Carter Harrison 313 Lamp post Lane Hampden Twp Camp Hill, PA l70ll Defendant(s) ,- " "~ -~.......... Tlilif-lIl.:lld:;;"~"<l""'__o -" >- ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. Ol-6S06 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (5) 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 lO/2S/0l to 12/29/0l Late charges per Complaint From lO/2S/0l to 12/29/01 Escrow payment per Complaint From lO/2S/0l to 12/29/0l TOTAL $l04,683.8S l,7S9.S6 l02.76 02 filQfL. 546 .19 I hereby certify that (l) the Defendant are as shown above, and (2) accordance with Rule 237.l, a copy of w addresses of the Plaintiff and that notice has been given in ich is attached hereto. & ASSOCIATES M rk J. Udre QUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY ~ ~".~...... ...." . , I ~..J..,~~ ".,I........ '~ ~ J~' ,M."~",'''''''k,_' 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 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF i COURT OF COMMON PLEAS ; CIVIL DIVISION Cumberland County v. Carter Harrison Defendant(s) ~NO. Ol-6506 civil Term \, ", DATED: 'TO: December l8, 200l Carter Harrison ' 313 Lamp Post Lane Camp Hill, PA l70ll 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 170l3-3387 7l7-249-3l66 or 800-990-9l08 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 TIENEDINERO 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 17013-3387 7l7-249-3l66 or 800-990-9l08 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 DI!:BT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,~':;';,~b~',,c,,""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 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA 170ll Defendant(s) 1-- '............."'--,"'-;~ -~~"""~- OO!i1i~ ~'ll'll!l~~f}klf.;";-,,";"''---;' ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. Ol-6505 civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF 6t&ff()l-~ COUNTY OF CJ/Z-.AtLJrrC SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and las,t known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Carter Harrison Over 18 As captioned above Unknown -~~ Na ."' ~F ~ES Title: FORECLOSURE SPEClALlSl' Company: Defendant: Age: Residence: Employment: Over 18 As captioned Unknown Sworn to and subscribed before me this 3() d of lJiVi,t~ , 20~ KATHERINE J. MILCHAK COMM. # 1205572 1: .. . NOTARY PUBLIC.CALlFORNlAGl or: ORANGE COUNTY 0 I "_" CO"''II, e,o, DEe, 20 2002" r................."V'_'V...,-~"":............'" "'i ,,., >- g; '-, r-- ~j~~ -'.... ~:Sf3 i C~ L~"I Cl:~ C) . ,~,_: !"II~, '''' __ v;) If:; ~ :z: :;;>$ z.J7 ():<r Cl::1 :~::~ :)2 '-2 :,.LjW Q~O- ~::- '5 cJ en ~ "'- " .~ r~,J I Z .:x , (,"..J C) }.(~--""'F'l'" ,<<",. ii_ (3i~ ..j 3 ]) ~() OFr:tVE OF THE SHERIFF ClJMBfill M' J COUNTY J'N Z 1119 ~11 '02 (; A i ~ _;..) '.. i'~ PEN N Si'LV Mv IA "d J~ ;)' J[j C)I E & d ~ t~ ,.' ,~_,.t ",-j~)'~*Wl~fjJlffiii!l<l~W;\ljf1~%%!%',\'I[!!,1'~~N');;j"O!f;>'OK';~f L, ~f'>!~~~- ~,_,) _lmrr\1 . ~:"-~"~" ,. "",",,',,"" ,-, 'C'""",, """'''\,'f',,\~,i!,- ' ,-! 'iL.ristiH';J~,~.,,,,,,,,,l.o_;..."""''''''''~;;,~~~\,;,,"~,-,,_.",,,,"","~",,,,,,,.,.,'''-'''"''w..