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HomeMy WebLinkAbout03-2716MARK 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, Mlq 55120 Plaintiff v. Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant{s) ATTOP~NEY FOR PLAINTIFF COURT OF COMMON PLEAS i CIVIL DIVISION Cumberland County COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following ~ages, 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. LAWYERE REFERP~AL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9018 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abo~ado y entre~ar a la corte en forma escrita sus defensas o sus objeciones a las d~mandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AFERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9018 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 marl it to you. If you do not dispute the debt, it is. not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 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: N/A Assignments of Record to: N/A Recording Date~ N/A · 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: 166 Oakville Road MUNICIPALITY/TOWNSHIP/BOROUGH: North Newton Township COUNTY: Cumberland DATE EXECUTED: 10/18/02 DATE RECORDED: 10/30/02 BOOK: 1779 PAGE: 4771 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: 6/9/03: (a) by failin9 or refusin9 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. The following amounts are due on the said Mortgage as of Principal of debt due ~npaid.I~terest at 7.785% rom 1~1/03 to 6/9/03 (the per diem interest accruing on this debt is $20.96 and that sum should be added each day after 6/9/03) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $240.17 and that sum should be added on the first of each month after 6/9/03) (239.27) Late Charges (monthly Iate charge of $34.79 should be added in accordance with the terms of the note each month after 6/9/03) 139.16 Suspense Balance (500.12) Fees Billed 55.00 Attorneys Fees (anticipated and actual to 5% o~ principal) 4,790.87 TOTAL $103,925.66 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 $95,817.37 3,332.65 250.00 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $103,925.66 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 ALL THAT CERTAIN TRACT OF LA/FD SITUATE IN NORTH I~WTON TOWNSHIP, CUM~ERLkND COUNTY, PEIqNSYLVANIA, BOITNDED A~ID DESCRIBED IN ACCOPJDANCE WITH A SLrBDIVISION PLAN FOR RONALD ~ ALICE NEGLEY, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR C~ERLA/~D COI/ATrY, PENNSYLV~%NIA, IN pLAN BOOK 32, PAGE 7, AS FOLLOWS: ~EGINNING AT A RAILRO~.D SPIKE IN THE CENTERLINE OF LEGISLATIVE ROUTE 21007 AT COP~ER OF OTHER LARD NOW OR FORMERLY OF RONALD P. ~ ALICE K. NEGLEY; THENCE BY LA~-D NOW OR FOP/~ERLY OF RONALD P. AND ALICE K. NEGLEY, SOUTH 51 DEGP~EES 15 MINUTES WEST 175 FEET TO AN IRON PIN; THENCE BY THE SAM~, NORTH 38 DEGP, EES 45 MINUTES WEST 200 FEET TO AN IRON PIN; THENCE NORTH 51 DEGREES 15 MINUTES EAST 175 FEET TO A RAILROAD SPIKE IN THE CENTER OF LEGISLATIVE ROUTE 21007 AFORESAID; THENCE BY THE CENTERLINE OF LEGISLATIVE ROUTE 21007, SOUTH 38 DEGREES 45 ~IIUJTES EAST 200 FEET TO A RAILROAD SPIKE, THE PLACE OF BEGINNING. BEING LOT NO. 4 OF THE AFORESAID SUBDIVISION PLAN. CONTAINING 35,000 SQUARE FEET. Image Print Page 1 of 6 Homecomings ~fna~.cinl Atvd107 2~t3 Certified Mail ]imam. Receipt Requesaai 043~752~ Ski!apcnsb,~ PA l Loan NUmber TO CURE THIS DEFAULT. :~I~T~ 'YOUI~. C~CK IN '~E ~MOt~T OF ~ I.~R.IO BY May O~. ~ '~) ~ F~LO%~(} ADDRESS ~mec~lng~ ~na~al, P.O. Bo~ ~26 Ph~ni~ ~ ~q~24~6 OR O~G~ T~ 2~ W. ~nlap Ax~nue, ~uite I~ Ph~iL You have lhe n~b.! lo bring ~ e.~t *ctkm Io ~k*t~t,*'tl t~ not~.x '~e of a de~hult ot may c~et d~t%n_~ fl.~ mt~y ~aat to prevem aceelcranea"~ ar, d sate of lhe prc~peny TI~ NOI'ICll IS SENT TO YOU D~ AN AI'r~tfl:'T TO COLLECT ~ kNDI~TEDNESS REFERll.ED TO HSRED4 ,ANT~ ANY INFOR~%{ATION OF~TAI~q~,D FROM YOU %%5I& BE t~/gD FOR TNAT PL'RPO~ Lmm C,~rmelln~ De~u-tmem .......... ~t?._s:{A~aging.homecomings.com/imageview/Pr/ntImages.asp?DocumentID=31398300&.. 