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Home My WebLink About99-05119II:. 7 ?s Fu Z Norwest Bank Minnesota, N.A. as trustee Under the pooling & servicing agreement Dated 1-1-99 Option One Mortgage Loan Trust 1999-A Assett Backed Certificates Series 1999-A Without Recourse -vs- Michael A. Kaydo, Sr. Lisa M. Kaydo In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-5119 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing 30.00 Poundage 2.40 Law Library .50 County 1.00 Levy 15.00 Postpone Sale 20.00 Surcharge 24.00 Mileage 4.34 Share of Bills 25.08 $ 122.32 Pd by atty 01/06/00 So answers: 9721009, ?. Sworn and subscribed to before me This day of R. Thomas Kline, Sheriff 1999, A.D. rothonotary Real Estate Deputy 5v t Lp-?2 1D0 9D /D/ MARK J. UDREN & ASSOCIATES BY. Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil Defendant(s) AFFIDAVIT PURSUANT TO.RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address MICHAEL A. KAYDO, SR. 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 LISA M.KAYDO 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. MILO CORPORATION 26 COPELAND AVE., PO BOX 210, HOMER, NY 13077 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 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 6 Independence Dr., Mt. Holly Springs, PA 17065 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: October 13, 1999 Mark d?=?ESQ. Attorney for Plaintiff HARK J. UDREN 4 ASSOCIATES BY: Hark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option one Mortgage Loan Trust 1999-A, Asset-Backed Certificate series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on March 1, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 28 EAST MARKET STREET, YORK, PA, to enforce the court judgment of' $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE-OP-OWNER-IS-RIGHTS YOV May BE_BLE TTQ_.2R_FVENTSHIS-SHERIFE! SALE .,: - . ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE :NO. 99-5119 civil N0=CE_QI? SHERIEF!S_SALE OF-REAL PROPERTY TO: MICHAEL A. KAYDO, SR. LISA M. KAYDO 6 Indepedence Drive 6 Independence Drive Mount Holly Springs, PA 17065 Mount Holly Springs, PA 17065 To prevent this Sheriff's sale, you must take immediate action:. 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (609)..482-6900. ' 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. w 3. Yrni 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.) 5 YOU_.MAY STILL.. BE.-ABLE._TO-SAVE-YO.UILPROPERTY_AND_YOU_HAVE QTHER__jIC}HTS EVEN IF-THE-SHERIFF! S_SALE_DOES-TAKE_PLACE_, 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 609-482-6900. 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 609-482-6900. --4. If-the ambuht -due -from -the -Buyer is not pa to the S enff, 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. 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU+DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REPEARAL SERVICV Cumberland County` Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 600-990-9lb8 v A fd -- ALL-THAT-certairr tract-of land-situate-in-thTBorough-of Mount Holly Springs, - -- Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: I BEGINNING at a point in wester.-, dedicated right of j Gno Ui independence Drive at corner of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence alonO said dedicated right of way line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet to a point, fne Place of BEGINNING. BEING KNOWN AS 6 INDEPENDENCE DRIVE PROPERTY TAX PARCEL NO. 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KnYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997 AND RECORDED 4/9/1997 Ii`Z DEED BOOK 155 PAGE 674 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-5119 CIVIL 19 _ CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: Nonvest Bank Minnesota, N.A., as Trustee To satisfy the debt, interest and costs due under the Fooling & Servicing Agrement dated 1-1-99 Option One Mortgage Loan Trust 1999-=A, Asset-Backed Certificate Series 1999-§, J4pr;ppW¢se from Michael A. & Lisa M. Kaydo, 6 Independence Dr., Mt. Holly Springs 17065. (1) You are directed to levy upon the property of the defendant(s) and to sell a}pd uF u.,i i yq$ inga PA_i7065 ( cam - h a at 6 independence Dr legal Ap=nVi }inn ) (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/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If properlyof the defendant(s) not levied upon an subject to attachment isfound in the possession of anyone other than a named garnishee, you are directed to notify hirn/he r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $111,773.45 LL $.50 fran 10/14/99 - 3/1/00 Interest $30 48 par di am %4,267.20 Due Prothy_ $1.00 Atty's Comm % _ Other Costs Arty Paid $116.96 Plaintiff Paid Date: October 28, 1999 REQUESTING PARTY Name Marc J. Udren, Esq. Address: 1040 N. Kings Highway, Ste. 500 Cherry Hill NJ 08034 Attorney for: Plaintiff Telepho4609) 482-6900 Supreme Court ID No 04302 CURTIS R. LONG civil Division PZL-yikAl by' L Deputy On 4uv-&"? s, 1999 the sherift levied upnn the der='?` =" . In?crest in the real property shal +?un'iwsrani ,ci nt , •, ,.A„ an more r tcdl. rte, t?,Id nrll and by this inco.pcrt,.: cl !In S r 795 Ey o ??, n-i ?,e„ 66. Nd ®S 6 h A0N >: • ,iOG j.{Il:itil:' :U:1 30 3113l0 MARK J. O'DREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Assoc., as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. --- Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant (s) COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $109,341.59 Interest per Complaint 2,316.48 From 7/30/99 to 10/13/99 Late charges per Complaint 115.38 From 8/15/99 to 10/13/99 Escrow payment per Complaint 0.00 From N/A to N/A TOTAL $111,773.45 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. J. UDREN & ASSOCIATES Mark J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED I 0 DATE : /U o? 0 q PRO MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant (s) TO: LISA M. KAYDO 6 Indepedence Drive Mount Holly Springs, PA 17065 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County -MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default - Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 609-482-6900 . .. . _r MARK J. UDREN E ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Spring, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE .NO. 99-5119 civil TO: MICHAEL A: KAYDO, SR. 6 Indepedence Drive Mount Holly Springs, PA 17065 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary _X_ Judgment by Default - Money Judgment - Judgment in Replevin Judgment for Possession - Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 609-482-6900 } MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) MORTGAGE FORECLOSURE NO. 99-5119 civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF C,4"f " fo ?210 , A COUNTY OF d P-NW a e- 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: Age: Residence: Employment Defendant: Age: Residence: Employment: Michael A. Kaydo, Sr. Over 18 As captioned above Unknown Lisa M. Kaydo Over 18 As captioned Unknown Sworn to and subscribed before me this / da of?/'?e ]?9 N6> Pub above j AttkCCLCLGI&? Name: / EVELYN ARCHULETA Title: Company: Feredaere Speek4st THERINE J.MILCHAK COMM, f 1205571 ; O : KA NOTARY PUBLIC-CALIFORNIAO ORANGE COUNTY 0 COMM. EXP. DEC. 20, 2002 MARK J. UDREN & ASSOCIATES BY: Nark J. Udren, Esquire ATTY I.D. N0. 04302 1040 H. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999- A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) DATED: October 1, 1999 TO: Michael A. Kaydos Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil 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 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION__IMP_ORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA FOR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA NATRIBUNAL R E (10) DIAS DE ESTA N PODRA I NE ESIDADDECOMPARAR CER U TEDTENICORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 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. NARK J. UDREN E ASSOCIATES BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITS 500 CHERRY HILL, Na 08034 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset- Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) DATED: October 1, 1999 TO: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 IMPORTANT--NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil 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 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACIOILIMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN A30GADO 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 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. iI ' J 1 - n iv uj P N L_ Li" I a S n? 3 V ? ? T M MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE v Michael A. Kaydo, Sr. Lisa M. Kaydo 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 6 Independence Drive Mount Holly springs, PA 17065 Amount due Interest From October 14, 1999 to Date of Sale March 1, 2000 Per Diem 0$30.48 (Costs to be added) MARK J. UDREN & ASSOCIATES Mark kUdren, ESQUIRE ATTORNEY FOR PLAINTIFF $111,773.45 V 4,267.20 } LJ L4 -' L .? (1} !I LL I\ f? L1. O lt) CI CC! CL H L (T al _): LJ l'_J U d D J MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 COURT OF COMMON PLEAS : CIVIL DIVISION :Cumberland County - MORTGAGE FORECLOSURE NO. 99-5119 civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner (s) or reputed Owner(s): Name Address MICHAEL A. KAYDO, SR. 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 LISA M.KAYDO 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 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: ?r R NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. MILO CORPORATION 26 COPELAND AVE., PO BOX 210, HOMER, NY 13077 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. 28 E. MARKET ST., YORK, PA 17401 Domestic Relations Section 100 W. MARKET ST., YORK, PA 17405 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 6 Independence Dr., Mt. Holly Springs, PA 17065 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: October 13, 1999 Mark J. Udren, ESQ. Attorney for Plaintiff ? h C ¢c .rrn f li_ G'1 s ' MARS J. O'DREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MICHAEL A. KAYDO, SR. LISA M. KAYDO 6 Indepedence Drive 6 Independence Drive Mount Holly Springs, PA 17065 Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on March 1, 2000, at 10:00 AM in the YORK COUNTY COURTHOUSE, 28 EAST MARKET STREET, YORK, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (609) 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) on YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff -s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 609-482-6900. 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 609-482-6900. 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 (30) 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL'SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT certain tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 84, Page 90, as follows: BEGINNING at a point in western dedicated right of way line of Independence Drive at corner of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence along said dedicated right of wby line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet to a point, fhe Place of BEGINNING. BEING KNOWN AS 6 INDEPENDENCE DRIVE PROPERTY TAX PARCEL NO. 