--';'~""",''''"'''''''~'" -:_ ~ i51~ ~~~~..,....J - 'I.~,""",,,,,,,:,,, ~~'.~~~'""_"~~__I'" ''-';~",,",'>~ ~ --IM!!!ilI-=' ~'fft"m,,,-,,~,,,,,,,, MARK W. UDREN & ASSOCIATES B1: Mark J. Udren, Esquire ATTY I.D. NO. 04302 l040N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l7011 Defendant(s) . . NO. Ol-6506 Civil Term TO: Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70l1 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you' in the above proceeding as indicated below. -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 8'>6-482-6900 "'" -::&,,,If(!,",;~,=,,,,-, L"""~,~,_"i',:JuJ>i.j~~~;;MM~0<4a,'>W"""'--"-',""","",,"'u,,,,, _= "~. ~,,_ _' ~...__~ ;,,,,-~_~,,...",~"_,~ - L " . 0 ~"~""""-'"-" ~~l- - ", -~~:t>j',~i_""ii)!"-,~, ,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, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 Plaintiff - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l7011 Defendant(s) - -NO. Ol-6506 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff I 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 Prom lO/2S/0l to 12/29/01 Late charges per Complaint From lO/2S/0l to l2/29/0l Escrow payment per Complaint From lO/2S/0l to l2/29/0l TOTAL $l04,683.8S l,7S9.S6 102.76 .02 ,S106.S46.19 I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, a copy of addresses of the Plaintiff and that notice has been given in ich is attached hereto. & ASSOCIATES M rk J. Udre SQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY ~ ""-",, <-,,, NO'" ~,,,,,_ ",..,<",..t""'"."""",,,,"" ~~ "~lu liT OffiCE OF THE SHERIFf Cljt"H~j:Yt ,\t~n C:')UNTY JAM Z 1119 All '02 G",II',. ,,:,_i::. PEN N S 'iL Y ;\r~ IA 'M ,,...-1- U1!!I "0,_,=", ,"' __ ,_.,=,,,,,,I"f!l'lM!i!lWliIIII, _')"ill,:",~~a'iil"jll!!,!W~",~'~I!-~~~NW~~'PH"""l:,"'i",~T'~~"~fI"l'll.-"-:]"MV\!-'!il~"'f'w"r"'''_~m1~~!~~~"", _. '"I"' ._~.~o .~'-_~_~~' ,. .I '~ J',IH~::Uil\~Ifr-._i';;.\i\:,";<'-'-' ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire AtTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70ll Defendant (s) , . - NO. Ol-6506 Civil Term PRAECIPE FOR WRIT OF EXECUTION ':t'O THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $l06.546.19 Interest From December 30. 2001 to Date of Sale June 5. 2002 Per diem @$26.66 4,212.28 (Costs to be added) $ Ma k J. Udren, SQUIRE ATTORNEY FOR PLA TIFF " .-,,, ,-~. < ~- . ~'"' '^'<""- .;;. ~- ~,,~~ '-~'""''"''~'''''''d''~~",''''~'''~";;&'"~_~-".;'__ ,~."""",,,'p,',~,.,",---' "',",,'- -~ ......,.. .- . """"""""m"__"""e,' o~~~~,o,~ .nl,~ t~~:W JfiH Z 1119 AM '02 c ,~, 1 L i .:- :.-L'_l PENN~)YLVI\NIA ~'-/i: , '-- '-- ~A "- "- , >- '.0 ?: ~ l0 Z ~ "- ~ :::J<( , , , u.JO G"\ 0- ~~ , , 0 ~ -J '7 c-z --- (.)<:'5 .... '-'~ - J U_",'" ;;;:c ~...... ~ III Qt; ~~~ I I C'''(f) \ <J $E: N "~;z I I 0 lI:, I ~z ~ ~ B 8 \) 0 & " -J.JUJ -- L:... ~' CiJo... '-1 !\. 0 -''') ::z l.L C'~ :::J L; ~ ~' () 1;"- ~ 'bf ~ 0 0 0 ~ ~cr ~ ~ 0 1<7- - 11IIlllI~ ~, .. ".._.~~-'$U~~ffljl!~~Nm;i\>f;Ji~l'f'"' "y";->,"t<-",.~",,-,,,,;, "-'FF"J~~""W-Y'"k~~1"f~i!1!i~;:eMI;'~~<J1"~~~ -/,,~,}_,. - ~ ',-.&;"",,_ -"I _ 110<>"",,,, .