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HomeMy WebLinkAbout03-2805MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0%302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS ~ CIVIL DIVISION Cumberland County Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) i N0. o 3- COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado clue si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Adem&s, 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 UNABOGADO iMMEDIATAMENTE, SI NO TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignments of Record to: Wells Fargo Bank Minnesota, f/k/a 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 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 313 Lamp MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 05/21/99 DATE RECORDED: 05/26/99 BOOK: Post Lane Township of Hampden 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 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 refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage as of (b) o or 05/30/03: Principal of debt due Unpaid Interest at 10.99% * from 12/01/02 to 05/30/03 (the per diem interest accruing on this debt is $26.41 and that sum should be added each day after 05/30/03) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow 0verdraft/(Balance) $87,717.49 4,780.21 250.00 280.00 1,194.00 Late Charges (monthly late charge of $51.01 should be added in accordance with the terms of the note each month after 05/30/03) 255.05 Corporate Advance 1,078.54 Attorneys Fees (anticipated and actual to 5% of principal) 4,385.87 TOTAL $99,941.16 * 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(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 $99,941.16 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~~J. Udren, Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN PIECE OR pArCEL OF L~ND, WITH i'M~ROVEMENTS THEREON EP. ECTED, SITUATE IN THE TOWNSHIP OF HAMPDEN, 'COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA, MOi~E PARTI~Y DESCRIBED AS FOLLOWS, TO WIT: BE~iNNIN~ AT A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LA/~E AT TH~ DMDIN~ · 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 SOUTHWESTEP~LY COP, R-ER OF CARi~IAGE HOUSE DKIVE AND LAMP POST LANE OF THE pLaN; T~r~NC~ BY SAID DIVIDIN~ LINE SOUTH 35 DE~REES, 10' MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BLOCK "H" OF THE pLAN; THENCE ALON~ LOTS NOS. 13 AND 12, NORTH 59 DE~REES, 30 MINUTES WEST 100.33 FEET TO THE DIVIDIN~ LINE BETWEEN LOTS NO.S 10 A~D 11, BLOCK "H" OF THE pL;tN; ~CE BY SAID DIVIDIN~ LINE NORTH 35 DEG"REES, .10 MINUTES EAST 121.43 FEET TO A POINT ON TRE SOUTHWESTERLY SIDE OF LAM~ POST LANE; T~]~NCE BY SAM~ SOUTH 54 DE~REES, 50 MINUTES EAST 100 FEET TO A POINT AT T~E DIVIDING LINE BETWEEN LOTS NO. 9 AND 10, BLOCK "N" OF THE pLaN, '~'~u~ pLACE OF BE~i'~NIN~. BEIN~ ALL OF LOT NO. 10, BLOCK "H", PLAN 4 OF PINE BROOK AS RECORDED IN TH~ CUMBERLAND COUNTY RECOP. DER'S OFFICE 'IN PLAN BOOK 15 PA~E 41. LOAN NO DATE LETTER '~0001693340 03/04/03 0P171 VER REQ DESCRIPTION DATE 016 FL1 Part 1 Pennsylvan±a NOI 05/30/03 March 04, 2003 Carter Harrison 313 Lamp Post Ln Camp Hill, PA 17011-1459 Homeowners Name: Carter Harrison Property Address: 313 Lamp Post Lane, Loan Account No.: 0001693340 PF: 1 SC F Hampden PA 17011 EXHIBIT LOAN NO DATE LETTER VER REQ DESCRIPTIONDATE 05/30/03 00.01693340 03/04/03 0P171 016 FL1 Part I Pennsylvania NOI brig±nal Lender: OPT[ON ONE Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASS[STANCE PROGRAM YOU ~AY BE ELIGIBLE FOR FINANCIAL ASSISTANCE NHICH CAN SAVE YOUR HOME ~ROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY NITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTC.~GE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 0Q01693340 03/04/03 0P171 016 FL1 Part I Pennsylvania NOI * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROLs * 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 th~s Not~ce. During that t~me you must arrange and attend, a -face-to-face" meeting with one of the designated consumer credit oounsei£ng agencies l~sted at the end of th~s Not£ce, THIS ~EET~NG ~UST OCCUR NITHIN THE NEXT (33) DAYS, ~F YOU DO 05/30/03 PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 0001693340 03/04/03 0P171 016 FL1 Part 1 Pennsylvan±a NOI ~OT APPLY FOR EMERGENCY NORTGAGE ASSISTANCE, YOU NUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HON TO CURE 05/30/03 YOUR MORTGAGE