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. A'ND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997 AND RECORDED 4/9/1997 IN DEED BOOK 155 PAGE 674 ?7 uj n n 62 T- Vic. CI ?? LL: CV F G C" cl? N U IV SHERIFF'S RETURN - REGULAR CASE NO: 1999-05119 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA N A VS. KAYDO MICHAEL A SR ET AL DAWN L. KELL Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT IN MORTGAGE FORECL. was served upon KAYDO MICHAEL A SR the defendant, at 1048:00 HOURS, on the 8th day of September 1999 at 6 INDEPENDENCE DRIVE MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND County, Pennsylvania, by handing to MICHAEL KAYDO a true and attested copy of the COMPLAINT IN MORTGAGE FORECL. together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 4.96 Affidavit .00 Surcharge 8.00 om s ine, e i ?r .?09/09%. UDDREN by / ..pu y eri Sworn and subscribed t before me this i V, day of 19 A.D. r nonotany CASE NO: 1999-05119 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA N A VS. KAYDO MICHAEL A SR ET AL DAWN L. KELL Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT IN MORTGAGE FORECL. was served upon KAYDO LISA M defendant, at 1048:00 HOURS, on the 8th day of September the 1999 at 6 INDEPENDENCE DRIVE MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND County, Pennsylvania, by handing to MICHAEL KAYDO, ADULT IN CHARGE a true and attested copy of the COMPLAINT IN MORTGAGE FORECL. together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge $T47.07 09j09%. UDREN 6.00 So answers: .00 .00 8.00 .. "'ulnas eri by Sworn and subscribed to before me this q I& day ofrD?.- - 19_99 A.D. - i C r on?a? y? epu 5 e i NARK J. UDREN a ASSOCIATES BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Michael A. Kaydo, Sr. a 0 Lisa M. Kaydo : NO. 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant (s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 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 que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE SSTA DEMANDA A UN ABOGADO INNEDIATAMME, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO 3DFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PDEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 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 (609) 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: Public Savings Bank Assignments of Record to: Option One Mortgage Corporation Recording Date: 11/9/98 Book: MISC 594 Page: 159 Assignor: Option One Mortgage Corporation Assignee: Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. Recording Date: LODGED FOR RECORDING Book: Page: 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(a) 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: 6 Independence Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mount Holly Springs COUNTY: Cumberland DATE EXECUTED: 10/29/98 DATE RECORDED: 11/9/98 BOOK: 1496 PAGE: 197 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 Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 7/29/99: Principal of debt due and unpaid $98,898.79 Interest at 11.25** from 3/1/99 to 7/29/99 (the per diem interest accruing on this debt is $30.48 and that sum should be added each day after 7/29/99) 4,602.48 Title Report 250.00 Court Costs (anticipated, excluding Sheriffs Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $-0- and that sum should be added on the first of each month after 7/29/99) _0_ Late Charges (monthly late charge of $57.69 should be added on the fifteenth of each month after 7/29/99) 365.38 Attorneys Fees (anticipated and actual to 5% of principal) 4,944.94 TOTAL $109,341.59 *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. S. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1953, has been sent as required on the date appearing on the copy attached hereto as Exhibit "A", 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 $109,341.59, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mor gaged premises. M rk J. Udren, E QUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT certain tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: BEGINNING at a point in western dedicated right of way line of Independence Drive at corner of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence along said dedicated right of way line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet to a point, the Place of BEGINNING. CONTAINING 0.1735 acre and designated as Lot No. 23 on Plan of Liberty Woods. BEING the same premises which Liberty Associates, by deed dated March 3, 1997 and recorded in Cumberland County Deed book 155, Page 674, granted and conveyed unto Michael A. Kaydo, Sr., and Lisa M. Kaydo, Mortgagors herein. E,ceNU RUG-06-1999 11:25 June 03, 1999 Michael A Kaydo Lisa M Kaydo 6 Independence Drive Mount Holly Springs, PREMIER SERVICES 06 OOIVEN uomoAOe Qonro??non PA 17065 Re: Property: 6 Independence Dr Mount Holly Springs PA 17065 Loan No.: 121302-4 ACT 91 NOTICE PLEASE READ THIS NOTICE 949 790 8244 P.03i06 CERTIFIED RECEIPT NUMBER IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information, call the Pennsylvania Housing Finance Agency at (717) 780-3800 or (800) 342-2397 from within Pennsylvania. La notificacion adjunta es de suma importancia pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion, obtenga una traduccion inmediatamente llamando a esta agencia (Pennsylvania Housing Finance Agency) sin costo alguno al numero mencionado arriba. Usted puede ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program", el cual puede salvar su casa de Is perdida del derecho a redimir su hipoteca. OP059 EXHIBIT A COgRO RL AT6 ORRIC 6H Q AOA • IgVING CALIRORNIA V901Q •.O10% OvOA. I/IIVIN! ? CALIVORNIA OQQ l0.T0?1 Q n e I. P l ?? O d Ti m P II r' . ?' ?? I1il' • QOQ.9'le.11100 • RA ,,NE "0.700.8+62 QII.IIII AUG-06-1999 11:26 PREMIER SERVICES 100 OriOT?IQN June 03, 1999 .....°Oe" Michael A Kaydo Lisa M Kaydo 6 Independence Drive Mount Holly Springs, PA 17065 Re: Property: 6 Independence Dr Mount Holly Springs PA 17065 Loan No.: 121302-4 ACT 91 NOTICE 949 790 8244 P.04i06 Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3,091.96. That sum includes the following: Monthly Payments: Late Charges: NSF Fees Due: Other Fees Due: Less Suspense Amount: 3 Months a $ 961.55 3 Months @ $ 961.55 2,884.65 192.31 15.00 .00 .00 O?J 3qp SL $ 3,091.96 TOTAL,DUE: You may be eligible for financial assistance that will prevent fore- closure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act") You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (33) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (33) days. OP059, Page 1 of 3 CORPO qA>C. OT"Ce9 - - A-A - MV1Ne . CALl1.ORNIn Oae. e . V.O. eOX °>en? . ,gy,Ne .CALIFORNIA Yae 1e.>°?1 ReCej'le,) Mlle ,Aig. h.•? j:'jF!??'-e°°.ave.•eee. ?..xume a.e.>°e.e rea muarn AUG-06-1999 11:26 PREMIER SERVICES 949 790 6244 P.05i06 E <<NU 00 OPO'T?QN OP059, Page 2 of 3 Loan No. 121302-4 Act 91, Continued If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Authority. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, fore- closure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application be accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your appXi- cation. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. GOAPORwTI OPPI0 9B.°wpw.IRVINE.CALIPORNIA°°Ol°.P.O.BOX p>MI.IRVINE.CAIIPOFlNIA Q ??c?i,d I T II? AlJ d. ?.u I:'I?',II. eo°.aa °.1e°°-PA%LINE V. °.>V°.wlw M= RUG-06-1999 11:26 PREMIER SERVICES 949 790 8244 P.06i06 OP059, Page 3 of Loan No. 121302-4 Act 91, Continued 00 OP??rxON The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Offfice Box 8029, Harrisburg, PA 17105. The telephone numbers are: (717) 780-3800 or (800) 342-2397 (toll-free number). Persons with impaired hearing can call (800) 342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely, Jose Juarez Loan Counselor 1-800-326-1500, ext. 8261 GOAVO RecOF F.CaiR.n?1n? gv?NP.rt.? OBNIA ¢II¢1• P.O. BOX 6>WI .IgVINE CI. LIPOXN.w ¢¢O?P>011 ?.piv?Ij (??a111?1.,4,.p I. ?III?M100.9'JM1.IM1OO.FAXLINEW¢.>¢O.e1G¢ ?1?11 V E R I F I C A T I O N 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. M Ark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES (E) LO i '-- r: -? <r ?o c LLr;... N - V _i? 'vc) Vr MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 856-482-6900 Norwest Bank Minnesota, COURT OF COMMON PLEAS National Association, as ;CIVIL DIVISION Trustee Under the Pooling and Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option MORTGAGE FORECLOSURE One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo :NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $111, 273_.45 Interest From Oc.Y._ober___14,__199.9 __23_,409_._54 to Date of Sale September-5,_20-0-1 Per diem ®$33.78 (Costs to be added) MARK J. UDREN & ASSOCIATES Mark J\, Udren, ESQUIRE ATTORNEY FOR PLAINTIFF - AL-L-FHAT-certain tract-of land Situate in the Borough-of mauht Holly Springs, -- -- Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: BEGINNING at a point in western dedicated right of way line of Independence Drive at _ comer of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence .along said dedicated right of way line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet to a point, rtr= Pace of 9_GINNING. BEING KNOWN AS 6 INDEPENDENCE DRIVE PROPERTY TAX PARCEL NO. 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997 AND RECORDED 4/9/1997 IIJ DEED BOOK 155 PAGE 674 2 0 UILI ?;? n U J n"< 1'n O V ?VY.\YL 1V. yy.?Y• VY.I.YJY,•VL/ VI\\1 ?t/YL/Lt/LL?ILL?,II.SJVI\\\ y A ¢6'Y L Vl L Bankruptcy Docket Report 199-05526 (Harrisburg) KAYDO, MICHAEL ANGELO, SR and KAYDO, LISA MARIE Docket items entered between 01/01/1931 and 03/15/2001 Filing Date No . Docket Entry 12/28/99 1 VOLUNTARY PETITION under Chapter 7 and Mailing Matrix [EOD 12/29/991 [KZ] ENTERED IN ERROR WRONG DOCKET CODE USED [EOD 01/25/001 [KZ] VOLUNTARY PETITION under Chapter 13 & Mailing Matrix (EOD 01/25/00] [KZ] 12/29/99 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 01/13/00 Re: Item # 1. (Complied] [EOD 12/29/991 (KZ] 01/19100 3 CORRESPONDENCE to Attorney allowing until January 25, 2000 to file missing documents. Re: Item # 2. (EOD 01/19/001 [CA] 01/24/00 4 Schedules and Statements (Everything filed except Plan & Plan Summary) Re: Item # 2. (EOD 01/25/001 [KZ] 01/27/00 5 Ch. 13 Plan Re: Item # 2. (EOD 01/28/00] [CA] 02/17/00 6 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. [EOD 02/17/00] [CA) 02129100 7 OBJECTION to Claim #2 of OPTION ONE MORTGAGE CORPORATION asserting arrearsges in the amount of $13,878.86 filed by DEBTORS (EOD 02/29/00] [SP] 02/29/00 8 ORDER fixing hearing date on 04/19/00 at 11:30 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG PA. 17108 Re: Item # 7. [EOD 02/29/00] [SP] 03102100 9 CERTIFICATE of service Re: Item # 8. [EOD 03/02/001 [SP) 03/24/00 10 341 meeting held. [EOD 03/24/001 (CA] 04/10/00 11 ORDER Confirming Plan [EOD 04/10/00] (SP] 04/19/00 12 PROCEEDING MEMO re hearing not held. Matter continued generally pending a stipulation to be filed. Re: Item # 7. [EOD 04/19/00) [JGJ 709/00 13 MOTION for relief from stay filed by KUHNS-HARNISH FORD, INC. t/a West Shore Kia. (Pd . $75.00, Rec.