~"-. ~,,~....,~ - I ~ ~"" ='-=~~.~ ,,~. -~ ~n_~"* " ~ ~'-,' ~" ""'iI-1li- .~" "-~,_%.<M"'~":"'''_~'.'' c__ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70ll . . NO. Ol-6506 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 9l because it is: An FHA insured mortgage Non-owner occupied Vacant x Act 9l procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of l8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ( >- \D C 0:: In ;:; :z LUQ e. :::><:( 0- ".....L.- U~ ~:;~~' ::l: '..1-,...'- """ 0>- C~ [---'----- Z~ ~J('--" fad: N ' 'W I 5:z: EE~~; z G:ifi UJ ....: .:no.. -, ~ U. N :::> 0 0 u "ilBI1 DllMlI!if~iIlJ'ffi1llll1 _H,~ .~ '" ,-.-., ,,-'~ _~__.k""""'~" T'_ 'W__ ---: llrl'~CE Oil' l~E %1!1I~f/l,n eu!'s';,'W) ~!Jo\l1l1:l'f JIH Z 1119 AM '02 &tilI~'W~Ji.".,..,....",,_~,-"'IFl'~,<m;llil>!f"l'q!)iW!~)l:$.~Wfif~~~i!!'H$ii?"""P":'''_i"-)':''!-'"-'-,:-,'''-''' --"":"'T""~"Ci'l"iiWle::!@j1'l';;0''!Oi'i!'''i~1Jl!<!J~~Ilff1!l!!ry,~~~: V,..:; r\ i_ [;.) .._1_ PENNSYLVANIA """''''''"",,'''''''' "'~ . ~".~,.~ - " L, ~ .. ;,I"" '''.... "'-=' . J:li:ii''-'- !hi,'~0~,,-!.i'"'~, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 l040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-703B . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70l1 - . NO. Ol-6506 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3l29.1 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the writ of Execution was filed the following information concerning the real property located at: 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l7011 l. Name and address of Owner(s) or reputed Owner(s) : Name Address Carter Harrison 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l70ll 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 '<l~^'.""'~',"",_'~d O~ ~..=-.,~ , ~~~ - ~, ~' I' .i ,~ .' ~l,... ."'~'"'"".~~ '~.. i#'4f\'I"""~"!h-~"-' ,,- '4: Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse sq., carlisle, PA l70l3 Domestic Relations Section 13 N. Hanover St., Carlisle, PA l70l3 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA l7l28-0946 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 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l70ll 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 l8 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: December 29, 200l Uf M rk J. Udr ,ESQ. Attorney for plaintiff ~~ . ,~ ~ ~-~< '~~'r' OFFWI<OI' THE SHERIFF CIJMIH :"',Wi~ ~111HTY JIH Z 1119 ~M 'az iJA,-; :_l ~:} l_ j" PENr~SYLVANIA >- \.D ~ c'- tJ) ~ en ::J<( ~~ 82 ;::: .<( 'I _:_, <a: o?; c,) ~:; "7>- f~8~ N ~i" Cf) ::Jz rrz __J. ~. tDLiJ u: "", ...::;; roo- -, :z u". N ::> 0 0 () "'iIl1 r, "~ ,~_ ". ,~~ iL~~ili'ImmJJeilll'!l:!!~nl1n~~~~~m~l!lm~~1d'~f;r;;?-t""""':--~'::'-"i"7-"""?~'~M,mf:'&';-.,!,"M,!~r;IWl~~~'ffl!!!l!l: 7"'1"~N'''''I!!fl!!'jI,''',~r'','",c,,,io/ '~-''"'''''''''''~'''''"'~~~'. """'.........'