DEFAULT"~ EXPLAINS HON TO BRING YOUR HORTGAGE UP TO DATE. OP1 71 PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0001693340 03/04/03 0P171 016 FL1 Part 1 Pennsy&vania NOI Re: Loan No. 0001693340 CONSUNER CREDIT COUNSELING AGENCIES - If you meet uith one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseZing agencies for the county in which the property is located are set forth at the end of this Notice, or you may contact HUD d±rectly at 800-569-4287 or visit the HUD PF: 1 SC F 2 SC 6 LOAN NO DATE LETTER VER REQ DESCRIPTZON DATE 05/30/03 0001693340 03/04/03 OP171 016 FL1 Part 1 Pennsylvania NOI 'Nebs±re at N~'hud'g°v/offices/hsg/sfh/hcc/hccprof14.cfm. It is onZy necessary to schedule one face-to-face meeting. Advise your lender immediateZy 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 &ender, you have the right to apply for f±nancial 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 Appl±cation with one of the designated consumer credit counseling agenc±es listed at the end of this Notice. Only consumer credit counseling agencies have appiications for the program and they wil& 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, PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0~01693340 03/04/03 0P171 016 FL1 Part I Pennsylvan£a NOI YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLON THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE NAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE HILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They Mill 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 Mill be pursued against you if you have met the time requirements set forth above. You ~ill be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. OP1 71 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0001693340 03/04/03 0P172 024 FL1 Part 2 Pennsylvania NO! Re: Loan No. 0001693340 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLONING PART OF THIS NOTICE IS FOR INFORNATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTENPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency ~ortgage Assistance,) HON TO CURE YOUR NORTGAGE DEFAULT (BRING IT UP TO DATE). PF: I SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0901693340 03/04/03 0P172 024 FL1 Part 2 Pennsylvania NOI 'NATURE OF THE DEFAULT - The MORTGAGE debt heZd by the above Zender on your property Zocated at: 313 Lamp Post Lane, Hampden PA 17011 IS SERIOUSLY IN DEFAULT because: months and the following amounts are non past due: (a) Monthly payments: 1 MONTHS ~ $ 850.17 2 MONTHS ~ $ 850.17 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the foiZowing $ 2550.51 (b) Prevlous late charges; $ 102.02 (c) Other charges; Escrow, Inspection, NSF checks $ (d) Other provisions of the mortgage obligation, PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ 0Q01693340 03/04/03 0P172 024 FL1 any (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE DESCRIPTION DATE 05/30/03 Part 2 Pennsylvan±a NOI $ 5.83 $ 2658.36 B. YOU HAVE FAILED TO TAKE THE FOLLONING ACTION (Do not use ~f not applicable): HON TO CURE THE DEFAULT - You may cure the default uithin thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER NHICH IS $2658.36, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES NHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made e±ther by cash, cashier's check, certified check or money order made payable and send to: PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0q01693340 03/04/03 0P172 024 FL1 Part 2 Pennsylvan±a NOI OvePn±ght Na±[ Address NestePn Un±on Qu±ck Collect 3 Ada Pay to: Opt£on One Nortgage Corporat±on Irvine, Ca, 92618 Code City: Opt±on, Ca You can cure any other default by taking the fo[[cuing act±on uithin thirty (30) days of the date of this letter, (Do not use if not (applicable,) 0P172 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0001693340 03/04/03 0P173 012 FL1 Part 3 Pennsylvania Re: Loan NO. 0001693340 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default ~ithin THIRTY (30) DAYS o~ the date of this Notice, the lender intends to exercise ±ts rights to accelerate the mortgage debt, This means that the entire outstanding ba~ahce of'this debt will be considered due ±mmediately 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 uithin THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your PF: 1 SC F LOAN NO DATE LETTER VER REQ DESCRIPTZON DATE 05/30/03 0Q01693340 03/04/03 0P173 012 FL1 Part 3 