#560993) [Disposed] [EOD 08/09/00] [SPj CERTIFICATE OF NON-CONCURRENCE [EOD 08/09/001 (SP] 08/09/00 14 ORDER that answers aredue on 08/29/00 Re: Item # 13. [EOD 08/09/00] (SP) 08/14/00 15 CERTIFICATE of service Re: Item # 14. [EOD 08/15/00] [SP] 09/12/00 16 MOTION for default judgment Re: Item # 13. [Disposed] (EOD 09/13/001 (SP] 09/13/00 17 ORDER granting default judgment Re: Item # 16. [EOD 09/13/00] (SP] ORDER granting relief from stay Re: Item # 13. [EOD 09113/00] [SP] 09/27/00 18 MOTION to reconsider Order filed by DEBTOR Re: Item # 17. [Disposed] (EOD 09/27/001 [SP] 09/28/00 19 CORRESPONDENCE SETTING PHONE CONFERENCE on 10/25/00 at 03:00 P.M at . FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG PA. 17108 Re: Item # 18. [Rescheduled] (EOD 09/28/001 [SP] 10/02/00 20 MOTION for relief from stay filed by OPTION ONE MORTGAGE CORPORATION (Pd. , , $75.00, Rec.#562501) [Disposed) [EOD 10/02/00] (SP] REQUEST for admission (EOD 10/02/001 [SPj /nPacer?ExecThis=docket&puid=00984671313&case_no=1999-05526&office=l &DktTypt03/15/2001 10/02/00 21 ORDER that answer, arcdue on 10/23/00 Re: Item # 20. [EOD 10/02/001 [SP[ 10/05/00 22 ANSWER by KUHNS-HARNISH FORD, INC. Re: Item # 18. [EOD 10/06/00] [JC] 10/10/00 23 CERTIFICATE of service Re: Item # 21. [EOD 10/10/001 [KL] 10/23/00 24 Praecipe/Withdmw Re: Item # 18. [EOD 10/23/00] [SP] This entry cancels the previous due date. Re: Item # 19. [EOD 10/23/001 [SP] APPROVED by the court. Re: Item # 18. [EOD 10/23/00] [SP] M 10/31/00 25 CORRESPONDENCE SETTING HEARING on 12/19/00 at 11:30 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 22. [EOD 10/3I/00] [SP] 12/26/00 26 INTERIM Order setting terms and conditions Re: Item # 20. [EOD 12/26/00] [B W] 02/12/01 27 CERTIFICATE OF DEFAULT Re: Item # 26. [EOD 02/12/01] [SP] 02/12/01 28 ORDER granting relief from stay Re: Item # 20. [EOD 02/12/01] [SP] 03/12/01 29 STIPULATION by Parties. Re: Plan arrears. [EOD 03/12/01] [SP] APPROVED by the court. [EOD 03/(2/01] [SP] A ervice enter - ransactton ecetpt T 111 03/15/2001 t AT T EKIR:ble : mu '!tent 'o e: oc et 'ase Number: : 12.? ost: Need he lp? Try the PACER User's Guide OPacer Service Center ../nPacer?ExecThis=docket&puid=00984671313&case_no=1999-05526&offrce=l&DktTyp 03/15/2001 7:J LI Ia - o u MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, COURT OF COMMON PLEAS National Association, as :CIVIL DIVISION Trustee Under the Pooling and :Cumberland County Servicing Agreement, dated as • of January, 1, 1999, Option MORTGAGE FORECLOSURE One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo :NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK REN 6, ASSOCIATES Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF e w ,9• u :S ?' - - ;_> - ?,. J '?? C9 ... ? ?-i -? ?I?J C I12 _) ?. ?? V 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 Norw t B k ATTORNEY FOR PLAINTIFF ea an Minnesota, COURT OF COMMON PLEAS National Association, as CIVIL DIVISION Trustee Under the Pooling and Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option :MORTGAGE FORECLOSURE One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo : NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address MICHAEL A. KAYDO, SR. 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 LISA M. KAYDO 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. MILO CORPORATION 26 COPELAND AVENUE, P.O. BOX 210, HOMER, NY 13077 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 SQUARE, CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 7. Name and address o f 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 6 Independence Drive, Mount Holly Springs, PA 17065 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: June 6, 2001 Ma k J. Udren, ESQ. Attorney for Plaintiff J/ U MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, 'COURT OF COMMON PLEAS National Association, as :CIVIL DIVISION Trustee Under the Pooling and .Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE_OF_SHERIFF!S_SALE._OF_.REAL_PROBERTY TO: MICHAEL A. KAYDO, SR. LISA M. KAYDO 6 Indepedence Drive 6 Indepedence Drive Mount Holly Springs, PA 17065 Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriffs Sale on September 5, 2001, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE_OF._ONNER.'_S_RIGHTS YOU_MASLBE-ABLETO_PREVENT THIS__SHERIFF! S_SALE To prevent this Sheriff Is Sale, you must take immediate action:. 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: .(8561_.482-69.0.0. 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 TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 r its ?- N Gi (Jj ?J n. ?:J MARK J. UDREN & ASSOCIATES FF BY: Mark J. Udren ATTORNEY FOR PLAINTIFF ATTY I.D. No. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 855-482-6900 Norwest Bank Minnesota, COURT OF COMMON PLEAS National Association, as :CIVIL DIVISION Trustee Under the Pooling and :Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo :NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff fIs 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 Sheriffs 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 "Bit. 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 2, 2001 MARK J. UDREN & ASSOCIATES BY:_z 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 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as f ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland county o January, 1, 1999, Option MORTGAGE FORECLOSURE One Mortgage Loan Trust 1999- A Asset-B k ac ed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address MICHAEL A. KAYDO, SR. 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 LISA M. KAYDO 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. MILO CORPORATION 26 COPELAND AVENUE, P.O. BOX 210, HOMER, NY 13077 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 SQUARE, 13 N. HANOVER ST., CARLISLE, PA 17013 Domestic Relations Section 1 COURTHOUSE SQUARE, 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue 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 6 Independence Drive, Mount Holly Springs, PA 17065 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: AUGSUT 2, 2001 Mark J. Udren, ESQ. 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 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) DATE: June 12, 2001 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF RRAT. PROPERTY OWNER(S): MICHAEL A. KAYDO, SR. & LISA M. KAYDO PROPERTY: 6 Independence Drive, Mount Holly Springs, PA 17065 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on September _a,-DOM , at 10:00 AM, at the COURTHOUSE, COMMISSIONER HEARING ROOM, 2ND FLOOR, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A 0 W V tL ? ? ?F E F ? 1 1 H ?? ? 9 ? yi vjLL C]ig ? ? 8 ??$ , ? V1 ? p ?y yy'ssss ?pp y Fpi u1313 S y? a: LL [9 e?f ?? L ` p yCY E E s Y to ? ??d{{ 5 y8 > Feyyj 6 F f } Sp ay O t N IM i A E C £u'S a ? pO o w W a)? N z 4 >w g,o. Ac =UU v Q ? J p y OQ i S` K O 8 ?r'l Y 5 H 6 W pb p m w m o C G X m S? H J pH 7' O = N Z we ?y~b lo g m ? C d 3 a 0U O , ~ ? ? ma m a e o? O 9 ' F y N ' m W Q ?N f 7 y yR' f' f7 z 6 b n m U N pYQ W W N ; A ? ? WU ZO Z zo p G LLO m y z~2 a " i W s q ? 9x4 F and a Q as ' LL, OZ=Z Wy o N? LLY Fw, Q ww 2 ? O? Q OO a0 k ;00_j ? cO Z y? U r.• ? ao NS 6 ]7Z= ??? K U 002 W???``` Z ow f QN 2a =F iz a a y= zz a O O H0 z o om = ?G -C ® zz W a o Z p m \ ? g a m Q Y b a f u E 3 jj , ay? I C V N c a N M < N W n m W 10- c a e a° A m O Y C m 3 m CL M v m m CL O U a N 7 f 9i W Z 2 a ti n m M O a r ? c CD C', " L . )d m n LLI ? F O cv U Norwest Bank Minnesota, National In The Court of Common Pleas of Association, as Trustee Under the Pooling Cumberland County, Pennsylvania And Servicing Agreement, dated as of Writ No. 1999-5119 Civil Term January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse VS Michael A. Kaydo, Sr. and Lisa M. Kaydo 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. Sheriffs Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library Prothonotary 1.00 Share of Bills 25.66 Mileage 10.40 Levy 15.00 Advertising 15.00 Certified Mail 2.30 Poundage 13.17 Postpone Sale Law Journal 288.65 Patriot News 225.60 $671.78 Sworn and subscribed to before me This ,y r day of dT 2001, A.D. L„ Prothonotary paid by attorney 8/31/01 c?aa?re? R. Thomas Kline, Sheriff Real Estate Deputy i,A CK333W1j1. 4W II&A 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 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ' ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael A. Kaydo, Sr. Lisa M. Kaydo :NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999,, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner (s) or reputed Owner(s): Name Address MICHAEL A. KAYDO, SR. 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 LISA M. KAYDO 6 INDEPENDENCE DRIVE, MT. HOLLY SPRINGS, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. MILO CORPORATION 26 COPELAND AVENUE, P.O. BOX 210, HOMER, NY 13077 R S. 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 SQUARE, CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue 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 6 independence Drive, Mount Holly Springs, PA 17065 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: June 6, 2001 Ma k J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: • Mark J. Udren, Esquire ATTY I.D. N0. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. Michael A. Kaydo, Sr. Lisa M. Kaydo NO. 99-5119 civil 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) NOTICE OE-SHERIFLS_SALE-D+-REA7-EROpERTY TO: MICHAEL A. KAYDO, SR. LISA M. KAYDO 6 Indepedence Drive 6 Indepedence Drive Mount Holly Springs, PA 17065 Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriffs Sale on September 5, 2001, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. YOU M81?F NO=E OF 0W=R_5_RIGHTS ..._AnLF TO 2RFVER THTR SHx•RIFFLC GALE To prevent this Sheriffs sale, you must take immadiate_ac_tion: 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: _L.flS_6)_4B2=fi94.0,. 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_ S.TILL_ BE. ABLE -TO SAVE.-YOUR .PROPERTY__AND_YOU HAVE OTHER_RIGHTS EVEN--IF-THE _SHERIFF! S_. SALE_.DOES__TASE__PLACE.. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 - AL-I_ FHAF-certairr tract-of land situate in the-Borough-of Mcuht Holly Springs-- -- Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: BEGINNING at a point in western dedicated right of way line of Independence Drive at comer of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence.along said dedicated right of way line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet to a point, f- F-= Pace of 9EGINNING. BEING KNOWN AS 6 INDEPENDENCE DRIVE PROPERTY TAX PARCEL NO. 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997 AND RECORDED 4/9/1997 IIJ DEED BOOK 155 PAGE 674 WRIT OF EXECUTION artd/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 99-5119 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION • LAW TO THE SHERIFF OF CUMBERLAND - COUNTY: To satisfy the debt, interest and costs due Norwest Bank Minnesota, N.A. , as Trustee Under Pooling &_Servicinq Agreement, dated as of 1/1/99. 0otion r) P rr,R., ?. a from Michael A. Kaydo, Sr. and Lisa M. Kaydo, PA 17065. -- "" "--'--------- ------ DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Restate located at 6--IndeWmd P^^?---e-n?t-Holly. %=ings_-PA-12Q-65?. (See attached legal desciption ) (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/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If propertyof thedefendant(s) not levied upon an subject to attachment is found in the possession olanyone 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. AmounfDue $111,773.45 Interest 10/14/99 - 9/5/01 $23,409.54 1em Atty's Comm % Atty Paid $251.78 Plaintiff Paid Date: June 12, 2001 REQUESTING PARTY: Name Mark J. Udren, Esquire Address: 1040 N Kings Highway, Ste 500 Cherry Hill NJ 08034 Attorney for: Plaintiff Telephone: (856) 482 6900 L. L. Due Prothy Other Costs CURTIS R. LONG Prothonotary, Civil Division by: ,. t (Lti Deputy $1.00 Supreme Court ID No. 04302 REAL ESTATE SALE No. 3c on ,To vij-- 131 7-001 the sheriff levied upon the oelenaao. Interest In the real property situated in X1. /ha TSFri? S .