~""..,.,,~'___v - ~,~ ~~- J_llilli""""' - 1 -~~. ~'-'ril"~'""'" ~Z-,o."",,,,_,,-,;,,,, ~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70ll . NO. Ol-6506 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA 17011 Your house (real estate) at 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at lO:OO A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $l06,546.l9, 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,F, TO PREVRNT 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'l s fees. you may call: (8~6l 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.) g: ,"""""""-_~l<>o"",,., "~" - -"~ -~- ~ -'" ~ ~-'.. .1"":",, ~-~~ '~~, > ~ *'-- "~''iJr~;;:''1&d)'''-''''<' .. 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 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ?i: r-- '>- L(:, I::; ">: ""'- \;:c; 6; :;:)<( UJSo-; O~ CO?' :JC 0, o:~:: ~ >. o~~::, Q,:;J ('~ :5~ ~;~-;.:, I cr:z ~ ~.ijW G::i= ....,." ~ rDo.... >-- -; 2 LL_ N :~ 0 0 0 ~ 'mi. ~, ",,,,,",1Ii!l! ~~ <~~, -~~ ~'H ""~ __"~" - .,,- ~~~,~""..."",,~ "'",,", ""~~ -~., ""= ~-~- OFFIGE Of THE SHERIFF CUf/!F: "\!' i':o;vNTY JaH Z 1119 nH '02 c.: " I ,~::- Li:. PDU,iSfLVANiA _",_..,,~~'R1IiP'''',~,~~I'!'1!ii~'l!!OO,*PWF,ffi~W~~~!!t<$'~7~~~~1':'','C''''0"''~~\'-;',~T;,'- -'-'-'-_""";'W';0PJi',",'''!'!:W''1:!!,'<i,1~~r'''<~,~!1jl.~'!il''i~~TI'I ,"~, . ,_~.'4rl~ ~~ ~~~ < . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY. SUITE 500 CHERRY HILL. NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for BASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70ll Defendant(s) ~,' .1,' , _ , "~~" < ~J;;..,,,. " _"'_, ~ "-_, " J...- "i:.' '"" - j:--!:t'_itN . ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. Ol-6506 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: l. 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. 3l29. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authori ies. Dated: May l, 2002 UDREN & ASSOCIATES BY: Mark J. Attorney )'i -'. c. ~....L'<l .--"",- >""'"" '"--""I~'!<$,"C- MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County . NO. 01-6506 Civil Term v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70l1 Defendant(s) DATE: January 4, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): CARTER HARRISON PROPERTY: 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l7011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 5. 2002, at lO:OO A.M., at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE,CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within lO days after the filing of the schedule. EXHIBIT A %!i ~; "U en ." o ~_____3 ,,1 ." 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"2.3 CD -m ~a o :i':::;; -10 -. ~ " =.~~ '" _ro !logo. ?" ~ "en .. .;r ;0 SI~ H ;.~ " . ro . . .-.'" ,;:[rYJi.~jn ' J~.,...,^,,,,^, ~-$Ii!:1i':iJ..\'tk.l',j~~.1,K~"';".";i;-'"",,,~<,,"(' ..,'~, ',\J,:,,,,,~',,, ",j,llIUj{ , .. ~ "~"', __"''''H,+,__,,,~;\.->,,m,m-;1,,,-\i)\i~lIJ~~~'';.li"I$;i€;'I'iij,wffijj;~iWk.~~i1ii!.l1il!:'i.tf't:J.~11l~1 ~.~= """1'_",~.,"[b!,...-. '.' ".",. ^,CA"",J*"?t_"," i<,,)i",'~,-.f3.,"_"" _i"___""r. _ _ _ .-.~.,"""""" ,.. , ~ -. """"-'~llIli'llI8!liild~ ~. '""' . 0 Cl 0 (-- 1'.) -0 ~ ::1: ..~l -00-' :r.:'" '?Fl~ rl1r"n , -, Z'.[l --..,fi1 ~S: "0 w ;,3 \ ~-!f'..J sec.) -0 ~-,- "fl (-"') ']J J>c ~ ~C) zj brTl --,( ) r.:? -;P"' -, C -r~; -7 '" ~ .l'" ~ ~ BM _= -0 ",~;'J1;i;f;(};w -",,,,--- ~ .