PennsyZvan±a NOI mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON ~ The mortgaged property w±ll be sold by the Sher±ff to pay off the mortgage debt. If the lender refers your case to ±ts attorneys, but you cure the deZ±nquency before the lender hr±rigs legaZ proceedings against you, you wiil still be requ±red to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, ±f legal proceedings are started against you, you w±ll have to pay all reasonabZe attorney's fees actually incurred by the lender even ±f they exceed $50,00, Any attorney's fees will be added to the amount you one the lender, ~h±ch may also ±nciude other reasonabZe coats, If you cure the default ~±th±n the THIRTY (30) DAY period, you ~ll not be required to pay attorney's fees, PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DE$CRZPTZON DATE 05/30/03 OQO1693340 03/04/03 0P173 012 FL1 Part 3 Pennsylvan±a NO[ 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 PR[OR TO SHERIFF'S SALE - If you have not cured the default Nithin 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 ~lth the foreclosure sale and any other costs connected Nlth the Sheriff's Sale as specified in NPitlng by the PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0~01693340 03/04/03 0P173 012 FL1 Part 3 Pennsylvan±a NOI 'lender and by performing any other requirements under the mortgage. Cur±ng your default ±n the manner set forth ~n th~s notice u~ll restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held Nould be approximately (7) SEVEN Nonths from the date of th±s Notice, A not~ce of the actual date of the Sheriff's Sale will be sent to you before the sale. Of couPse~ the amount needed to cure the default will increase the longer you wait. You may find out at any time exactl~.~hat the required payment or act±on w±ll be by contact±rig 'the lender. 0P173 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0001693340 03/04/03 0P174 029 FL1 Part 4 PennsyZvan±a NOI Re: Loan No. 0001693340 HOW TO CONTACT THE LENDER: Name. of Lender: Address: Attn: Address: Phone Number: Fax Number: PF: 1 SC F Option One Mortgage Corporat±on 7515 Irvine Center Drive Ed Turner Irvine, CA. 92618 800-326-1500, Ext. 46004 949-784-6033 LOAN NO 0Q01693340 Oontact Person: Office hours: DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 03/04/03 0P174 029 FL1 Part 4 Pennsylvania NOI Ferdinand Lim Monday through Thursday 8:00 a.m. to 8:00 p.m. Friday 8:00 a.m. to 5:00 p.m. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale Mill end your oNnership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer-your home to a buyer or transferee Nho Nill assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to oP at the sale and that the other requirements of the mortgage are satisfied. PF: I SC F 2 SC B YOU ~AY ALSO HAVE THE RIGHT TO: LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 05/30/03 0~01693340 03/04/03 0P174 029 FL1 PaPt 4 Pennsylvan±a NOI TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORRON MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HONEVER, 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 LA~SUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH PF: 1 SC F 2 SC B LOAN NO DATE 0@01693340 03/04/03 ACTION BY THE LENDER. LETTER VER REQ 0P174 029 FL1 DESCRIPTION DATE 05/30/03 Part 4 Pennsylvania NOI OP 174 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAN. PF: 2 SC B 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 this statement herein Pa.C.S. Section 4904 authorities. agents. The undersigned understands that is made subject to the penalties of 18 relating to unsworn falsification to Mark"J. Udren, Esquire, ESQUIRE 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Carter Harrison Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DWISION Cumberland Connty NO. 03-2805 MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure upon Defendant(s), Carter Harrison by regular mail and certified mail and in support thereof avers the tbllowing: 1. Process was unable to be served at the then last known address of said Defendant(s) at 313 Lamp Post Lane, Camp Hill, PA 17011, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit B. 3. Said investigation was unable to determine an altelmate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiffpmys and respectfully requests tlhat this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure by regular mail and certified mail upon said Defendant(s), Carter Harrison. MARK J. UDREN & ASSOCIATES BMY;k J.