&ruuc't ? Cumberland County, Pa., knr?., mbered as: ? h he aha- k. . fit. Ifu %Y rrn Sand more tur; ,tt FxhLWt "A" W w;; this writ and by this reif, Cbft'',(V nL /J. X20/ ???? y4? .I<zerr`ff 0 a v, W . ?J THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 I,til 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 Patrlot-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 dally and/or Sunday/ Metro editions which appeared on the 24th and 31st day(s) of July and the 7th day(s) of August 2001. 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 verity 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 COPY S A L E 830 hbi 21st d. A.D. ift' TerrytaDUry, sbu% DaeupMn Co NarhwKn Coun rlf` My C0lmYeslon Explna Jum6, NOTARY PUBLIC 30 ManMer, Pannsytvan!a AS600e111)! d NOW" My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 '"A Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached n hereto on the above stated dates $ 224.10 Probating same Notary Fee(s) $ 1.50 d u!wte in lk Total $ 225.60 yhn timnow; w aN uw in Ah A Phil by L'I 98UN. ., ?urem6er&. Publisher's Receipt for Advertising Cost let lne in ?PlmiBPok ra. Page .90, a ., publisher of The Patriot-News and Ilte Sunday Patriot-News, newspapers of general 'v +, punt lawwem dcd?md 3e receipt of the aforesaid notice and publication costs and certifies that the same have By .......................................... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) as James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 Lhta 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 dally and/or Sunday/ Metro editions which appeared on the 24th and 31st day(s) of July and the 7th day(s) of August 2001. 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 ............................ ,........................................... .......... .............. COPY SALEN30 ?lNdt?No?tl P6 1r' .90 Nai?iN 9?ink?AlNri?NO1?, ,?r,RaLM aMt'IgnO . AOnemMdtllMe,. oell n.A, lita Mees LAW L. 21 st A.D. NOTARY PUBLIC Memoer, Pennsylvania AsfouaWn a WON My commisslon expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs k + "• ' To THE PATRIOT-NEWS CO., Dr. a+ J? For publishing the notice or publication attached ftM hereto on the above stated dates $ 224.10 Aie 3 ? Probating same Notary Fee(s) $ 1.50 A(1 {Ht1T?ERTgllmo[I?adwua in the Total $ 225.60 Dsni"idw&~1989 Publisher's Receipt for Advertising Cost 64• F* 90• U publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general weeacni d4casd Is receipt of the aforesaid notice and publication costs and cert ifies that the same have ra% 19 to By ................................................. loom Cott to a pant in wcwom of way. line Of lM;pcn&.:. M@ ui I dalieaa l ngM of way axe'=saah l9 ds-pray wnls Fie 75.59 key to a point. W1Io. a 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 : Es. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, 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, Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. i" Roger . Morgenthal, Editor REAL ESTATE aAr.E NO. 80 - SWORN TO AND SUBSCRIBED before me this Writ No. 1999-5119 Civil __L _day of AUGUST. 2001 Nomest Bank Minnesota. N.A. as Trustee Under Pooling & Servicing Agreement ' dated as of 1/ 1/99 . Option One Mortgage loan ary ew Trust 1999-A d C tifi A B k LOIS E. S ' E PuMle sset- ac e er cate 9 9 A h Cartislet3e Series 1 - out recourse 9 wit k? CWW960? Ellokm Unh+a mvw VS. Michael A. Kaydo. Sr. and Lisa M. Kaydo PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, 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; JULY 20, 27, AUGUST 3, 2001 Afffant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Roger &4. Morgenthal, Editor REAL. EST.'ATS 8AI8 NO. 90 Writ No. 1999-5119 Civil Nolwest Bank Minnesota. N.A. W Trustee Under Pooling & Servicing Agreement dated as of 1/ 1/99. Option One Mortgage Loan Trust 1999-A Asset-Backed Certificate Series 1999-A without recourse Vs. Michael A. Kaydo, Sr. and Lisa M. Kaydo Ally.: Mark J. Udren ALL THAT certain tract of land sit- uate in the Borough of Mount Holly Springs. Cumberland County. Penn- sylvama, bounded and described In accordance with a Plan prepared by Walter N. Heine Associates, Inc.. dated December 8. 1989 and re- corded In Plan Book 64. Page 90, as follows: BEGINNING at a point in west- em dedicated right of way line of Independence Drive at corner of I.ol No. 24: thence along Lot No. 24. South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point: thence along Lot No. 18. North 19 degrees 32 minutes. 29 seconds West 75.59 feet to a point common to Lots 18, 19. 22 and 23: thence along Lot No. 22. North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way ]Inc of Independence Drive: thence along said dedicated right of way line of Independence Drive. South 19 degrees 32 min- utes 29 seconds East 75.59 feel to a Point, the place of BEGINNING. BITING KNOWN AS 6 INDI:PEN- DI:NCF. DRIVE. PROPERTY TAX PARCEL NO. 23-Sri-21110 1 1:1. TITIA: TO SAID PRP.MISES IS v-.s'BI{D IN MICHAEL A. KAYDO. SR. AND LISA M. KAYIX). I [IS Witl.- AS'11{NANTi BY'1I[K F.N1ll?r'lll-,S BY DINT) FROM I.I111;BTT ASSO- C.IATEIS DATED 3/:1/ 1997 AND RECORDED 4/9/1997 IN DEED ROOK 155 PAGE 674. SWORN TO AND SUBSCRIBED before me this ---L -day of AUGUST, 2001 LOIS E. SNYMER, Notery puW Carlisle 9Qro, OXW& lltd Can f lrtlkdo 1 E0w MWd, a, s F.. I r' t I? 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. Roger M. Morgenthal, 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, Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ?T Roger Al. Morgenthal, Editor REAL ESTATE SAM NO. 30 Writ No. 1999-5119 Civil Nomest Bank Minnesota. N.A. as Trustee Under Pooling & Servicing Agreement dated as of 1/1/99. Option One Mortgage Loan Trust 1999-A Asset-Backed Certificate Series 1999-A without recourse vs. Michael A. Kaydo, Sr. and Lisa M. Kaydo Atty.: Mark J. Udren ALL THAT certain tract of land sit- uate In the Borough of Mount Holly Springs. Cumberland County, Penn- sylvania, bounded and described In _ accordance with a Plan prepared by 1 Walter N. Heine Associates, Inc., dated December 8, 1989 and re- corded In Plan Book 64. Page 90, as follows: BEGINNING at a point in wrst. em dedicated right of way line of Independence Drive at comer of Lot No. 24; thence along Lot No. 24. South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point: thence along Lot No. 18, North 19 degrees 32 minutes, 29 seconds West 75.59 feet to a point common to Lots 18. 19. 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive: thence along said dedicated right of way line of Independence Drive, South 19 degrees 32 min- utes 29 w.couds East 75.59 feel to a point. the place of UEGINNING. BEING KNOWN AS 6 INDEIPE.N DENCI: DRIVE. PROPERTY TAX PARCEI, NO. 23:15-2316-1 13. TITLE TO SAID PREMISES IS VESTED IN MICHAEI. A. KAYDO. SR. AND LISA M. KAYDO. I HS WIFE, AS 11iNANTS BY THE EINTTRL" nES BY DEED FROM LIBERTY ASSO- CIATES DATED 3/3/ 1997 AND RECORDED 4/9/1997 IN DEED HOOK 155 PAGE 674. SWORN TO AND SUBSCRIBED before me this --L -day of A T 2001 1 j, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil SUGGESTION-OF- BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Michael A. Kaydo Sr. has filed Baikruptcy in the Middle District of Pennsylvania on August 9,2001, Bankruptcy No. 01-04367. Mark J. ren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff , ,: . ?_ ;•: :; ., ' ,, ? ?? 1. ?) MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, 'COURT OF COMMON PLEAS National Association, as ;CIVIL DIVISION Trustee Under the Pooling and :Cumberland County a i i erv c ng Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff MORTGAGE FORECLOSURE V. Michael A. Kaydo, Sr. NO. 99-5119 civil Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Please Issue Writ of Execution in the above matter: Amount due $111 773.45 Interest From Qct_ober 14, X992 40,484.16 to Date of Sale June ll 2003. Per diem 0$30.28 (Costs to be added) $ MARK J. UDREN & ASSOCIATES M k J. Udren, ESQUIRE ATTORNE OR PLAINTIFF v S ?n A ci4 v W? y W WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MORTGAGE LOAN TRUST 1999-A. ASSET- BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, 6 INDEPEDENCE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 (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 gamishee(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. Amount Due $111,773.45 L.L. Interest FROM OCTOBER 14,1999 TO DATE OF SALE JUNE 11, 2003 PER DIEM C $30.28 - $40,484.36 Arty's Comm % Due Prothy $I.00 Arty Paid $938.56 Other Costs Plaintiff Paid Date: MARCH 12, 2003 CURTIS R. LONG Prothonotary (Sea)) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856482-6900 Supreme Court ID No. 04302 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, COURT OF COMMON PLEAS National Association, as = CIVIL DIVISION Trustee Under the Pooling and :Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 MORTGAGE FORECLOSURE Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 NO. 99-5119 civil Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. HARK UDREN & ASSOCIATES a k J Udren, ESQUIRE ATTORN -FOR PLAINTIFF Ll MARK J. UDREN & ASSOCIATES 1 BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION :Cumberland County :MORTGAGE FORECLOSURE Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) NO. 99-5119 civil AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Milo Corporation 26 Copeland Avenue, PO Box 210 Homer, NY 13077 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, Bureau of Compliance, Dept. 280946 Department of Revenue 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 6 Independence Drive Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: February 26, 2003 i rk J. Udren, ESQ. ttorne for Plaintiff it 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 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff 99-5119 civil NOTICE O+LSHERIFF'S-SALE_OF REAL PROPERTY V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) TO: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE 'NO Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on June 11, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE-OF _OWNER_'SRlru_'_ra YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff Ia sale, you must take immadiata_actioaa 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: _L8a61_482=63.0.0. 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 atop 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.) Y_O.II_MAY_STILL_BE_ABLE. TO SAVE YOUR PROPERTY_.AND..YO.II_HAVE_OTHER_RIGM EVEN ILTHH-SHERIFF-' S..SALE _DOES_.TAFE_PLACE.. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OA CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE ` Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 -_ ?' :; ?. ? - ? ?. I,.... -? ??.t - ). . - ?;'.: ._ j ?.t ?i) i(.J li!? ? ?- ''7 .7 -' _. rJ L. N „ IN THE UNITED SPATES BANKRUPTCY COURTFOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Michael A. Kaydo, Sr I CHAPTER 13 ' Lisa M. Kaydo CASE NO. 01-04367 Norwest Bank Minnesota, National 11 U.S.C. SEC. 362 Association, as Trustee Under the Pooling and .Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A, without recourse Movant r.