~ ~ - -1', ~ , I. J 1 - ~~" ,~, .;, .,0 -,' -.- 111lFit*':1 t . Wells Fargo Bank Minnesota, N.A. Flk/a Norwest Bank Minnesota, N.A. as Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS Carter Harrison In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6506 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 J. Udren. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30.00 20.00 15.00 .50 1.00 25.20 17.94 15.00 15.00 2.78 432.22 316.55 251.35 $1142.54paid by attorney 6/06/02 Sworn and subscribed to before me So..~s7: ~VA', (J ..."........~r'.-~ ~ This //"'::.. dayof~~ r ., - G ,R. Thomas Kline, Sheriff 2002, A.D. _!'P" (J n.,d/.f...., ,D,,'Z J rI" r - 11 / ;77 BY' ()~ dMCtYI Prothonotary Real Estate Deputy '" j,i,-'tJ ek. _3(, 3 70 t2u-./.2f,/f5 111 ",;,~~~"",","",.",-,'",,",w."""'''''''''''''''''Il,jt,I,j.~_''''''''"'" .=..-.. ~-~--. ,....~~,.~,,"...J"""~"~>,,~~.-~, "I .... 11"'"- -""""', "",,,,I"""IiIi' ~o, ,~"- "-="'~~"' ',~itI~~Mj;-*;'1.<'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 Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 - : COURT OF COMMON. PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70l1 . . NO. Ol-6506 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3l29.l Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4, Plaintiff in the above action,by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 313 LampPost Lane, Hampden Twp, Camp Hill, PA l70l1 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Carter Harrison 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l70ll 2. Name and address ,of Defendant(s) in the judgment: Name Address Same as #l above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None "'--',' ~ - - --,-~.~, ",,,,,.,,",,",,,,~~-,,,,,,,--,,,"~"~,,,,~~;,,;;::,.",",..~, ".<>~,...,,~,~ ~,- ~ I "~" "1' ' __'" =--~ <~-"""a~~I~..."J"", -~ \li1__~~!lJjJJi<!O~k;j1dMP" ~mWJ:I!I!~~jOj;~L"k-;:"'~""""""'-l-""_":0:., . , 4. Name and address of the la~t recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA l7013 Domestic Relations Section l3 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA l7128-0946 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 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA l70ll 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 29, 200l ESQ. Plaintiff ~., --, ,;' ~-- : l!l! ~.~"'~c.~"'"O""~_"~';"all''--''~~'''''''''''"",,,",,,lA~~~,ilr'''' l4:;ilIIilUlIlI~ "l._~i ",L._~....."__..",~,_...,w.~___J,""",",~",,,,~~_ 'lii,1I b!I'~-'''-''~'' ~,~:fu~]"'k' . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY IoD.NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, ,PA 17011 . . NO. 01-6506 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA l70l1 Your house (real estate) at 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA 170ll 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 $106,546.19, 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 ABI,J< TO PREVENT THIS SHERIFF'S SALE '-..