~en, 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Carter Harrison Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DWISION Cumberland County NO. 03-2805 MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good t~th effort" to discover the correct address. Adoption of Walker, 468 Pa. 165,360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Retum of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage Foreclosure. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully reque~,;ts service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and ce~tified mail. MARK J. UDREN & ASSOCIATES By: F~ Mark J. Udren, Esquire Attorney for Plainti[ff 'CASE NO: 2003-02805 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER R. Thomas Kllne ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the wi=bin named DEFENDANT HARRISON CARTER unable to locate Him in his bailiwick. but was He therefore returns the COMPLAINT - MORT FOR~ , , NOT FOUND , as tO the within named DEFENDANT , HARRISON CA~TER 313 LAMP POST LA/qE CAMP HILL~ PA 17011 UN~?,~ TO SERVe, AI~THOUGHNL~4EROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing 18 Service 20 Not Found 5 Surcharge 10 53 00 70 00 00 00 70 So answers: R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this day of Prothonotary PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number, 03050628 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number: Subject: Carter Harrison A.K.A.: CarterH Harrison Last Known Address: 313 LamR Post Lane Camp Hill, PA 17011 Last Known Number: (717) 761-6843 Mellssa Kozma, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of Location Specialist for PlayerS National Locator. 2. On 07/18/2003, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation arS as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER(S);126-38-6120 B. EMPLOYMENT SEARCH: We were unable to verify current employment for Carter Harrleon. C. INQUIRYOF CREDITORS: Creditors Indicated the last reported address for Carter Harrtson ts 3t3 Lamp Post Lane, Camp Hill, PA 17011, with the home number of (717) 761-6843. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The home number for Carter Harrison la (717) 76t.6843, registered to 3t3 Lamp Post Lane, Camp Hill, PA 17011. We called the home number and spoke with a relative who stated Carter Harrison ts living at 313 Lamp Post Lane, Camp Hill, PA 17011. INQUIRY OF NEIGHBORS - NIA INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: Aa of July 16, 2003 the National Change of Address (NCOA) has no change for Carter Harrison from 313 Lamp Post Lane, Camp Hill, PA 1701 t. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Motor Vehicles has Carter Harrison listed at 3t3 Lamp Post Lane, Camp Hill, PA 17011. OTHER INQUIRIES - A. DEATH RECORDS: Aa of July t6, 2003 the 8oclal Security Admlnlatratlon has no death record on file for Carter Harrtson and/or A.K.A'a under the social security number provided. EXHIBIT Ju1-18-03 12:09pm From-Player's Association 636 Z3§ ['558 I-y4~ y.u~4/u~4 r-~q4 B. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC. ): None Found. C. COUNTY VOTER REGISTRATION: The Cumberland County Votem Registration Office ha~ Carter Hs~son listed st 313 Lamp Post Lane, Camp Hill, PA 17011. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: June t958 Players National Looator 113 Old State Road, .S,,uite 104 St. Louis, MO 6302~ Phone: (636) 230-9922 Fax. (636) 230-0668 EXHIBIT B VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are tree and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unswom falsification to authori'ties. MARK J. UDREN & ASSOCIATES Date: Mark J.~U en, 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ' NO. 03-2805 Carter Harrison : Defendant(s) : CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: X Regular First Class Mail Certified Mail Other Date Served: TO: Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 MARK J. UDREN & ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff LAW OFFICES MARK J. UDREN & ASSOCI,4 TES 1040 NORTH KINGS HIGHWAY SUITE $00 CHERR Y HILL, NEW JERSEY 08034 856. 482. 6900 FAX: 856. 482. 