05/27/2003 Image Print Page 2 of 6 ACT 91 NOTICE TAKE ACTION TO SAVE YO~ HOME FROM FORECLOSURE NOTICE IS SEN'f TO YOU IN ~ AITEMI~ TO COLLEc~f TI~ D,~I~TEDNE$S P,I~ER.R.ED TO ~i~ ANT~ ~.NY INFORMAT~.~ OBTAIN~ED FROM YO[7 ~.%~L BE I ~15I)FOR TIL~,T PURPOSE ~¢ HC~IEgYWN~R'S MORTGAGE ASSLST~au'qCE PRCA'~RAM fHlqMAP~ may be ~1¢ t~ help m aave _v~mr h~n~ This Notice ~Ll~ how ~ pmgr~ ~o_ rks Io..~ ff I-~MAP can h~l? ?-oa mint MEET WITH A CON_~~~_Q~QE~'NCY 30 DAYS OF TH DATE OF 'GllS N'O'HCE. Take th/.s notioa ~rRh you wham ¢oa meet with the Coum~l~ The ~,%.._add~e ss ~d ph,.x~e numbe~ of Cort~um~r Credit C~[ n~ .a,g~9,~ ~:~i.~ sea'~'tr~ ~'~ a' Coamy are li~d at the This Notice con,aim imp~mant I~t infor~ao~, If y~haa'e ~y ~s~, ~i~ ~ ~e Cm~ Credit lro6 Oak,rille Road Sh~p~m~. PA 11157 .............. ~ .t~_s!((imaging.homecomings.com/imageview/PrintImages.asp?DocumentID=31398300&.. 05/27/2003 Image Print Page 3 of 6 HOMEO~2NERS' EMERGF~CY MORTGAGE z~SISTANCE PROGRAM YOU MAY lie £LIGIBLE POR F[NA.~CLkL ~'4SIS-rANcE WHICH CAN ~XVE F'ORE(~I,(~,[ RE AND HELPYOU MAKE FUTURE MORT(.~AG-b'~ IF YOU COMPLY ~3,TI'H TttE PRO'~ZSIONS OF ~ HON~O~k%~'S ~G~CY MORTG~ ~SrT:MN'CE AC~ OF 19~ ~}~ ".~T% YOU ~LAY BE ~.IG~ FOR ~G~CY M~TGAGE EF YOCR DEI:AUL r ~ BEEN CAUSED BY C[P. CUM,~[KNCE$ BEYOh'D YQUR CONWRf)L. IF YOU HAVE A RE~,~ON,%BLJ5 PROSPE(YF OF BEE'4G ABLE TO PAY YOL~ MORI~AGE PAYMENTS. AND [F YOL' MEET OTHER ELIG[BILtTY REQLqREIvlENTS ESTAI~LISI:IED BY ~ PE2~'NS YL V~xlLA HOL'S I~O T~IPOIZ~Ry STAY OF IZORECLOSURE - Under the ~ y~a are ~fl~ ~ a ~- ~ ~ MO[~TGAGE ASSIST~NCb~ YOU Mt~T BRhNG YOL~ MOR'I~}AGE [P TO DAFE. '~ P~T OF ~PdL% APPLICATION FOR MORTGAGE ASSLSTANCE - Ym~r nmrtg~e L~ in &faMt f~ ~e m~ s~ f~ ~ ~e ~ble to t~ol~ ~s ~em w~h ~ I~, ~ We ~ r~t ~o ~ly for ~nc~ ~ ~ ~e ~ ~' mil ~i~ y~ m ~mit~ a c~letc ~pli~n to ~e P~'lmla I{c~ Fmc ~ CONTACT IN REGARIXS 'to PENNSY1,V,,*,NT~X HOUSING 2711 N~mh I-[as~k~it A~e. Strife 9~313 .............. ?tps://imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=31398300&... 05/27/2003 Image Print Page 4 of 6 AI,L CORRESI~)N~DENCE REG-ARDL~G PHFA ,xs,s~r.~'~c E s}Iot~ BE ~RW,~$~ TO ~)VE REFER.~NC ED ~O[ MinSq' FILE YOUR APPLICA~ PRO~LY, IF YOU F~L TO ~ ~ OR W YOU ~ N~ FOLLOW THE OD[~ laME PERI~ SET ~RTH LN HHS LE'~E~ ~)R}X'.L~q~RE MAY PROCEED AGAINST YO[~ HOME [%[MEDIATELY &ND YOUR APPLICATR)N FOR M(~'rGAGE AGENCY ACTION -- Available fun, ds ibr emeatwn~' mart~a~ l~.~ialara~ ate very limited They. will No~rE: IF YOU ARE CURREN'TI,Y PROTECTF~ BY THE. FIIJNG OF A PETITION LN ~X'~qtUPTCY, 'rile FOLLOWING PART OF THIS NOTICE I~ FOR kNq~ ORM.~tTION lq;liPC~l~ ONLY AND ~tOLrLD NOT lie C ONS'TRLq~I} AS ,MN ATTEMPT TO COLL FX2T ~ DEBT, lIOW TO CURE YOUR MORTGAGE DEFAULT (Brb~g il up to date). NATURE O g 'IH I~ D E FAUI.T -?he MORT~,~}E debt be d ~' ~¢ aborn endcr on yo~ pmper~y Ic,~ed at: 17257 iS SE1LIOUSL Y IN DEFALLI' becatm YOU }5.XVE NCO' MADE MONq'HLY M©RTOAGE PAYMENTS t~r the follOWl*~ $ 69.58 $ 2500 $ 5~)0.12 It[OW TO CURE TIlE DEFAULT .- You may. ~te ~e ~ ~ D~TY ~) DAYS of ~ ~ of ~ N~i~ BY PAYING ~ TOT~ ~MOL~ D~ TO ~ L~N~ h~ ~ $ 2.~.10. PLL~ ~' MORT(},kGE PAYNimS :M~ LATE C~S L~CH BECO~,~ DC~ D[~'O ~ T~ (~0) DAY Homeeo~ F~e~, P.O. Box 7M26 ~oe~ .~ ~$26 OR O$~NIGHT TO: IF YOU DO NOT CT'RE T~IE DEFALqLT - ff you & mt c~ h% ~f~lt mhhm ~' (~ DAYS ~ of ~is Nc-ti~c, t~ lender in.rids ~ ~1~ it~ ~ht ~ ac~e~te ~g mo~ ~ 'l~s m~ ~at ~ o~[~ing ~aLance of ~i$ d~ writ be c<~M~cd ~ i~i~, ~d y~m m~v Io~e ~ ~ {o ~y t~ m ~ly ~t~. ~ ~1 ~ ~f ~ ~1 ~t ~ ~ K nm m~ wi~ 'F~' ~30) DAYS, https://imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=31398300&... 05/27/2003 Image Print Page 5 of 6 IF ~ MORTGAGE I$1 FORECLOSED L'POD' - ~e m~ F~/~11 ~ ~o~ ~ ~ S~ff m ~y off /) . - _iho lemter may also ,ue yo~ t~,t,,m~lly l~ ~.~ ur~id principal ~k~ ~t al RR;tlT TO CURE THE IIEFAUI,T PRIOR TO ~}IERIF['$ ~3L[ - [f~u ~ ~ :~t ~ ~utt · e ~TY 00) DAY ~iod ~ f~lo~ ~in~ h~'e k~ ~~~ ~ pr~'~ thc :~le a ~v ti~ ~ to o~ ho~ ~f~ thc ~it~ ~ You ~V ~ ~ by ~fing ~ t~[ ~t ~ ~ ~er r~[* ~ ~e ~ CuH~ ~ur d~u~ in ~ ~ ~ f~ iu this EARLIEST POfl,~BLE Slt~.RIFF .