--. To prevent this Sheriff1s Sale, you must take immQdia~Q a~tiort~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (B56\ 4B2~690Q mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ ~_~""~,.,"-'"="""_"""'~,,~"'.~""~' r-' ....-"~~'~ '""'~^ ~ ~",,~~i,~.. 1~oiI!~_JJr~/Il~~~libollll1J:1i!k.;.ItJiJ11~I"l.J",iiilJvjJli"A " YOU MAY STI~~ 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 C1oNNOT 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 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 "",~",,,,,,,...,,,,,,_,,,,_,,,,",:lli1,,--_.~_,,,"",,,,,llJ ~-~.'''''~5'''~"'~- .~ . ~ ~_.~ ----.,,_d ~"_, ~ '-~'""'"'tjoWi',,,,,,,,,~.,.~ "'~'" ir' ""'i"ci.,-""""",~';l<$"-""'-"""",,,'_""~"""'~'""""-li>l.-","''-''~'''"'' ,,," ALL THAT CERTAIN PIECE OR PARCEL OF LAND, WITH IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: ' BEGINNING AT A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST,LANE AT THE DIVIDING LINE BETWEEN LOT NOS. 9 AND 10, BLOCK "H" OF THE HEREINAFTER MENTIONED PLAN, WHICH POINT IS 627.23 FEET IN A NORTHWESTERLY DIRECTION FROM THE SOUTHWESTERLY CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE OF THE PLAN, THENCE BY SAID DIVIDING LINE SOUTH 35 DEGREES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BLOCK "H" OF THE PLAN, THENCE ALONG LOTS NOS. 13 AND 12, NORTH 59 DEGREES, 30 MINUTES WEST 100.33 FEET TO THE DIVIDING LINE BETWEEN LOTS NO.S 10 AND 11, BLOCK "H" OF THE PLAN, THENCE BY SAID DIVIDING LINE NORTH 35 DEGREES, 10 MINUTES EAST 121.43 FEET TO A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE, THENCE BY SAME SOUTH 54 DEGREES, 50 MINUTES EAST 100 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NO. 9 AND 10, BLOCK "H" OF TItE PLAN, THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK "It", PLAN 4 OF PINE BROOK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 15 PAGE 41. BEING KNOWN AS 313 LAMP POST LANE, HAMPDEN TWP., CAMP HILL, PA 17011 PROPERTY ID NO.: lO-20-l848-108 TITLE TO SAID PREMISES IS VESTED IN CARTER HARRISON, SINGLE MAN, BY DEED FROM CARTER HARRISON AND GUO HARRISON, HUSBAND AND WIFE, DATED 4/19/99, RECORDED 5/26/99, IN DEED BOOK 200, PAGE 2l1. - / ~w ~ -, "-........- ~- ~ ...... ..."L. ~ ~, ;~,~'-' ,'~'"~~-"' ..~<r;';:' ,',", :iill!i1JJf,;i' WRIT OF EXEC(mbN.'andlor ATTACHMENT COMMONWEAlTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF -.9:Jmberland NO, 01-6506 CIVIL 1~ TERM CIVIL ACTION - LAW COUNTY: To satisfy the deb!, interest and costs due Wells Farqo Bank Minnesota, National Association, F /K/ A Norwest Bank Minnesota, Nal:iooaT Assoclan,on, as 'l'rus"Cee for ::'ffi:>CO Mu... L;ja;jt' TOolll 'l'Rist. 19qq-Rr4 PLAINTIFF(S) from ["'''..-rpr_H''rri""n, 11:\ Lamp Po!'lt Lan~li<m1pden Two, Camp Hill. PA 17011 DEFENDANT(S) See Legal Description (1) You are directed 10 levy upon the property of the defendant(s) and to sell (2) You a'. ,1M ""M'^" '^ oH""h lh.. oroaerlv e( 100 dekm(\"AtI<:\ "". levied upon in the possession of GARNISHEE(S) as follows: aJ1d,\~OO, t>>y the ga~!t1l1l1~Ll\..at{l!La.n~1I.,9\JIpjlnl has beermued; (b) the gamishee(s) is/are enjoined frompaying any de!;llloor for the acUiHlFotIifii!J8~ant(S)'fl'r\& from