1199 FREDDIE MAC PENNS YL VANIA DESIGNATED COUNSEL "PLEASE RESPOND TO NEW JERSEY OFFICE" July 18, 2003 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Re: Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 VS. Carter Harrison Cumberland County C.C.P. No. 03-2805 Dear Carter Harrison: In connection with the above captioned matter, enclosed you will find a copy of the Motion for Alternate Service which was sent for filing on THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Should you have any questions, please contact our office. Sincerely yours, . e,;' sNqui,; ssocI ' ES ~fy Enclosures 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Carter Harrison Defendant(s) JU oo3 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ' NO. 03-2805 .- .- ORDER AND NOW, this ~/~y of ~ , 20~,~, upon consideration of Plaintifffs Motion and the Affidavit o£ Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Carter Harrison, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address o£Defendant(s), Carter Harrison at 313 Lamp Post Lane, Camp Hill, PA 17011 and by posting the mortgaged premises located at 313 Lamp Post Lane, Camp Hill (Hampden Twp.), PA 17011, ~ARK 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff ATTORI~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 Vo Carter Harrison Defendant (s) PRA~CIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: July 29, 2003 MARK J.~~SSOCIATES 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Carter Harrison Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a tree and correct copy of the Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: MARK J. UDREN & ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff L~W MARK J. UDREN & ASSQClATE~e-- 1040 N. KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ ~8034 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. · Print your name and address on the reverse so that we can retum the card to you. · Attach this card to the back of the mallplace, or on the front ff space permits. A. Signature B. Recelvedby(PrintedNeme~. C. DateofDelJvely D. Isdellve~Yaddre~o~fferemfromiteml? [] Yes if YES, enter delNer~ addre~ below. [] No .2. -"" I-I Yes !' ~ 7001 2510 0004 0563 $191 ~1 PS Form 3811, August 2001 Domestic Retum Receipt 2ACP.~ J SHERIFF'S RETURN - CASE NO: 2003-02805 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER R. Thomas Kline duly sworn according to law, says, that he made inquiry for the within named DEFENDANT HARRISON CARTER unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being a diligent search and but was He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 313 LAMP POST LANE CAMP HILL, PA 17011 UNABLE TO SERVE, , HARRISON CARTER , NOT FOUND , as to ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing 18.00 Service 20.70 Not Found 5.00 Surcharge 10.00 .00 53.70 So a n s w e r~s~ j[i~i~/~~ R. Thomas/Kline Sheriff of Cumberland County MARK UDREN 07/18/2003 Sworn and subscribed to before me this ~ day of ~ ~) A.D. Pr(Dtnonot ary ' SHERIFF'S CASE NO: 2003-02805 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER RETURN - REGULAR RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT HARRISON CARTER DEFENDANT , at 1955:00 at 313 LAMP POST LANE CAMP HILL, PA 17011 POSTED 313 LAMP POST LANE a true Sheriff or Deputy Sheriff of who being duly sworn according to - MORT FORE was served upon 4th day of August HOURS, on the by handing to CAMP HILL, PA the and attested copy of COMPLAINT - MORT FORE together with law, , 2003 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.97 Posting 6,00 Surcharge 10,00 .00 42,97 Sworn and Subscribed to before me this ~g~-~ day of .~'003 A.D. So Answers: o8/o5/2oo3 MARK UDREN Deputy Shgriff MAP~ 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Vo Carter Harrison Defendant (s) ATTOP. NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 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: September 9, 2003 MARK J. UDREN & ASSOCIATES BY: ~ark~ Ud~squire ~x~Attorney for Pla~ff JUN, 2~,2003 8:42AM Mail MARK J UDREN & ASSOC 856 4825384 N0.8171 P, 2/9 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 unsworn falsification to authorities. T! tlc: Heother Patterson cc ~mpan¥: Foreclosure :) I II t Carter Harrison Loan #0001693340 MJU #03050628 M~RK 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Vo Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORI~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2805 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND A~SESSMRNT 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 5/31/03 to 9/9/03 Late charges per Complaint From 5/31/03 to 9/9/03 $99,941.16 2,693.82 TOTAL $102,788.01 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 J. UDREN & ASSOCIATES · Mark ~~IRE At~ney f~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Sank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Vo Carter Harrison Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 DATED: TO: August 27, 2003 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOM_ADO 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 ESCUCN_A_R PREUBA ALGUNA, DICTAR SEAVfENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTA/~TES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ',JUN, 23,2003 8:42AM M~il MARK J UDR£N & ASSOC 856 4825384 .... N0,8171 ?. 