~ SALE DA~ - ~ is eaim~l U~ ~c ~li~ ~c ~at ~ a Sh~ff~ Sale of t~ mo~d pm~y muld k~ ~ld ~d be app~mately ail (6) month, from Ire d~ of thin No~. ~ ~ ~f~ll ~511 ~ ~ 1~?~ ~[ You m~' find ~ a ~F ~m~ ~lly w~ ~ r~md ~t m }IOW- TO CONTACT THE L E fflrECT OF THE SI-~W~"S ,qALE - Yoa should r~alize tl~at a Sheriffs $~le w/it end y~ o~,a~J'tip ,~The laWr~t tu m-ao~ ~m and y~r fumir, d~ a,'at ~tla:* h~l~n8~2 ~ l~ smm:d by dw 1~ at ~. ~ A~U~PTION OF MORTGAGE - Yum may b~ a~le ~o ~l! or r. ramf~ yo,tlr ~ to a buyer or transferee who will ~ur~ t~ m~'tlta~ de~.~ i~'m,~do;t daat alt tl~ o. rm,mdmg t~a),,~, eh,arg~ md al'mm~'a fe,~ and co.,,~ pard F/nor Io or at the sale amd that th~ olher ~,Cl~S of the men,gage a~e YOU MAY AL~;O HAVE 'tHE R~]~: TO $~ TItlJ PROPV~,TY TO OB FAff,T MONF. Y TO PAY OFF T[-IE MORTGA(IE DEBT OR TC3 BORROW MONEY FR/3M .~(.7['ItER LI:NDLNG L%S~TI'U3~)N TO PAY OFF THIS DEBT TO HiVE 'tHIS DEFAIla.T CURFJ) BY ANY THIRD P -~.~ll' Y A{}-F ]~J Ct ¢3N YOUR BF~HeM. Z https://imaging.homecomings.comJimageview/Printlmages.asp?DocumentlD=31398300&... 05/27/2003 Image Print Page 6 of 6 TO [L&VE lYJ~ MORTGAG~ RESTORED TO T~ 5&ME ~[[[ON ,~ · NO DEFAULT ~ ~CL~. · YOU ~ ~ D~FAEI.T ~%~. YOU ~9 N~T ~ ~ TO ASSERT ANY cYr~ ~'5E YOU BIiLi~¥'E YOU ~b'~.Y ldA~v~ 'It) SUCft ACTION BY DIE Smo~a~ly~ L,a~ C~hn~ D~ L~s~ or Coumehng Agera,4~ httPs://imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=31398300&... 05/27/2003 Image Print Page 1 of 6 Homecomings ~inancial Ami 07. 21~T3 Certified Mail. Remm R¢oeipt Requested 0435075270 Caren 16S Oakvflle P~ Shippen~bur~ PA 1~57 Numb,a- 04.~5075270 ~' fees. ~/c~ o~ f~s ~i ~ w~h tony ~e d~, ~ ~ date of TO CL-P.E THIS DEFAULT, :gliNT) YOLI~ CASi-amq'S CKE~ ~Y ~ OR C~ CHECK L~ THE ~,[OL~T OF $ l.~.lfl BY May ~7. 2~B '~) ~ F(~,O~O ADD~S: IbJemln{{ F~a~l, P.O. Box ~26 ~nlap Am~nue, Suite 1~ If the default is nm cured xOhln thirV/(3(0 days of the mailing af this letter, tl~ k-rider, wlthoul further netlce ~ 'l'e~ to ~ i~e~a~ly d~ ~ pa~Me '1~ l~ t~ inure& to ~ve ~ p~' ~mld ~ a public You have the d$-,l 1o lmng a ¢,~u't act/mm Io am¢~ t~¢ m~ismenee of a default or may' clhcr ¢lef.,~,~e that exu,~ to prevem acceteratk~ ~ ~.q{~ of the l~'opo'ty ]INFORMATION OBqTAI~'~'D FROM YOUWILL BE L~ FOR THAT PL*RPOSH Sincerely, ........... _ht~Ps:#imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=31398294&.. 05/27/2003 Image Print Page 2 of 6 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NOTICE IS 5ti2qT TO YOU D4 ~ ATTE~ TO COLLECT ~ ~ti~TEDNE~S ~D TO }~.El~ ~ND .AZ<Y E~F OR MA'FfON OBTAP4ED FROM YOLr WR,L BE USED FOR THAT PURPOSE Thia is an offxcad notice that the nvmtgt~t~n y~ur ~ L~ in dei~uI.T,__ar!4_ .the lender int=nds The HOMEO~?,~R'~ MORTGAGE ASSISTANCE PROGRAN~ (HE'MAP} may This Notice e~plains 313 DAY5 OF TI4 DATE OF TI~ NOTICE. Take this notice wi~ you when you meet a~ilh April 07, 20)3 ?t~s:ffimaging.homecomings.com/imageview/PrintImages.asp?DocumentID=31398294&.. 05/27/2003 Image Print Page 3 of 6 HOMEOWN~ERS~ E~IERGENCY MORTGAGE ASSISITANCE PROGILM%! YOU MAY BE ELI¢;IBLE VOR FL*4ANCL'dl .~SI~[~'qCE WHICIt CAN ~XVE YOUR/tIOME YKq)M IF YOU COMPLY WFVH Tile PRO%qlSIONS OF ~ HO~O[%~'S ~G~' MORTO~E ~T~ A~ OF 198~ ~ "~T'), YOU XLkY BE ELIG~[~ FOR ~G~Y MORTGagE IF YOUR DFA:AULT I:IAS BEEN CAUS ~') BY CIRC UM$'r.~NCE$ BEYOND YOUR CONTROl.. ~ YOU tL4 x.'"/~ A RI~,ASGCN&B,I~ PRDSPEL~ OF ~E~'O ABLE TO PAY YOLIqt MORTGAGE PAYN~N'TS, AND Ilr YOL'NfiEET OTteR ELIGIBILITY REQ/L2RE~[ENTS I~STABLIgHED B Y Tile PEN~SYLVP..IW~ t-IOIU~ lNG I~¢ANC~ TEMPOtLCCRY STAY OF FORECLOSURE ~ Undo' th~ ~ ~ ~ ~tl~ ~ a ~' my ~ ~ecl~ on y~ ~ ~ ~ (30) d~vs ~ ~ d~e ~ ~ N~i~ ~ ~ ~ ~ ta~ ~ ~ ~1 a MoIcrtgAGE ~SlST~NL'E~ YOU MUST BRING YOL~ MORIYJAGE UP TO DAFE, 1~ P~T OF T}{~ N<YIIC'E C.a&LED ~I4D%' T{,) CURt~ YOER MORTGAGE DEFAL~LT'~, ~ed~LAINS 'fiC~V TO BRI~qG YOL~ APPLICATION FOR ,MORTGAGE ASSifi;T:M'~CE - Yrmr morlg~,e ia in def~ull for the rem<~a se~ foe& h~r in thia Notice (see fi~tl°~nn$ pages toe sr~-eiti¢ information abouz tl~ nature of ~ default) If ),ma have tried and lqceactys'n~'s Emargemy M, mgage ,~i~mr, e l~*gram. To do ~:~ you ma~t flu out, ~rt md fik a ~omple~cd ~ ~' ~]t ~ ~ m ~im~ a c~plete ~pt~ m ~e P~'~a R~i~ F~ ~ https://imaging.homecomings.corrdimageview/Printlmages.asp?DocumentlD=31398294&.. 