delivenng'any orooel1Y of \heJlefendRnll,::\ nr otherwise disposing thereof: ' . , ,., ;, " . . , ': '-'" "',l.,-' :~" -', ,', (3) If property of the defendant(s) not levied upon an subject to attachment is found in the pol;Ses1>ion01,ilhY~pQ.other lhana named garnishee. you are directed to not>>y him/herthat he/she has been added as a garnishee and isenjolrfdlfas:abOve staled. . Amount Due $106.546.19 LL from 12/30/0l to date of sale 6/5/02 Interest Per Diem @l;2€.ee ~1,212.2!l Due Prothy AlIY'S Comm % Other Costs $.50 $1 00 Ally Paid Plaintiff Paid $J07 AO Date, .Janll"TY 2. 2002 Curtis R. Long Prothonotary. Civil Division AO/Y1 0 [} C;pc/(/J/"r-f.l r-- Oeputy ~ REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Marney for: Plaintiff Telephone: A56-4A2-6900 Supreme Court 10 No. 04107. ,,,"_"-0:,, _-'~"'G,_-" b__",-' ,o-"i., '< _ '~';<j:"'j""j''''-%,,,,l'E!!)-0.;,,'%i,,j:',M,!,+,,.'''L,,,\b)j-'trc.i<.1!t".,.!"Mi~4\gfi",;""*,"~'~~9._,",,,_M<~'<!~il~~jIiHti1iliil!itilitlf!lii iJ.!I! ~II;:i!IlI 11Iil., '.~EAL ESTATE SALE No. 01 On February 5, 2002, the sherifflevied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, P A, known and numbered as 313 Lamp Post Lane, Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 5, 2002 By: JodL[ Jvvt.JC1. Real Estate Deputy __,~~, .'MO,,,",. . .~~~ ,~ . ~ r::;;:g c::::::J Gt) GViJ . 'f,' ,~,~ . ''-''. -- '-.c" ~~iA-~' 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 ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: APRIL 26, MAY 3,10,2002 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. Ro SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 NOTARIAl: sEAL LOIS E. SNYDER. Notary PublIc ~ Boro, CUmbertand Coun\y My Commis8Ion ExpIres M8rl:h 5. 2005 '-.--- _.1 REAL ESTATE SALE NO. 1 Writ No. 2001-6506 Civil Wells Fargo Bank Minnesota, National Association. f/k/a Norwest Bank Minnesota; National Association, as Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS, Carter Harrison Atty.: Mark J. Udren ALL THAT CERTAIN ptece or par- cel of land, with improvements thereon erected, situate in the Town- ship of Hampden, County of Cum- berland. State of Pennsylvania. more particularly described as follows, to wit: BEGINNING at a point on the southwesterly side of Lamp Post Lane at the dividing line between Lot Nos. 9 and 10. Block "W of the hereillafter mentioned P18ll, which point is 627.23 feet to a northwest- erly direction from the southwest- erly comer of Carriage House Drive and Lamp Post Lane of the Plan; thence by said dividing line South 35 degrees, 10 minutes West 113- .27 feet to a point at the line of Lot 13. Blo~k MH" of the Plan; thence along Lots Nos. 13 and 12, North 59 degrees, 30 minutes West 100.33 feet to the dividing line between Lots No.s 10 and 11. Block "W of the Plan; thence by said dividing line North 35 degrees, 10 minutes East 121.43 feet to a point on the south- westerly side of Lamp Post Lane: thence by same South 54 degrees. 