3/9 NARK J. UDK~N & ASSOCZAT~S BY: Mark J. Udren, Require, Esquire A-~-z'f I.D. NO. 04302 ~040 N. KINGS HIGHWAY, SUITE 500 C~RRY HILL, NJ 08034 8~6-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank National Association, as Trustee for SASCO Mortgage Loan Trust, Irvine, CA 92619-?038 Plaintiff ~NO. 03-2805 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTOP~NEY FOR P~AI~*TIFF COURT OF COMMON PLEAS CIVIL DIVISION' Cumberland County ~ MORT~AG~ FORECLOSUR~ ,/~FFID~IT;~ OF NO~-MILITAR¥ SERVICE TF~E UNDE~SIGNEp bein~ duly ~wO~, ~pose¢ ~d say8 ~hat the ave~e~ts herein are mased upon ~nvest=gatlons ~de and records maintained by ~s ei=heK as Plain~lff 9r~as .se~iqing agent of the Pla%ntiff herean and t~at the above me=enfant(s) are not in the Military or ~ava~ ~e~ice of the United .~tates o~ America or its Allies as de=ineu in the Soldiers and Sa~ors Civzl Relief Act of 1940, as amended, and that =he age and las~ kno~ residence and emplo~ent o~ each Defends= are as follows: De~endant: Carter Harrison ~ Age:. ~er 18, . ' 1/~ Resi=ence: AS captioned ~ov~ ~ ~ ~ / ~/ '~ ~plo~ent: Un~o~ ~~ Sworn to and subs~ribed Company: --before me z~oeaz'y ~ ~ C~rnrn~on # 1277761 Heather Patterson Foreclosure Specialist F~%~RK J. UDP. EN & 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff ATTOR/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO. 03-2805 Defendant (s) : PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 9/10/03 to Date of Sale December 10, E?~D~3 Per diem @$26.41 (Costs to be added) $~. Ol 2~.72 MARK J. UDREN & ASSOCIATES Mark ~RE MAP, K 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, : f/k/a Norwest Bank Mirinesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS ! CIVIL DIVISION : Cumberland County : - MORTGAGE FORECLOSURE :NO. 03-2805 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: ( ) ( ) ( (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 Sec. 4904 relating to unsworn falsification to authorities. 18 Pa. C.So MARK J. UDREN & ASSOCIATES \ Mark J/~n~~ MA~tK ~. UDREN & ASSOCIATES BN= 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 De f endant ( s ) ATTOP/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 03-2805 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, 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, Camp Hill (Hampden Twp.), PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Carter Harrison 313 Lamp Post Lane, Camp Hill, PA 17011 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 in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every 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 313 Lamp Post Lane Camp Hill (Hampden Twp.), PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: September 9, 2003 Mark J.~_ ~y for Pl~lntif~ ~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minl~esota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTOI%NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-2805 NOTICE OF SHERIFF'S SA?.R OF ~RaT. PROPERTY TO: Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Your house (real estate) at 313 Lamp Post Lane, Camp Hill (Hampden Twp.), PA 17011 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 $102,788.01, obtainedby 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 ABLR TO PPRV~,NT THIS SHERIFF'S SAT,R To prevent this Sheriff's Sale, you must take ~e8~ate action= The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900. 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. 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 A~LE TO SAN~ YOU~ P~O~ERTY AND YOU ~VE OTHR~ ~TGHTS EVEN IF THE SHERIFF'S SA?.R DOES TAK~ P?.