05/27/2003 Image Print Page 4 of 6 .iLL CORRESPONDENCE REGARDL'~G PHFA ~m~r,~Nc E SIIOULD BE FORW~D~} TO ~{E X~)VE REFERENCED MID R S~ YOU ~U~q' ~E YOUR AI~qACA~ PRO~'LY~ ff YOU FA~ TO ~ ~ OR W YOU ~) NOT FOLI,OW THE Ortl~;R TL~IE PERI(~ SgT F(~'fH LN ~IIS LE~ER, g~RECL{~URE ~Y PROCEED AGXINST YOCR HOME IMM~LVrELY AND YOUR ,~PLRCA~ON FOR MI~TGAGE A¢;F/NCY ACTION - Availabl= fun, da far cmer,gcn~y mortgase ~i~ ~ ve~ limed ~' will M ~s~ a:l] ~ ~ ~m ~ if ~ have m~ thc h~ ~im~ ~ t~ ~, Y*u mil ~ n~ificd di~ly ~ NOTE: IF YOU ARE CURR~'I'LY PROTECTFJ) Blt' Tg-IF Itl.lNG OF A PETITION liA.~13PTCY, ~ FO LLO%VLNG PART OF ~ NOTICE ~ FOR EXlFOR.%L.%IION ONLY ,MN'D SHOL~J) NOT l~g CONWrRlrED .~.q .~ ATTEMPT TO COLLECT ~ DEBT HO%V TO CURE YOUR ~MORTGAGE DEFAULT (Bring il NATL~ E O F 'I'HF I}~U~T -T~ N/ORTGA~ dc~ ~ld by ~c ~ I~r on yo~ ~r~y I f~ C~4llc R~, S~p~ PA 17257 SERIOUSLY ~I DEFALLT beeauae: YOU HAVE NOT 5~[XDE MONTHLY MORTGAGE PAYMENTS for IE0 mmatha and tl~ ~llowing anamwla ar~ r.~v p~t $ 250(} $ ~0.12 HOW TO C[~:R~ THE D~I~AULT .. You may ~ ~e Nm~ BY PA%~G ~ T~.~ ~%{OL~ DUE TO 'r~ MORTGAGE PAYNimS :XN~ I_ATE C~&R!}E~ %~CH BECON~ DUZ DU~*O ~ T~TY (~0) DAY H~eco~ F~Ie~ P.O. ~x 7~26 ~oe~x, AZ ~$26 OR O%~NIGHT TO: 2~5 W. ~p Avenue~ S~te 1~ ~a~ntx, AZ 8~21-~. IF YOU DO NOT CLrRE TIlE DEF,%[~LT - I1~ >~ do ~t ~c ~ ~au]t m~m ~TY ~) DAYS ~f ~ ~e m ~n~y ~t~enm. ff i~l ~m oC ~ t~ ~ ~ ~ is ~ m~ ~i~ T~'I'Y (30) DAYS, .............. h~¢!/(imaging.homecomings.corrffimageview/Printlmgges.asp?DocumentlD=31398294&... 05/27/2003 Image Print Page 5 of 6 IF ~ MOI~GAGE L~ FORECI,~ L'PON - The moon, aged pro~xy ~t] ~ soM ~ ~ 5h~ff ~ ~y off i~ ~p ~ ~.~J. 1~'~, ff ~ ~e~ ~c s~ed ~t yol you w~ We lo ~y ~ ~{~ RI(IHT qX) CURE THE DF. FAULT PRK)R ~) SHERI}~ SALE - ~')~u ~ p~l ~e role ~t ~v- fi~ up to ~ hour ~f~ ~he ~s ~[e You ~v p~~~km ~.~c ~, C~ ~ur det~u~ in ~ ~er ~ [o~ J" ibis Notice E.~uRI,IEST PO&qIRI,E ~ERIFI~ SALE DA~ -- ~l~ of the ~o~d p~ ~uld ~ ~ld would ~ app~m~ly ~il (~ mot/bm f~m ~e da~ of ~{n NO~, ~W TO CO~TM:T THE LEND~ 271 ! N Hmsk¢lL Suit~ Altn: ,~UMPTION OF MORTGAGE - ytm nm), b~ able to ~_lI ~ ~ y~ ~ ~o a b~ct ~ ~sf~e a'ho paid ~or YOU ~.IAY Al~ed~ HAVE DEBT HAVE THJS DF, F^L];r CURED BY ANY TI-1TRD PARffY AC-rlNO ON YOUR Bi.HALF' htt~s://imaging.homecomings.com/imageview/Printlmages.asp?DocumentlD=31398294&... 05/27/2003 .Image Print Page 6 of 6 TO ASSERT A~NY OTitF~t D~'SE YOU B~VE YOU MAY t:L~VE !~3 SLL~It ACTION BY 'FIIE LKND~ T¢) SE~.K PROT~CTI©N L~N'DER 'File FIgDERAL B ANI<RL'~ICY LAW Lba of Commlmg Agenci~ https://imaging.homecomings.com/imageview/PrintImages.asp?DocumentlD=31398294&... 05/27/2003 VERIFICATION 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. Mar~J/~. Udren, ESQUIRE MARK Jo UDREN & ASSOCIATES SHERIFF'S RETURN - REGULAR CASE NO: 2003-02716 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAI~D MORTGAGE ELECTRONIC REGISTRAT VS BODINE SCOTT A ET AL RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE BODINE SCOTT A DEFENDANT , at 1704:00 HOURS, at 166 OAKVILLE ROAD SHIPPENSBURG, PA 17257 by handing to CAREN L. BODINE, WIFE a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to was served upon on the 20th day of June the together with , 2003 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this ~D ~ day of A.D. pr~ ~2~~ ,~ othononary So Answers: R. Thomas Kline 06/23/2003 MARK UDREN Deputy Sheriff SHERIFF'S RETURN CASE NO: 2003-02716 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLA~[D MORTGAGE ELECTRONIC REGISTP~AT VS BODINE SCOTT A ET AL REGULAR RONALD HOOVER , Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE BODINE CAREN L DEFENDANT , at 1704:00 HOURS, at 166 OAKVILLE ROAD SHIPPENSBURG, PA 17257 CAREN L BODINE a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 20th day of June by handing to