- VS.. Michael A. Kaydo, Sr Lisa M. Kaydo Debtor(s) .. and Charles J. DeHart, III, Esquire T - ;i nrstee .: RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY. AND NOW, this ? / • Fn day of YGfG Y , 20? 3 itisORDERFD AND DECREED tha :' The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.C. 362, is modified with respect to premises 6 Independence Drive •.Mount Holly Springs, PA 17065 1 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action, for enforcement of its right to. possession of said premises. The relief granted by this order shall survive the conversion of this bankruptcy case to a.case under any other. Chapter of the Bankruptcy Code. AM TEAT CERTAIN TRACT OF LAND SITUATE IN TEN BOROUGH or MOUNT ROLL: BYRIEGS, ' .. CUXBRHLARD COUNTY, P$NNSYiVANIA, HOUNDED AND DESCRIRRD.IN ACCORDMC39 WITH A.PLAN, j PREPARED 137 WALTER N. NEWS ASSOCIATES, INC., DATED DECEMBER 8, 1989 AND RECORDED . ]N PLAN HOOF 64, PAGE. 90, AS FOLLOWS . szonarma AT A POINT IN NESTERS DEDICATED RIGHT-Or-WAS LIEF 07-I1mEPffi®ERCE DRIV= . AT COMM Or. LOT 110. 241 THENCE ALONG LOT NO. 24, 809TH 70 DEGREES 27 MIDOTES 10. •'SECONDS WEST 100.00 RM TO A POINT; TERM ALONG LOT NO, 18,:NORT8 19 DROURS 32 xmmTRS 29 SECONDS WEST 75.59 FEET TO A POINT.CONNON To LOTS 18, 19, 22 AID 2111 'TREMOR ALONG LOT NO. 22, NORTE 70 DEGREES 27 MINUTES 10 SECONDS EAST 100.00 FEET '*.-TO A POINT IN WESTERN DEDICATED RIGHT-Or-WAS LINE Or INDEPERDERCE DRIVE; TRENCH ALONG SAID DEDICATED RIGHT-OF-WAT LIRE Or INDEPENDENCE DRIVE, 809TH 19 DEGREES 32 •. MINOTSS 29, 8ECOED8 EAST 75.59 nn TO'A, POINT, THE PLACE OF HEG]]Unw. .90STAINZNG'O.173$ ACRE AND DESIGNATZD AS LOT NO. 23 Oil PLAN Or LIBERTY WOODS. . SUBJECT TO. THE FOLLOWING. REBTRICTIONSi . 1. ALL.RESIDESTIAL STitucTDREs SHALL EAvE A MINnmY or 11o0,SQUARN FEET OF rnM28H>m,. •. LIVING FL-002 AREA. . ..2. : No MDBILE HOMRB BRIMS, HE, PLACED ON LNNY LOT I8 TRIS svEDmSION. . . 3..: No DUMDIIING OR BTOCm?ILING OF MATERIALS OR OTHER ITEMS SHALL BEPmm Trap NOR .. T HE ACCUMULATION Or ANY JUNE OR UNLICENSED VEHICLES ON ANY MAT WITHIN SAID SUROMSION. '.4. TREE REMOVAL SHALL HE XZPT To A MIIPaDM To PERMIT THE CONSTRUCTION OF A PRIM M "'RESIDENCE AND' GARAGE.. - - . 5 LOT OWNERS 'SHALL HE RESPORSNULR FOR THE INSTALLATION AND X&xxTz ONCE Or A SIDENALE ALONG'7HR',8T8H3P FRONTAGE OF T882Y LOT. BIDENALE CONSTRUCTION NOT HE ...,..,Cc=LETED WITHIN ONE YEAR OF LOT PURCRASR'. . T88 SIDEWALK MUST HE.COINSTRIICPED *A9 PER , THE SPECIFICATIONS OF THE APPROVED PLAN OF SUBDIVISION. .. 6. TER DRIVEWAY TO TES HOUSE MUST'RE PAVED WITH A BITUMINOUS OR CONCRETE FINISH W]:TE]3 ONE TEAR 07 THE COMPLETION Or ANY RESIDENTIAL STEUCSORE. . • 7. A RESIDENTIAL STRUCTURE MUST BE COMPLETED AND HABITABLE WITHIN TWO TXM Or THE ..'PURCHASE Or. TEE LOT. FAILURE TO ACCOMPLISH THIS saaLL-GIVE THE DEVELOPER AN •.EXCLUSIVE OPTION TO REPURCHASE THE'LOT--FOR THE SAME PRICE AS TER ORIGIIAL PURCRASE. . AN ONNU Or TWO OR MORE CONTIGUOUS LOTS NEED NOT CONSTRUCT MORE THAN ONE RESIDENCE . ON THOSE LOTS: ' TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997, RECORDED 4/9/1997, IN DEED BOOK 155, PAGE 674. PROPERTY ID NO.: 23-35-2316-113 BEING KNOWN AS 6 INDEPENDENCE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Require ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil SUGGESTION_OF_.BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Michael A. Kaydo, Sr. and Lisa M. Kaydo has filed chapter 13 Bankruptcy in the Middle District of Pennsylvania on May 1, 2003, Bankruptcy Case No. 03-02613. Mark VUdren, Esquire MARK . UDREN & ASSOCIATES Attor ey for Plaintiff ?- c? ,, .? ?.? Norwest Bank Minnesota, National n The Court of Common Pleas of Association, as Trustee Under the Cumberland County, Pennsylvania Pooling and Servicing Agreement, Writ No. 1999-5119 Civil Term Dated as of Jan. 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse VS Michael A. Kaydo, Sr. and Lisa M. Kaydo 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. Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Surcharge Law Library Prothonotary Mileage Certified Mail Levy Cumberland Law Journal Patriot News Share of Bills 30.00 16.37 15.00 15.00 30.00 1.00 9.66 15.00 311.90 365.92 25.24 S 835.09 paid by attorney 5/14/03 Sworn and subscribed to before me This-47 a' day of 2003, A.D. Prothonotary So Answers: R. Thomas Kline, Sheriff 411- BYE Real Estat Deputy 1,0 LP 109.tl pu„ /3f.1fG NAM J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 • CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, 'COURT OF COMMON PLEAS National Association, as :CIVIL DIVISION Trustee Under the Pooling and :Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option One =MORTGAGE FORECLOSURE Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. NO. 99-5119 civil .Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Milo Corporation . 26 Copeland Avenue, PO Box 210 Homer, NY 13077 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, Bureau of Compliance, Dept. 280946 Department of Revenue 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 6 Independence Drive Mount Holly Springs, PA 17065 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 unworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: February 26, 2003 J. Udren, ESQ. 4ttk' orne or Plaintiff MARK J. UDREN 8 ASSOCIATES ATTORNEY FOR PLAINTIFF 8Y' Nark J. Udren, Esquire ATTY I.D. N0. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, COURT OF COMMON PLEAS National Association, as :CIVIL DIVISION Trustee Under the Pooling and :Cumberland County Servicing Agreement, dated as of January, 1, 1999, Option One =MORTGAGE FORECLOSURE Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. NO. 99-5119 civil Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) NOTTCP OF SHBR?FF'S c rg Og RaT pR0 SRTY TO: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo . 6 Indepedence Drive Mount Holly Springs, PA 17065 ,• Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on June 11, 2003, at 10:00 AM in the Commissioners Hearing Room,. 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWWMIS RTGHT5 YOU MAY RF ARTR TO PREVENT THTR S'HBBTPF'C S TP To prevent this Sheriff's Sale, you must take lamadiata-acti=u 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: (9561 492-6400. 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.) ' Y.QII MAY aTrr.r. gg nnr g T CAVE YOUR PROP ERTY YOII ayg OTHER RTSHTa .. $. ' rF TA'S SFIB TFF a3?r•g DOgy TAXR PL.a CS 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFBRRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN TRACT or LAED SITUATE IN THE BOROUGH OP MOUNT HOLLY SPRINGS, CONE"TiAED COUNTY, PANKSYLVANIA, BOUNDED AND DRSCRIBED.IR ACCORDANCE WITH A.PLAN PREPARED BY WALTER H. EE3NE ASSOCIATES, INC., DATED DRCEYERa e, 1969 AND RECORDED 3N PLAN BOOK 64, PAGE. 90, AS FOLLOWSS • BEGINNING AT A POINT IN WESTERN DEDICATED RIGHT-OF-WAY LINE OF INDEPENDENCE DRIVE AT CORNSR OF LOT NO. 24; TH NCE ALONG LOT, NO. 24, SOUTH 70 DEGREES 27 M3NOTES 10 •'BZC03WO WEST 100.00 REST TO A POINT: THENCE ALONG LOT NO. 10, NORTH 19 DEGREES 32 MINUTES 29 SECONDS WEST 75.59 PEST TO A PO3NT.Commom To TATS 18, 19, 22 AND 2?M 'THENCE ALONG LOT NO. 22, NORTH 70 DEGREES 27 M]NOTEB 10 SECONDS EAST 100.00 FEET '•'.,TO. A POINT IN WESTERN DEDICATED RIGHT-OF-WAY LINE OF INDEPENDENCE DRIVE; THENCE 'ALONG SAID DEDICATED RIGHT-0I-WAY LIEN OF INDEPENDENCE DRIVE, SOUTH 19 DEGREES 32 NIIIDTES' 29; SECONDS Ei.9T.75.59.FEET TO'a.POINT, THE PLACE or BEG»XNIXG. .:..CONTA]NXiG.'0.17.3t ACRE AND.DESIONATED'AS LOT. NO. 23.0 . N PLAN OF LIBERTY WOODS. . . SUBJECT TO. THE. FOLLOWING. RESTRICTIONSt' 1. ALL.RESXDZXTIAL STRVCTURNS SHALL HAVE A M3N]NUM OF 1100.8QUARE FEET OF rXNiSEED LIVING FLOCK AREA. .3. :NO NOZZLE BOMBS 'SMALL DR. PLACED ON ANY LOT 331 THIS SUBDIVISION.. 3.: NO DUMF3NG OR STOCKPILING OF XLTZLTALS OR OTHER ITEMS SHALL BE PERMITTED NOR THE ACCUMULATION OF ANY JUNE OR UMMXCMS33D VEHICLES ON ANY LOT WITHIN SAID . . .. 'SUBDIVISION. 4. . SREE REMOVAL BHArs BE KEPT To A u3NaNUM TO PSiDIT'TBE CONSTRUCTION OF A PRnQRT. '• "RESIDENCE AMID' GARAGE. 5. LOT OWNERS SHALL BE RESPONSIBLE FOR THE INSTALLATION AM M<AXIMUMACE OP A .. SIDEWALK ALONG'.THH'•BTREET FRONTAGE OF THEIR LOT. SIDEWALK CONSTRUCTION MUST BE .. ':.COMPLETED WITHIN ONE YEAR OF LOT PURCHASE. -THE SIDEWALK MUST BE CONSTRUCTED AS PER, . , THE SPECIFICATIONS OF TIM APPROVED PLAN OF SOBDMSION. 6. THE DRIVEWAY TO THR'HOUSE MUST-8E PAVED WITH A BITMCMUS OR CONCRETE FINISH ` WITHIN on TEAR Or THE CoMPLz=oN OF a= RESIDENTIAL STRUCTURE. 7.. A RESIDENTIAL STRUCTURE MUST HE COMPLETED AIM HAS WITHIN TWO YEARS OF TEE; . 'PURCHASE OF THE LOT. FAILURE TO ACCOMPLISH THIS SHALL GIBE THE DEVELOPER AN •.EXCLUSIVE OPTION TO REPURCHASE THE'Mb'F.FOR TER S= PRICE AS THE ORIGINAL-PURCHASE. .. . AN OWNER OF TWO OR MORE CONTIGUOUS LOTS NEED NOT CONSTRUCT MORE THAN ONE RESIDENCE ON THOSE TATS. TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/1997, RECORDED 4/9/1997, IN DEED BOOK 155, PAGE 674. PROPERTY ID NO.: 23-35-2316-113 BEING KNOWN AS 6 INDEPENDENCE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MORTGAGE LOAN TRUST 1999-A. ASSET- BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, 6INDEPEDENCE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 (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 gamishee(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. Amount Due $111.773.45 L.L. Interest FROM OCTOBER 14,1999 TO DATE OF SALE JUNE 11, 2003 PER DIEM @ $30.28 - $40,484.36 Atty's Comm % Due Prothy $1.00 Arty Paid $938.56 Other Costs Plaintiff Paid Date: MARCH 12, 2003 CURTIS R. LONG Prothonotary (Seal) QyetQ.gsC?s?` Deputy C 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 Real Estate Sale # 72 On March 17, 2003 the sheriff levied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA known and numbered as 6 Independence Dr., Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 17, 2003 By: Jb&q ?y& Real Estate Deputy 0 Cry 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, APRIL 25, 2003 & MAY 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 statements as to time, place and character of publication are RM BBTATa aMZ No. 72 Writ No. 1999.5119 Civil i Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing ' Agreement. dated as of January 1. 