50 minutes East 100 feet to a point at the dividing line between Lots No. 9 and 10, Block "W of the Plan, the place of beginning. BEING all of Lot No. 10. Block "HM, Plan 4 afFine Brook as recorded in the Cumberland Cormty Record- er's Office in Plan Book 15 Page 41. BEING known as 313 Lamp Post Lane, Hampden Twp" Camp Hill. PA 17011. PROPERlY 1D NO,: 10-20-1848- 108. TITLE TO SAID PREMISES IS VES1ED IN Carter Harrison, single man, by deed from Carter Harrison and Guo Harrison, husband and wife, dated 4/19/99. recorded 5/26/99. in Deed Book 200. Page 211. . ." ~~ "I" ,-~" .,' ,..' ,- ,_, _'::,,~'c'~i- '"'\i!i~'!/Q;"j,lli.~",, ~ ~Jll:t_"N.7"1'l ~- .-. .....,,;,,= ' fr^'.~~'-" J' i "f . l~_,~_~~~o #~,""~"'~"" ~ - THE PATR'IOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, I';:lproved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and..I!1ll Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. .~ d'~~........................................................ Sworn to and subscribed befor his 17th day of May 2002 A.D. NolarlalSe.I, // Terry l, Ru~, NotalY Public L.:1..A Harrisburg, Oauphln County My Commission Explr.s June., 2002 TARY PUBLIC Member. PennayWanla AssQ<:\at\on 0\ Not~ commission expires June 6, 2002 PUBLICATION COPY SALE #1 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTl-lOUSE 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 $ 249.60 1.75 251.35 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ~ REA{ESTATESALE No, 1 - WrU!{o, 2001-6506 -____c,Iv!1Term ~ WeUi -Eargo Ban.k Minnesota, - . National AssociatIon, '~_ f1Jrla t{orwesl Bank 1nDii-nota Nalional Assocol ~ ,~....nu_lorSASCO Mortgage Loan i'tust , .191l9-SC4 '.... - ---- c._r:ttr Hardson ~- -~-::.. Atty:T~rk J. ~dr~n ~~;~- --- ~_TI1AJ CERTAiN piece or parcel 'Of land. with improvements thereon erected, situate in the Township 'Of Hampden, County of Cumberland. _.Btale of Pennsylvania, more particularly ~asfoUows,towit: ~.BEGINNING at.a point on the southwesterly side iE'QfJ..amp Post L;me at the dividing line between ~N",. 9 and 10, Blool "H"of the hereinafter :-iJtehlIorled pIan, which point is 627.23 feet in a -noOhwester1.l' direction from the southwesterly coiner of Carriage House Drive and Lamp Po~t or-,l.aue-_of the_Plan; thence by _said dividing line ~ro_QtTf3~~.10-mimites west. 113.27 feet to ~ 9Qtn(3,I'!!ie line 'Of Lot 1~. Block "II" of the .;J'fi!p; _ akm& r..,~ No. 13 and 12, north 59 ~",_jILmjnutes w"'L 100.11 feet 00 the .~__v linebetweenLotsNos.lOandll,Btock ,==="lli' Phw; the= hy .said dividing line - - ~.J: 10 minutes east 121.43 feettoa ~ the southwesterly side 'Of Lamp Post ~Laoe; thence by s~e sou~ 54 degre~~ .50. 1Irlfiute.I. east roo feel to a POlO! at the dividing ~ liDebetweenLili_Nl;,.;9aoc1lO,Biock "H"oftbe ~.Ihe pl,ce of BEGINNING, ;.JlmNGJ\L1. OF ill N~.l~ BJoc,l, "H," Plan 4 ~.orP'me Brook. as recorded in the Cumberland - COimlfRecorder's OILce in Plan Booli. 15 page '4L 'JjlllN:cr KNOWN " 313 Lamp Pm' Lane ~enTwp.,CampHil1,PA 17011. "'1'J!OPERTYIDNO.: 1iJ.21l-1B4B.IOB. ~ SAID_ premises is vested in Carter ~ sin$le ,man. by deed from Carter ~and Quo Harrison. husband and wife. ~ 4719J99, recorded 5(1..6199, in Deed B001 ''W.1'''&e211.