the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 30 ~ day of ~rothSnorar¥ So Answers: R. Thomas Kl±ne 06/23/2003 MARK UDREN By: Deputy Sherif~ MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. Plaintiff Scott A. Bodine Caren L. Bodine Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2716 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: July 25, 2003 MAR~UDREN & ASSOCIATES Mark J. ~dren, ESQUIRE ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. Plaintiff Vo Scott A. Bodine Caren L. Bodine Defendant(s) ATTOR/~EY FOR pLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland. County NO. 03-2716 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: August 12, 2003 MARK J. UDREN & ASSOCIATES BY: Mar/j.~r~e ~orney 'for Plaintiff VERIFICATION 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 unswom falsification to authorities. Nalne: Title: Company: Sco~ A. Bodine Caren L. Bo~ne Loan#0435075270 MJU#03050549 ~*31V '~MinnM, ~nebi,,mq eoiV ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I,D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) ATTORREY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2716 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESS~NT 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 6/10/03 to 8/12/03 Late charges per Complaint From 6/10/03 to 8/12/03 Escrow payment per Complaint From 6/10/03 to 8/12/03 $103,925.66 1,341.44 69.58 480.34 TOTAL $105,815.02 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. (MARK~EN & ASSOCIATES x~a~rk J. Ud~en, ESQUIRE Attorney foY Plaintiff PRO PROTHY 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 Mortgage Electronic Registration System, Inc. Plaintiff Scott A. Bodine Caren L. Bodine Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2716 Civil Term DATED: July 30, 2003 TO: Scott A. Bodine 166 Oakville Road Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTOP_NEY 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 800-900-9018 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 UNABOGADO 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 800-900-9018 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. AN~ INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 Mortgage Electronic Registration System, Inc. Plaintiff Scott A. Bodine Caren L. Bodine Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2716 Civil Term DATED: July 30, 2003 TO: Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAR3LNCE 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 800-900-9018 NOTIFICACION IMPORTANTE USTED SE ENCUENTP~A EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A I/N 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 800-900-9018 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. MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINOS HIOHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) NO. 03-2716 Civil Term STATE OF AFFIDAVIT OF NON-MILITARY SERVICE cou ¥oF %',-c9 o : SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Scott A. Bodine Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Caren L. Bodine Age: Over 18 Residence: As captioned above Employment: Unknown Sworn to and subscribed before me this Is~"day Notary Public Name: Title: Company: Vice Preeiclent MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP. RY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) ATTOR/~-EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2716 Civil Term CERTIFICATE 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: Sec. ) ) ) (x) ( An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Vo Scott A. Bodine Caren L. Eodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) SUITE 500 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2716 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 8/13/~13 to Date of Sale D_e~cember Per diem @$20.96 (Costs to be added) 10, 2003 $ $105,817.02 2~5~ MARK J. UDREN & ASSOCIATES ~en, ESQUIRE ATTORNEY FOR PLAINTIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-2716 Civil COUNTY OF CUMBERLAND) CIVIL ACTION LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From SCOTT A. BODINE AND CAREN L, BODINE (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $105,817.02 L.L. $.50 Interest FROM 8/13/03 TO DATE OF SALE 12/10/03 - PER DIEM ~ $20.96 - $2,515.20 Atty's Comm % DueProthy $1.00 Arty Paid $136.35 Other Costs Plaintiff Paid Date: AUGUST 19, 2003 (Seal) ILEQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 CURTIS R. LONG Prothonot~ Deputy MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE $00 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2716 Civil Term AFFIDAVIT PURSUA/qT TO RULE 3129.1 Mortgage Electronic Registration System, Inc., 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: 166 Oakville Road Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Scott A. Bodine 166 Oakville Road, Shippensburg, PA 17257 Caren L. Bodine 166 Oakville Road, Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS %1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded record: Name Address holder of every mortgage of 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 the property and whose interest may be affected by the sale: Name Address in Real Estate Tax Claim 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 other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 166 Oakville Road, Shippensburg, PA 17257 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: August 12, 2003 MARK J. UDREN & ASSOCIATES 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 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Scott A. Bodine Caren L. Bodine 166 0akville Road Shippensburg, PA 17257 Defendant(s) ATTOR/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 03-2716 Civil Term NOTICE OF SHRRTFF'S SA?.E OF ~R~?. PROPERTY TO: Scott A. Bodine 166 Oakville Road Shippensburg, PA 17257 Your house (real estate) at 166 Oakville Road, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,817.02, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTI~CE OF OWNERJS RIGHTS YOU MAY BE ARLE TO PRRV~.NT THIS SHRRIFF'S SAT,R To prevent this Sheriff's Sale, you must take The sale will be cancelled if you pay to the mortgagee the back payment, lat~ charges, costs and reasonable attorney's fees. To find out how much you must pay you may call: (856) 482-6900. You maybe able to stop the sale by filing a petition asking the Court to strik, or open the judgment, if the judgment was improperly entered. You may also as the Court to postpone the sale for good cause. 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, tb more chance you will have of stopping the sale. (See notice on page two on hc to obtain an attorney.) AYE_XQ~ P/~0P~EP~TY~ARD_XOU HAYE_Q~~ EVEN IF THE SHERIFF'S SAT.R DOES TAKE~PJ~%SLF~ 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 HA%'E A LAW~ER OR CANNOT AFFORD ONE, G0 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAW~ER REFEP~AL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9018 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9018 'MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Vo Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) SUITE 500 ATTOR/TEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2716 Civil Term NQT/~F-~0 ' OPERTY TO: Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Your house (real estate) at 166 Oakville Road, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,817.02, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOT/~CEO~ OWN~5S RIGHTS ~OU ~Y~BE ARLE TO PREVuF2~T~~'S SALE To prevent this Sheriff's Sale, you must take 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: ~J_-482~900~ 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 'YOU MAY~STILL BE._ABLE T~SAVE 55OUR PROPERTY~AND_Y03/ HAVB OTHER RIGPITS EVEN IF~HE_SHERI~F_'~SALE DOES~AKE~ P~LA~E~ 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 AFFOP, D ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERHAL SERVIC~ Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 170130 717-249-3166 800-900-9018 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9018 ALL THAT CERTAIN TRACT OF LAND SITUATE IN NORTH NE~FTON TOWNSHIP CUMBEPuLA/~D COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCOEDA/~CE WITH A SUbDIVISiON pLAN FOR RONALD ARD ALICE ~-EGLEY, P~ECORDED IN TH~ OFFICE OF THE RECOP. DER OF DEEDS FOR CLr~BERL/tND COUNTY, PEri, SYLVAnIA, iN PLAN BOOK 32, PAGE 7, AS FOLLOWS: ~EGIbrRING AT A P~%ILROAD SPIF. E IN THE CENTEP~LI~E OF LEGISLATIVE ROUTE 21007 AT COP.