~CE, 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 PAPF~ TO YOUR LAW~ER AT ONCE. IF YOU DO NOT HAVE A LAWYF~ OR CANNOT A~FO~D O~E, ~OTO OR TELE~HONETH~ OFFIC~ LIh'£~u BELOW TO FIND 0UTWHERE YOU CAi~ GET LEGAL HELP. LAWYE~ P~FEP~AL S~VICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-2166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-2805 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, F/K/A NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR SASCO MORTGAGE LOAN TRUST, 1999-BC4 Plaintiff(s) From CARTER HARRISON (1) You are drrected tn 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 proper~y 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 hirrffher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $102,788.01 L.L. $.50 Interest FROM 9/10/03 TO DATE OF SALE 12/10/03 - PER DIEM ~$26.41 - $2,429.72 Atty's Comm % Due Prothy $1.00 Atty Paid $178.67 Other Costs Plaintiff Paid Date: SEPTEMBER 10, 2003 (Seal) CURTIS R. LONG Prothonotary ~Bv: REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Deputy ~;=%~tK 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Vo Carter Harrison 313 Lamp Post Lane camp Hill, PA ~7011 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 The undersignedihereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he maile~ a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: November 3, 2003 Carter Harrison~ 313 Lamp Post L~ne Camp Bill, PA 17011 I verify that t~e statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of ~8 Pa.C.S. Section 4904 relating to unsworn falsification t0 authorities. Dated: MARK Mark MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CttER.RY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff Carter Harrison Defendant(s) JUl~oo3 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION i Cumberland County : : ' NO. 03-2805 .- : ORDER AND NOW, this ~/~y of .~ , 20~,.~, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Carter Harrison, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Carter Harrison at 313 Lamp Post Lane, Camp Hill, PA 17011 and by posting the mortgaged premises located at 313 Lamp Post Lane, Camp Hill (Hampden Twp.), PA 1701 lp Return Rece pt Fee £ -~'* Here '~i;~;'t'~ N · ' ....... ~ ' ~ .............. I .............. :.~.!..~ ~.~.~ 06'0~ ,[ 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, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof ~ compliance with said Order is attached hereto as Exhibit "B". / ~ All Notices were served within the time ~ts ~et ~orth by Pa Rule C.P. This Affidavit is made subject to the p~nalties pf 1~ Pa.C.S. Sectji<fn 4904 relating to unsworn falsification to aut~Drities/ / ~ Dated: November 4, 2003 ~K J.~/3DREN &~~S BY: Ma~k J. Udren, Esquir~ ~ e 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 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plaintiff Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 DATE: November 3, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE QF~RA~, PROPERTY OWNER(S): Carter Harrison PROPERTY: 313 Lamp Post Lane Camp Hill (Hampden Twp.), PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~/~mberla~ld County Sheriff's Sale on D~r~emb~r~l~, 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. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATT¥ I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 PO Box 57038 Irvine, CA 92619-7038 Plainuiff Vo Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant {s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-2805 Y~kIFui~?~TION OF SERVICE BY CF. RTIFIED MAIL AND_ ~W. GUI.AR MAIL PURSU~O COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: November 3, 2003 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: MARK~~SSOCIATES Mark J. Ud/~n, Esquire MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, ESQUIR~ ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CItERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION Cumberland County · NO. 03-2805 Carter Harrison " Defendant(s) : ORDER AND NOW, this ~/n~y of ~ ,20~,,~, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Carter Harrison, shall be complete when Plaintiff or its counsel or agent has mailed true and correct cop~es of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Carter Harrison at 313 Lamp Post Lane, Camp Hill, PA 17011 and by posting the mortgaged premises located at 313 Lamp Post Lane, Camp Hill (Hampden Twp.), PA 17011~ TRUE COPY FROM RECORD In Tesfimo~ly whereof;' I here unto ~et my hand ~nd,/,he sea:l of said ICourLa~Car~j~) Pa. sap!AOJd Ile~ Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 