1999. Option One Mortgage Loan Trust 1999-A. Asset-Backed Certificate Series 1999-A, without recourse vs. Michael A. Kaydo. Sr. and Lisa M. Kaydo Atty.: Mark J. Udren ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs. Cumberland County. Pennsylvania, bounded and de- scribed in accordarmr with a Plan prepared by Walter N. Heine Asso- ciates. Inc., dated December S. 1989 and recorded in Plan Book 64 Page 90 as follows: 21, isa Marie Coyne, ditor S RN TO AND SUBSCRIBED before me this 2 day of MAY. 2003 Lots E WMER Nowt' Pub Carlow on, cunteriffild cou * CogrNetlon Evil" kwrch 5, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 567, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) as 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 22nd and 29th day(s) of April and the 6th day(s) of May 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 COPY ............................................... Sworn to and subsc be ore is 14th day of Kay 2 0 A.D. Nolanal Sea] Terry L. Russell, Notary PuW City Ol Harnsburg, Dauphin County NOTARY PUBLIC MY Commission Expires June 6, 2006 Membe, PennsylvaniaAss tion()fNM mmission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 364.17 Probating same Notary Fee(s) $ 1.75 Total $ 365.92 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... SALE #72 UDREN LAW OFFICES, P. C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael A. Kaydo, Sr. NO. 99-5119 civil Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $111.773.45 Interest From 10/14/99 71,262.24 to Date of Sale March 8, 2006 Ongoing Per Diem of 30.48 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. ?o N J \ ' " 1 ` ? ? ` O 1 1 ( ` r4 1% y?? 4u j ry J WRIT OF EXECUTION and/or ATTACHMENT' COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORN'ES'I' BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MORTGAGE LOAN TRUST 1999-A, ASSET- BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR AND LISA M. KAYDO (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 gamishee(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. Amount Due $111,773.45 L.L. Interest FROM 10/14/99 TO DATE OF SALE 3/8/06 ONGOING PER DIEM OF $30.48 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $71,262.24 Atty's Comm % Due Prothy $1.00 Any Paid $1,788.65 Other Costs Plaintiff Paid Date: DECEMBER 7, 2005 CURTIS R. LONG Prothonot ^ (Seal) `L331 Ui n (2' J Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICE, P.C. WOODCREST CORPORATE CENTER 1l l WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Michael A. Kaydo, Sr. d/b/a Kaydo CHAPTER 13 Roofing _`- Lisa M. Kaydo CASE NO.03-bk-02613 MDF Norwest Bank Minnesota, National 11 U.S.C. SEC. 362 Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A, without recourse Movant vs. Michael A. Kaydo, Sr. d/b/a Kaydo Roofing Lisa M. Kaydo Debtor(s) and Charles J. DeHart, III, Esquire Trustee RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY Upon consideration of the Motion of Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse for Relief from Automatic Stay, as well as the Certification of Default filed by same, it is hereby ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided tinder 1 I U.S.C. §362 is modified with respect to premises located at: 6 Independence Drive Mount Holly Springs, PA 17065 so as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code; and it is further By the Com't. Ban ru0 Budge (EW) Dated: October 3, 2005 This electronic order is signed and filed or, the same date. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF ?COURT OF COMMON PLEAS :CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAWJOFFICES, P.C. Mark J.1 Udren, ESQUIR ATTORN FbR PLAINTIFF y. •?o • i ! LL =? aJ J C? ? J ? 0 , , UDREN LAW OFFICES, P.C. BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as Of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner (s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 The Milo Corporation 26 Copeland Avenue Homer, NY 13077 Norwest Bank Minnesota National Association P.O. Box 57038 Irvine, CA 92619-7038 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Public Savings Bank, A PA Federal Savings Association See Caption above. 2300 Computer Avenue, Suite H-42 Willow Grove, PA 19090 Milo Corporation 26 Copeland Avenue, P.O. Box 210 Homer, New York 13077 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 Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 6 Independence Drive Mount Holly Springs, PA 17065 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. UDREN LAW OFFICES, P.C. DATED. December 6, 2005 Udren, ESQ. for Plaintiff >• r, i? iii ?.: ?. ?_ i ??i n i;,:. 1 L C. (., 1. 1-? 1? _ (_? ?' ?i { UDREN LAW OFFICES, P. C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney ,s fees. To find out how much you must pay, you may call: (856) 669-5400. 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.) y L. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ?lj t`J UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's sale on March 8, 2006, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take mediate action: 1. The sale will be canceled 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)-669-5400 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 TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE 1. If the Sheriff f-s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-91o8 r? r•, i= u 4 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) NO. 99-5119 civil AMENDED 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 fIs 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 Sheriffs Sale was sent to Defendant (s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit 111311. All Notices were served within the time lA '3129. This Affidavit is made subject to the p nrelating to unsworn falsification to au Dated: February 20, 2006 r . BY: forth by Pa Rule C.P. 18 Paf2:S. Section 4904 P. C. Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of owner (s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 The Milo Corporation 26 Copeland Avenue Homer, NY 13077 C/O Robert L. O'Brien, Esquire 17 W. South Street, Carlisle, PA 17013 Norwest Bank Minnesota P.O. Box 57038 National Association Irvine, CA 92619-7038 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Public Savings Bank, A PA Federal Savings Association Milo corporation 2300 Computer Avenue, Suite H-42 Willow Grove, PA 19090 26 Copeland Avenue, P.O. Box 210 Homer, New York 13077 5. Name and address of every other person who has any record lien on the property: Name Address Borough of Mt. Holly Springs 200 Harmon Street Mt. Holly Springs, PA 17065 C/0 Keith Orr Brenneman, Esquire Snelbaker & Brenneman PC 44 W. Main St., Mechanicsburg, PA 17055 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 Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 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 6 Independence Drive Mount Holly Springs, PA 17065 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 h reiAg ree subject to the penalties of 18 Pa.C.S. sec. 4904 re ati to u worn falsification to authorities. P. C. DATED: February 20, 2006 Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) DATE: January 18, 2006 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): MICHAEL A. KAYDO, SR. & LISA M. KAYDO PROPERTY: 6 Independence Drive, Mount Holly Springs, PA 17065 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 8. 2006, at 10:00 AM, in the COMMISSIONERS HEARING ROOM, 2m 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. T p alit 9 a $ $ a ? la J A al g ig 3 R g p a s j i o r z %omnrr ??? 13 FF 1 W W ] 7 yj N 0 m R p? °n a? ?_ ¢ W w < C x a¢ CN7 N F Z a 6 z ?¢ U o m o ZO a a ?J p N QQ = W R e 3 N- UP N gg W ae ¢ R p J g W Cc ?i' 5 n m¢ oa a 8? m$ d LL a= S g a Wo ' ¢ ¢V N 7 z> w a? "W Z O J 2?i a 4aW z n ma p W 8W w O 00?' F ?? EL CO ? gO ¢_ m d+ Y? ? co Z a }g? C} 88 p N ¢ a a ¢ J m m a d ? ¢ m =p Rg3w w m F? O¢ W z z O0 2m W" z 9 981 _ p3?0 v8 w a y o a ? a ? 0- gg :, ~ A E aE ' Q m w mo U Z a $ Y W S E ?. N e ? 0 N f7 •t N f0 f? CO N O N N O N F ? m a IL a LL a ? u 6't? 3 D i1 E ? ? a 288 ??? ? as ? g a 1W I go I W° on Q 081= W ¢o= 1 g U8Y a ¢8;W m z8 g 9 fA d Z71 w a¢ N N6. ? yN ?Y.{{ U ?X ?N LL y O? S j3 0 Id $Q •w F a 30VISOd'S'n 0 6: 0 = OZZ R In Io n a 4wal 6 d t .0 LL II r 2 m LL M ?? J N a i The Court of Common Pleas of Norwest Bank Minnesota, National Association, as Trustee Under the Pooling Cumberland County, Pennsylvania Dated as of Writ No. 1999-5119 Civil Term And Servicing Agreement , January 1, 1999, option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse VS Michael A. Kaydo, Sr. and Lisa M. Kaydo Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2006 at 6:16 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon kin within named defendants, to wit: Michael A. Kaydo, Sr. and Lisa M. Kaydo, by g known unto Michael Kaydo, personally and husband of Lisa M. Kaydo, at 6 its Pennsy rland ings Ind epend con and at theesame tirive me hMt. him personallyethe sa dt ru eand correl tacopy of thetents same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according, to law, states that on January 06, 2006 at 11:18 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 Michael A. Kaydo, Sr. and Lisa M. Kaydo, located at 6 Independence Drive, Mt. Holly Springs, 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 Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Michael A. Kaydo, Sr. and Lisa M. Kaydo, by regular mail to their Holly never returned PA 17065. These letters last known address of 6 Independence Drive, Mt. to the Sheriffs Office. were mailed under the date of January 13, _,6 Sworn and subscribed to before me This _ day of 2006, So Ans ers: omas Klin , Sheriff BY4 ,!r J- Real Estate Sergeant N _ y C' ` '- ?' i ;? ??-?`?- J; i ?, •'` ?. ?.: 1 ?_n. ` _. r . u_ c_ V ? ? UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY RILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-5119 civil SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendants, MICHAEL A. KAYDO, SR. & LISA M. KAYDO has filed Chapter 13 Bankruptcy in the MIDDLE District of Pennsylvania (HARRISBURG) on MARCH 7, 2006, Bankruptcy Case No. 06-00359. __?M Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff ATTORNEY FOR PLAINTIFF ?. ? ?r; - .?'? ,? C: f7. L' ? • ?-? Y? Norwest Bank Minnesota, National The Court of Common Pleas of Association, as Trustee Under the Pooling Cumberland County, Pennsylvania And Servicing Agreement, Dated as of Writ No. 1999-5119 Civil Term January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse VS Michael A. Kaydo, Sr. and Lisa M. Kaydo Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2006 at 6:16 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Michael A. Kaydo, Sr. and Lisa M. Kaydo, by making known unto Michael Kaydo, personally and husband of Lisa M. Kaydo, at 6 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 06, 2006 at 11:18 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 Michael A. Kaydo, Sr. and Lisa M. Kaydo, located at 6 Independence Drive, Mt. Holly Springs, 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 Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Michael A. Kaydo, Sr. and Lisa M. Kaydo, by regular mail to their last known address of 6 Independence Drive, Mt. Holly Springs, PA 17065. These letters were mailed under the date of January 13, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, states this writ is returned Stayed per instructions from attorney Mark Udren . Sheriffs costs Docketing 30.00 Poundage 27.05 Posting Bills 15.00 Advertising 15.00 Prothonotary 1.00 Mileage 11.44 Certified mail 3.66 Levy 15.00 Postpone 20.00 Postage 1.17 Surcharge 30.00 Law Journal 623.00 Patriot News Share of Bills Total: S /, X?. R. Thomas Kline, Sheriff BYJA' Real Esta Sergeant 481.40 21.05 1,2- 94 77 6/.7 'F106 s l u° Ch__ y44ut, pu" 17q '12Y -- UD_REN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999- A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 51038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, asset-Backed Certificate Series 1999-A , without recourse., 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, ?A 17065 Lisa M. Kavdo 6 Indepedence Drive Mount Holly Springs, P.A. 17065 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 orcoerty to be sold: Name Address The Milo Corporation 26 Copeland Avenue Homer, NY 13077 Norwest Bank Minnesota National Association P.O. Box 57038 Irvine, CA 9619-7038 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Public Savings Bank, A PA Federal Savings Association See Caption above. 