~;ER OF OTHER LA-ND NOW OR FOP~fERLY OF RONALD P. A/qD ALICE Ko N~GLEY; TA!ENCE BY LA/qD NOW OR FOP/(E~LY OF RONALD P. AND ALICE K. NEGLE¥, SOUTH 51 DEGREES 15 MI/~UTES WEST 175 FEET TO AN IRON pIN; T~-ENCE BY THE SA~/~, NORTH 38 DEGREES 45 HINUTES W~ST 200 FEET TO A/~ IRON PIN; THENCE NORTH $1 DEGREES 15 MINUTES EAST 175 FE~T TO A P~-ILROAD SPIKE IN THE CENTER OF LEGISLATIVE ROUTE 21007 AFORESAID; THENCE BY THE CENTERLIHE OF LEGISLATIVE ROUTE 21007, SOUTH 38 DEGREES 45 MInuTeS EAST 200 FEET TO A RAILROAD SPIKE, THE PLACE OF BEGINNING. BEING LOT NO. 4 OF THE AFOHESAID S~'BDIVISION pLA~. CONTAINING 35,000 SQUAP. E FEET. BEING KNOWN AS: 166 OAIfVILLE ROAD, SHIPPENSBURG, PA 17257 PROPERTY ID NO.: 30-10-0616-020 TITLE TO SAID PREMISES IS VESTED IN SCOTT A. BODINE AND CAREN L. BODINE, HUSBAND AND WIFE BY DEED FROM EDWARD D. THRUSH AND BRENDA J. THRUSH, HIS WIFE DATED 10/18/02 RECORDED 10/30/02 BOOK 254 PAGE 1446. MARK j. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ATTORITEY FOR PLAINTIFF Vo Scott A. Bodine Caren L. Bodine !NO. 166 Oakville Road Shippensburg, PA 17257 Defendant(s) : 03-2716 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 lieD_holder 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". Order is 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". was ! pfi~o/~of compliance with said 4. If service by Order of Court hen imi~s seI forth by ~.P. ;na%.ti~s of %8 Pa.C.S//Section 4904 ~K~. ~R~S~I~ES Ail Notices were served within the til 3129. This Affidavit is made subject to th~ relating to unsworn falsification Dated: November 4, 2003 BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Vo Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant (s) ATTOP/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2716 Civil Term DATE: November 3, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OWNER(S): Scott A. Bodine & Caren L. Bodine PROPERTY: 166 Oakville Road Shippensburg, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the C//~aerland County Sheriff's Sale on Ikecember~O~=~10~, at 10:00 AM, 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. i Mortgage.Electronic Registration Systems, Inc. VS Scott A. Bodine and Caren L. Bodine In The Court of Common Pleas of Cumberiand County, Pennsylvania Writ No. 2003-2716 Civil Term Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on September 08, 2003 at 1:50 o'clock PM, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Scott A. Bodine and Caren L. Bodine, by making known unto Caren Bodine, personally and wife of Scott Bodine, at 166 Oakville Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2003 at 2:58 o'clock P.M., he posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Scott A. Bodine and Caren L. Bodine located at 166 Oakville Road, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to the within named defendants, to wit: Scott A. Bodine and Caren L. Bodine, by regular mail to their last known address of 166 Oakville Road, Shippensburg, PA 17257. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. Swomand subscribed tobeforeme This__day of 2003, A.D. Prothonotary R. Thomas Kline, Sl~eriff Real Estato/Deputy Mortgage Electronic Registration System, Inc. VS Scott A. Bodine and Caren L. Bodine In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2716 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 30.00 Poundage 12.93 Advertising 15.00 Posting Handbills 15.00 Levy 15.00 Surcharge 30.00 Service 27.60 Law Journal 256.10 Patriot News 207.19 Law Library .50 Prothonotary 1.00 Postpone Sale 20.00 Share of Bills 28.90 $ 659.22 paid by attorney 03/05/04 Sworn and subscribed to before me So Answers: This ~- day of 7,~_~e~ ~~ f,~__~--~e~  ,bj , R. Thoj~as Kline, Sheriff Prothonotary Real Estfi,,,t/e Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says; That he is the Asst. 