VS Carter Harrison In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2805 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly swom according to law, states that on September 25, 2003 at 2:32 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Carter Harrison, pursuant to order of court by posting the premises located at 313 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania. Shannon Shenzer, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 11:36 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Carter Harrison located at 313 Lamp Post Lane, Camp Hill, 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 defendant, to wit: Carter Harrison; by regular mail to his last known address of 313 Lamp Post Lane, Camp Hill, PA 17011. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This day of 2003, A.D. Prothonotary R. Thomas Kline, Sheriff Real Esta~jDeputy Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 VS Carter Harrison In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2805 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 Udren. Sherifi's Costs: Docketing 30.00 Poundage 367.20 Posting Handbills 15.00 Advertising 15.00 Mileage 19.32 Levy 15.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Law Journal 293.30 Patriot News 244.54 Share of Bills 28.90 $1055.76 paid by attorney 12/18/03 R,~Thomas Kline, Sheriff Prothonotary Real E~ate Deputy 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, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing stataments as to time, place and character of publication are true. REAL ESTATE SALE NO. 59 Writ No. 2003 2805 Civil Wells Fargo Bank Minnesota, 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 piece or par cel of land, with improvements thereon erected, situate in the Tov~ 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 "H" of the here- inafter 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 de grees. 10 minutes West 113.27 l~et 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 Nos. 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 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 "H' of the plan, the place of beginning. BEING all of LOt No. 10, Block "H', Plan 4 of Pine Brook as recorded in the Cumberland County Record- SW (L~a MORN'TO ANaDr/~;~Y~;'R~I~t;~ be fore me this 31 .day of OCTOBER, 2003_ ~ot~,v /./ NOTARIAr_ SEAL C/ LOIS E. SNYDER. Notary Public Cadisle Bom, Cumberland County My Commission Expires March 5, 2005 wit: BEGINNING at a point on the southwesterly side of Lamp Past Lane at the dividing line between Lot Nos. 9 and 10, Block "H' of the here ina~fter mentioned plan. which point is 627.23 feet In a northwesterly direction from the southwesterly corner of Carriage House Drive and Larnp Post Lane of the plan; thellce by said dividing line South 35 de- grees, I0 minutes West 113.27 l~et 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 Iket to the dividing line between Lots Nos. i0 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 south- westerly side of Lamp Post Lane: thence by salne South 54 degrees, 50 rainutes East 100 feet to a point at the dividing llne between Lots No. 9 and 10. Block 'H' of the plau. the place of beginning. BEING all of Lot No. 10. Block "FI", plan 4 of Pine Brook as recorded in the Cumberland County Record er's Office in Plan Book 15 Page 41. BEING KNOWN AS: 313 Lamp Post Lane, Camp Fiill {Hampden Twp.), PA 17011. PROPERTY ID NO.: 10-20-1848- 108. TITLE TO SAID PREMISES IS VESTED IN Carter Fiarrison, single man by Deed from Carter Harrison and Guo Harrison, husband and wife dated 04/19/99 recorded 05/ 26/99 Book 200 Page 211. I{~arlisle Bom, Cumbeflan¢ · My Commission Expires Ma] 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 ef 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 cimulation, 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 Mamh 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/er 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 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. PUBLICATION ....................... ~ ~ C O P Y sworn ~d ~003 A.D. My Commission Expires June 6, 20C6 NOTARY PUBLIC iVlember, PennsytvaniaAsSOciat~nOf Not~es My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs Te THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 244.54 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav 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.