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; 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 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said pdnted 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.  'A.D. copt t9th S A L E #37 ~ ~le. ~? C ,' · .~,~_~.,~,t~J,. My commission ~-xp~res jun ,... _ Y PUBLIC Msmbe~, Pennsytvania'T--ss°~a~°nOfNU~3My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 of Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 207.19 Publisher's Receipt for Advertising Cost ~. ~., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ;le receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, ~tnd 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 tune, place and character of publication are tree. REAL ESTATE SAI~ NO. 37 Writ No. 2003-2716 Civil Mortgage Electronic Registration System. Inc. VS. Scott A. Bodine and Caren L. Bodine Atty.: Mark J. Udren ALL THAT CERTAIN tract of land situate in North Newton Township, Cumberland County, Pennsylvania, bounded and described In accor- dance with a subdivision plan for Ronald and Alice Negley, recorded in the Office of the Recorder of Deeds for Cumberland County. Pennsylvania, in plan Book 32, Page 7, as follows: BEGINNING at a r~ilroad spike in the centerline of Legislative Route 21007 at corner of other land now or formerly of Ronald P. and Alice K. Negley; thence by land now or formerly of Ronaid P. and Ak[ce K. Negley, South 51 degrees 15 min utes West 175 feet to an iron pin; thence by the sm'ne. North 38 de- grees 4S minutes West 200 feet to an iron pin: thence North 51 de- grees 15 minutes East 175 feet to a railroad spike in the center of Leg- islative Route 21007 aforesaid; thence by the centerline of Legislative Route 21007, South 38 degrees 45 m~nutes East 200 feet to a railroad spike, the place of beginning, BEING Lot No. 4 of the afore- said subdivision plan. Containing 35,000 square t~et. BEING KNOWN AS: 166 Oakville Road, Shippensburg, PA 17257. PROPERTY ID NO.: 30 10-0616- 020. TITLE TO SAID PREMISES IS VESTED IN Scott A~ Bodine and Car- en L. Bodine, husband and wife by SWORN TO AND SUBSCRIBED before me this 31 .day of OCTOBER, 2003 LOI9 E. SNYDER, Notmy Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 BEGINNING at a railroad spike i~t the centerline of Legislative Route 21007 at corner of other la]id now or formerly of Ronald P. ired ~ice K. Neg[ey; thence by laxd now or formerly of Ron~d P. axd ~ce K. Negl~y. South 51 degrees 15 utes West 175 Iket to ~ iron pin; thence by the s~ne. North fl8 g~es 45 ~nutes West 200 feet an iron pm; thence North 51 de Crees 15 minutes East 175 f~t to a r~lroad spike ~ the center of is~ve Route ~ 1007 albres~d; ~ence by the centerline of Legislative Route 21007. South 38 degrees 45 ~nutes East 200 feet to a r~koad spike, the ptace of beginning. BEING Lot No. 4 of the afore- said subdivision plarn Containing 35.000 square feet. BEING ~O~ ~: 166 O~ille Road, Shippensburg, PA 17257. PROPER~ ID NO.: 30-10-0616- 020. TITLE TO S~D PREMISES ~STED IN Scott A. Bod~e ~d en L. ~ine, hushed ~d ~fe by ~ed from Edw~d D. ~rush ~d Brenda J. Thrush, his wiI% dated 10/18/02 recorded 10/30/02 Book 254 Page 1446. UDREN LAW OFFICES, P.C. BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration System, Inc. 1270 Northland Drive Suite, 200 Mendota Heights, MN 55120 Plaintiff Scott A. Bodine Caren L. Bodine 166 Oakville Road Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COD-RT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2716 Civil Term SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the Bodine and Caren L. Middle District of Case No. #03-07249. record that the above Defendants, Scott A. Bodine have filed Chapter 13 Bankruptcy in the Pennsylvania on December 9, 2003, Bankruptcy Mark J. l]dren Esquire UDREN LAW OFFI, PS, P.C. Attorney for Plaintiff