2300 Computer Avenue, Suite H-42 Willow Grove, PA 19090 Milo Corporation 26 Copeland Avenue, P.O. Box 210 Homer, New York 13077 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 aff:cted by the sale: Name Address Real Estate Tax Dept 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the Plaintiff has knowledge who has any :nteresr_ is the property which may be affected by the sale: Name Address Tenants/Occupants 6 independence Drive Mount Holly Springs, PA 17065 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. UDREN LAW OFFICES, P.C. DATED: December 5, -2005 Mark J.? Udren, ESQ. Atto ne for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff.; Sale on March 8, 2006, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pav 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) 669-5400. 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. -. 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 ona how to obtain an attorney., _. _.._ .. ._?..i _.. ?_ ... ..•.r' tit:?. YOU MAY STILL HE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE if the Sheriff I Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-569-5400. 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 :ias happened, you may call 856-569-5400. 4. :f the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property asif 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 ocher rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 3 Liberty Avenue Carlisle, PA 17013-3387 717-2-49-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association C Liberty Avenue Carlisle, PA 17013-3387 717-349-3156 or 800-990-9108 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY RILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of January, 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse. P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. if the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take i-ediate action: 1. The sale will be canceled 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: 18561-569-5400. 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 'four rights. The sooner you contact one, the more chance you will have of atopping the sale. (See notice on page two on how to obtain an attorney., J , YOU MAY STILL HE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten ;.10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ..7 ALL THAT CERTAIN TRACT Or r-x m SITUATE IN IBM BOROUGH 07 MOUNT FOLLY SPRINGS, :.ClUm"LaED COUNTS, 1mwSYtV2EIA1 BOUIIDRD AND DE9CEIHED.IQ ACCORDANCE NJ. A PLAN'- . PREPARED BY WALTER N. EEIE'E A880CTATES, INC., DATED DECAOIBQ•8, 1989 AID RECORDED .. IN PLAIT BOOK 64, PAGE 90, AS FOLLONBi . 2EG1 NNrl0 2T A POZlrA - WESTERN DEDICATED BIGHT-OF-WAS LIFE OF.TNDEPEEDENCE DRIVE AT CORNER Or LOT NO. 24] TBAf' ALONG LOT NO. 24, sODTH 70 DEGREES 27 EI70THS 10... •' sECORDS NEST 100.00irz= To A POINT/ TTXXXCE ALONG LOT NO. 18,4ITE 19 DEGEE88 32 ., XINUTBS 29 8EC0ND8 NUT 75.39 FEET To A POINT CWOION To LOTS 18, 19, 22 AND 2?N T838C3 ALONG LOT NO. 22, NORTH 70 DEGREES 27 MIIDTEE 10 8EC0MDS RUT 100.00 FEET M •..•TO,A POINT IN WESTERN DEDICATED RIGHT-OF-NAT LINE Or TND3PEEDENCE DRxVS].TSEECE .:ALONG -ax" DEDICATED RIGHT-OF-NAB LIEN Or MMNPENDENCE DRIVE, 80018 19 DEGREES 32 .. MINUTES 29. 83CONDS RUT .73.3.9.n= TOA.POINT, TRZ PLACE or'BEOIIOfnOG. . CONTAIN33M, 0.1733 ACRE AND . DESIGNATED 'AS LOT No. 23 ON PLAN Or LMMTY WOODS. •- . ?9UBJECT TO •, TEE FOLLownra. zasmiCTIONBt .• . 1. ALL.RE8IDEETx2L STRUCTURES SHALL HAVE A MINIMUM Or Y100,sQ02RE rmr or rzaismo .L17m FLOOR AREA. .i _ .. ..2. NO MOBILE HUMNS SMALL•EE.PLACmn ox AM LOT If THIS SUBDIVI820N.... . .. ?3..:.EO DUMPING OR STOCEPZp.?IO OF NAtenT?* a OR OTBBS =Imo s41T.T. BR. PERMISTm NOR .. .. THE ACCUMULATION OF ANS JUNL OR UNLICENSED VEHIICL3s ON ANY LOT WITHIN SAID SUROMSXON. ' 4. TREE REMOVAL 88aLL BE E3@T TO 'A 1®TII0H TO PERMIT TEX CONSTRUCTION OF A P xlmxr -','II89mffi(CE AND GARIGE. .. 9. LOT OWNERS 882LL 3E IRSPONSIBLE FOR THE ffis'riT.T.A^'*p3 AECI IDII,TEANNCE OF A . aID811aLE ALONO•.THX STREET 3E1021. or T1DZtY LOT. SIDNI CONBTRUCIION 1[OST BE .. • :.Co10?LETBD WITHIN ON3'-SEAR OF LOT PURCEASB., . THE SiDIN= MOST BZi,tmT2UCTED ']8 PER.'. . , TSB sP3CTFTCATxoNs or Tim..APYRovBD PLAN or s=xVxsxoN. .. ,?. 6. THE DRS98R2l TO THX-HOUBE NOT-BE PAVED WITH A BITOMMIIB OR COECiETB FINISH. ...-1011ME ORR THAR OF 188 COMPLETION Or ANT RESIDZWTX& . 81RUCTQRE. • 7.. A 97-M yam aL 9TRVClURE MST BE CoMPLBTED am •mixTama WITHIN TEC TEARS or TEE • . 'PURCBASE OF. THE LOT. FAILURE TO ACCOMPLISH THIS SHALL GIVE TE D3V8APER AN' .83CLU9IV3 OPTION TO REPURC11A.4E THE LOS-FOR TER aam PRICE as .THE ORIGINAL -PURCHASE. AN OWNBB.OF TWO OR MOEE CONTIGUOUS LOTS NEED NOT CONSTRUCT NQE.E THAN ONE RESIDENCE .. . ON THOSE LOTS. BEING KNOWN AS: 6 Independence Drive, Mount Holly Springs, PA 17065 PROPERTY ID NO.: 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/97 RECORDED 4/9/97 IN DEED BOOK 155 PAGE 674. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMEN'T', DATED AS OF JANUARY 1, 1999, OPTION ONE MORTGAGE LOAN TRUST 1999-A, ASSET- BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR AND LISA M. KAYDO (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 slated. Amount Due $111,773.45 L.L. Interest FROM 10/14/99 TO DATE OF SALE 3/8/06 ONGOING PER DIEM OF $30.48 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $71,262.24 Ally's Comm % Due Prothy $1.00 Arty Paid $1,788.65 Other Costs Plaintiff Paid Date: DECEMBER 7, 2005 CURTIS R. LONG Prothonot (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICE, P.C. WOODCREST CORPORATE CENTER I I I WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF V ` Telephone: 856-669-5400 Supreme Court ID No. 04302 - Real Estate Sale # 48 On December 12, 2005 the Sheriff levied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA Known and numbered as 6 Independence Drive, Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Qw Date: December 12, 2005 By.,jo?._ , QQ Rc al Estate Serge `ant 80 111 d 8- 330 SOOT Vd'AINnoo ONV1d39wn0 AWNS 3H1 A 331140 I'k UI Mill ICA'1'10!\' 01- No flCF. i it\1131sR1.,1ND LAW JOIIIZN:AI. (Uwlrr 5S7, app:oved May 16, 1929t, 1'. L.1784 STATE OF PIsNNSYLV: `•. COUNTY OF ('LJAIBFRI Lisa Maric Cocne. 1 State aforesaid, heing ditfv Journal, a legal periodical p1; was established hinuan ', periodical for the publicatiol issued weekly in the said t exactly the same as wa, p11; Journal on the liillowine date viz: _ .lams:u? _'U \s. ,ire. !:dito: I'the Cumberl:tntl ; aW Journal, of the County and accordill !o faw, deposes :ulo says that the Cumberland Law ,.d in the R•uuugh of ('arliSlc in the County and Slate aforesaid, '. ;I?d dcsig,natcd by the local courts as the official legal II Ir al notices, and has, smn e I:muarv 2, 1952, been regularly :u •.I tha! he printed notiec or publication attached hereto is n th.: rcgu!.tr editions and i,su:s of the said Cumberland Law hrn.a'y i.: M6 -- Affiant further d In It 11 is :u,:' urizcd to verily th:a statement by the Cumberland Law Journal, it Irgal pcrn„ir, ga::ral cu, ul:nion, ;;nd 111,1 I;. is not interested in the subject matter of the atirresaid iw n :.,Ivcrtc:mcnt. and lh:n ai: allegations in the foregoing statements as to time, 1;u:1. Icr o! lblication arc !:uc. REAL ESTATE BALE NO. 46 Writ No. 1999-5119 Civil Norwest Bank Minnesota. National Assoclatlon, as Trustee Under the Pooling and Servicing Agreement. dated as of January 1, 1999. Option One Mortgage Loan 71vst 1999-A. Asset-Backed Certificate Series 1999-A, without recourse va. Michael A. Kaydo, Sr. and Lisa M. Kaydo Atty.: Mark Udren ALL that certain tract of land situ- ate in the Borough of Mount Holly Springs, Cumberland County. Penn- sylvania, bounded and described in accordance with a plan prepared by Walter N. Heine Associates, Inc.. dated December 8, 1989 and re- corded In Plan Book 64, Page 90. as follows: BEGINNING at a point In west- ern dedicated right-of-wav line of Isu M:nic (uync, f- lilor -ORN TO AND l Sl BSCRIBBD before me this da 01'. _i el : uar , 2006 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} as Michael Morrow, being duly swom according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; 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 in the 24th and 31st day(s) of January and the 7th day(s) of February 2006. 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 COPY SALE#48 ................................................................................................ Swom to and subscribed bef re mHh 76th day of Februa 2006 A .D. Public NOTARY PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ... DFBCBIPfIDN ,?„11lL7WCWAIN tract d 4M,'i4uk m AS OF lo-a6-aoo6 CASE# f`igq - 5119 moral -t., HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. •' . r,-b UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate :NO. 99-5119-CIVIL Series 1999-A , without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendants, Michael A. Kaydo, Sr. And Lisam M. Kaydo filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on March 7, 2006, Bankruptcy Case No. #06-00359. Case was dismissed on September 18, 2006 and reinstated on October 18, 2006. Mark J. Udren, Esquire' UDREN LAW OFFICES, P.C. Attorney for Plaintiff C c?"' ...{ ,? ? -- -„ ? ?`+ . ? ; r ?,?, 5 r..+ ?. Y ?..? ??~l .? ? ? ,...f . V ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as of :Cumberland County January 1, 1999, Option One Mortgage Loan Trust 1999-A, :MORTGAGE FORECLOSURE Asset-Backed Certificate Series 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE.TO REISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due $111,773.45 Interest From 10/14/99 82,356.96 to Date of Sale 3/7/07 Ongoing Per Diem of 30.48 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, 7.C: Marx u. uaren, E6Qu.ixE ATTORNEY FOR PLAINTIFF C-' Va- - vt V .... i0or tj* r ^ ?1 w w ? A r I C) t t7i / -., WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NA, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MORTGAGE LOAN TRUST 1999-A, ASSET-BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR. AND LISA M. KAYDO (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. Amount Due $111,773.45 L.L. Interest FROM DATE 10/14/99 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $30.48 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $82,356.96 Atty's Comm % Atty Paid $3,108.42 Plaintiff Paid Due Prothy $1.00 Other Costs Date: OCTOBER 20, 2006 (Seal) Cur ' . Long notaryBy: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 MDPA-MSM1SMAPT REV 6105 UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA IN RE: MICHAEL A. KAYDO, SR. D/b/a KAYDO ROOFING Chapter 13 \ V Case No.: 1-06-bk-00359 Debtor(s) ORDER DISMISSING CASE Upon consideration of the Certificate of Default filed by Charles J. DeHart, III, Trustee, of Debtor on stipulation filed July 20, 2006 resolving the Trustee's prior motion to dismiss the case, and in accordance with the terms of the stipulation regarding dismissal, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U.S. Bankruptcy Court. Date: September 18, 2006 BY TBE COURT, rnp ; duaTt 1Fn, RP ?V V This document is electronically signed and filed on the same date. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mortgage Loan Trust 1999-A, :MORTGAGE FORECLOSURE Asset-Backed Certificate Series € 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. ::NO. 99-5119-CIVIL Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 De f endant (s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is. ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penaltie' of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. OFFICES, J. Udren, ESQUIRE NEY FOR PLAINTIFF CD G ` Y' tM? rnT"' Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mortgage Loan Trust 1999-A, :MORTGAGE FORECLOSURE Asset-Backed Certificate Series € 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999- A, without recourse, 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 Mt. Holly Springs Borough 200 Harman Street Mt. Holly Springs, PA 17065 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. The Milo Corporation 26 Copeland Avenue, Homer, NY 13077 c/o Robert L. O'Brien, Esq., 17 W. South Street, Carlisle, PA 17013 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 Department 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17103 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 6 Independence Drive Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or informati n and belief. I understand that false statements herein are ma e subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. LAW OFFICES, P./C. DATED: October 11, 2006 arx u- uuren, ttorney for Plaintiff cr. -f 4 c? ~ - 73 y 37:- r' A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as ::Cumberland County of January 1, 1999, Option One Mortgage Loan Trust 1999-A, :MORTGAGE FORECLOSURE Asset-Backed Certificate Series 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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.) I YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 G ? er p n 31 - L5 .tZ" ^C Original writ and package returned to the Prothonotary`s Of :ice - Check #72533 in the amount of $1,500.00 returned to Attorney Udren with a copy of the writ. MARK J.UDREN* STUART Wn'gNEG" GAYL SPIVAK ORLOFF*** HBO[ R. SPIVAK"* MARISA JOY COHBN*** LORRAINE DOYLE** ALAN M. MINATO04* "AMTMD NJ, PA. FL "ADVEMM PA ",,AD w=v m, PA TINA MARIE RICH OMCS ADaaMrMTOR October 20, 2006 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER I I I WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003.3620 856.669. 5400 FAX 656. 669. 5399 _ FREDDIL C PENNSYLVANIA DESIGNA?ED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE Sent via telefax #1-717-240-6397 P SYLVANIA OiFFIS 215.5689 M Cumberland County Sheriffs Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 ATTN: Deputy Jody Smith Re: Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A , without recourse vs. Michael A. Kaydo, Sr. & Lisa M. Kaydo Cumberland County C.C.P. No. 99-5119-CIVIL Premises: 6 Independence Drive, Mount Holly Springs, PA 17065 SS Date: March 7, 2007 Dear Deputy Smith: Please Stay the Sheriff's Sale scheduled for March 7, 2007. Sale is stayed for the following reason: Defendant(s) filed Chapter 13 Bankruptcy on March 7, 2006 in the Middle District (Harrisburg, PA). Case number #06-00359. Care was dismissed on September 18, 2006 and reinstated on October 18, 2006. Thank you for your attention to this matter. Sinc el y urs, Ma' j r . Udren UDREN LAW OFFICES, P.C. /hac in/in -A 'ON XU WV L0:80 NOW 90OZ-EZ-100 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. €NO. 99-5119-CIVIL Lisa M. Kaydo Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled 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)-669-5400. 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.) A YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 rz1 T! Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo Defendant(s) ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee 669t atorney's fees. To late charges, costs and reasonable you must pay, you may call: 5400. 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.) the back payment, find out how much Y j I- YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 C=3 c7n d Fn ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as =COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse, 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 Borough of Mt. Holly Springs 200 Harman SStreet PA 17065 r 4. Name and address of the last recorded holder of every mortgage of record: Address Name Norwest Bank Minnesota, NA as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Milo Corporation 26 Copeland Avenue, P.O. Box 210 Homer, NY 13077 c/o Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Address Name 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: Address Name Real Estate Tax Department 1 Courthouse Square 1 013 Domestic Relations Section 13 NorthHan Street Carlisle, 1701 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of every other person the prope?tytwhichamaylbe has knowledge who has any interest affected by the sale: Address Name Tenants/Occupants 6 Independence Drive Mount Holly Springs, PA 17065 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. OFFICES P•L- .vr DATED: February 19, 2007 ark J. Udren, ESQ. Attorney for Plaintiff 1tv N ? C' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NA, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MTG. LOAN TRUST 1999-A, ASSET-BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR. AND LISA M. KAYDO (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) of otherwise disposing thereof; (3) If property of the defendant(s) not levied directedto notify him/her hat he/she has been added as a of anyone other than a named garnishee, you are garnishee and is enjoined as above stated. Amount Due $111,773.45 L.L. Interest FROM 10/14/99 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $30.48 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $85,344.00 Atty's Comm % Atty Paid $3,083.42 Plaintiff Paid Due Prothy $1.00 Other Costs Date: MARCH 2, 2007 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. C s &R.Long t By: Deputy WOODCREST CORPORATE CENTER WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 ?w UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. =NO. 99-5119-CIVIL Lisa M. Kaydo Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $111,773.45 Interest From 10/14/99 85,344.00 to Date of Sale 6/13/07 Ongoing Per Diem of. 30.48 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. arl", Udren, ESQUIRE TTORNEY FOR PLAINTIFF r' t 0 W N I c o o c?? o ? w , I ? j l? 1 ? 1 ? w w 1 p % 1 1 . 0 N r 1-0 9 lxe991? 7?? IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Michael A. Kaydo, Sr. CHAPTER 13 d/b/a Kaydo Roofing CASE NO. 1-06-bk-00359 MDF Option One Mortgage Company a California Corporation Movant VS. Michael A. Kaydo, Sr. d/b/a Kaydo Roofing Debtor(s) and Charles J. DeHart, III, Esquire Trustee RESPONDENTS ORDER MODIFYING AUTOMATIC STAY Upon consideration of the Motion of Option One Mortgage Company a California Corporation for Relief from Automatic Stay, as well as the Certification of Default filed by same, it is hereby ORDERED AND DECREED THAT: The 11 U.S.C. §362 Automatic Stay of all proceedings is hereby modified with respect to premises located at: 6 Independence Dr. Mt. Holly Springs, PA 17065 so as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. By the Court, Dated: January 16, 2007 This document is electronically signed and filed on the same date. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is. ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to au7.orities. LAW qlrF%CES, P . C ?_u_dren, ESQUIRE EY FOR PLAINTIFF n 9 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One € Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo ::NO. 99-5119-CIVIL 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its his her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth b Pa Rule C.P. 3129. This Affidavit is made subject to the penalties o 8 P .C. . Section 4904 relating to unsworn falsificat'on to author' 1 s. Dated: June 1, 2007 UDREN OFF CES, C. BY: V Mark J Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as :COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mortgage Loan Trust 1999-A, :MORTGAGE FORECLOSURE Asset-Backed Certificate Series 1999-A, without recourse P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset-Backed Certificate Series 1999- A, without recourse, 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 104 Big Spring Terrace Newville, PA 17241 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 Mt. Holly Springs Borough 200 Harman Street Mt. Holly Springs, PA 17065 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. The Milo Corporation See Caption above. 26 Copeland Avenue, Homer, NY 13077 c/o Robert L. O'Brien, Esq., 17 W. South Street, Carlisle, PA 17013 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 Department 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17103 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 6 Independence Drive Mount Holly Springs, PA 17065 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. UDREN LAK OMCE9, P .IC . DATED: June 1, 2007 Mark J. drdfi, Es ire Attorne for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as Trustee € COURT OF COMMON PLEAS Under the Pooling and Servicing -" CIVIL DIVISION Agreement, dated as of January 1, 1999, Cumberland County Option One Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse € NO. 99-5119-CIVIL Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Michael A. Kaydo, Sr. And Lisa M. Kaydo PROPERTY: 6 Independence Drive, Mount Holly Springs, PA 17065 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 13, 2007, at 10:00 am, in 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 than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A z m LL m m'7 c c a n O W o • m $" ° E W ? N - N O ' R E°a y °$ a W V m N N m C O c H a) E c m a U- E?Em-a N m N = ? C Q E5:$?° LO = U O? 0 w ° c V m 0 N (n LL W N x C E Wv o w o N ?w C LV E W - po c, c m U O WO m w O • N (Y LL m m .m i. N C Z D n O (p Q/ Q ' C N E a 13 ` a m E m o W E ' a CL U W 0 d ?O -ZE y o o m m oa c$O m cc y?o c Lup (A _ WWE3v`w E2?'cc O y0 oU mE G) V QUfO a o WxfE» s m w x N ° m v a m E m °c t m o m` m O j ? E W L m n ES o ?- 'rn m e c Y Lp L p11C1 r moml C ? W c ? O ? O ? t 0 ° •? j C 2 me Q.$ m N C r m o c C N i0 mR m g N rW ° 0 n c Q? yOO,$mEm c nv o CL :3 ?Co®o ° L4 0 N L_ L_ N o w nN D1 p? O T m '43) 3 ._5 Lu , ? ?? 'E - m e° > mc U ? ? c C E m v_ W SC 2W5M z c ° E o N V p m N m x ID ' EIM m a ' N .... , Q V ., i ? ' S n n r_ c V x C w a? LL lz z -'i q g c 9 k C u v N .. - -.... -_: of v d ? S N d Q w U a: 9 U U ?? ? ? a w C7 j Z m w N m OT O U) m d o v ¢ C) Q w _ = 0 3 a Q N 0 ~a Q Z O = w m 04 C? w F „J !4 co z N zto w m L7 _ d' O L L 1 T ?N T c N o- w O O NO £ - wV ? wC p Za Co m m a W p Ix co Z a? VaZ U- 0 w S cn¢ a2 F- m cn0 Lo ¢' OV N ? J O y » 0 Ld 0 z? Q 750 n m ? ? ?? °Wo W yviS C m 0a UN HJ Q? La aw as OU) 2r c m a d na O a N w d N J.J wao C O 0 w 0 0 Z Zj wQ o QU? pJ vi m N o ? a wow a ?_ ? aa°b ins o= O: S O O wF- , W OJN ZH ?n oU Z > i a E m? ?? ??? 2Z 2 o0 0 O N r, m ?O 0 I- 000 w0 - oo -M T T Z UU 0C0 UUa F-2 mS ?T cp N O m ,o rn N M a O N L co :E Q Z t a m lC ? C (D 4 C1 ' T E U C l0 Q m c ? m m Z O J e.. N C7 er U) t0 I? CO 0 - .T-- - M - -- • ., ? EXHIBITA C a d !0 m `o Y C V W 3 a H a O V d .C 3 O U. a O) LL ti M O U- co n. v c co E U rn cfl CD rn O T CY G J a Q L 0 W Y Q N fQ U 2 CTl C- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Option One Mtg Loan Trust 1999-A Tr is the grantee the same having been sold to said grantee on the 13th day of June A.D., 2007, under and by virtue of a writ Execution issued on the 2nd day of march, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 1999 Number 5119, at the suit of Norwest Bank Minnesota NA Tr against Michael A Kaydo Sr & Lisa M is duly recorded in Deed Book No. 281, Page 64. IN TESTIMONY WHEREOF, I haveeer_eunto set my hand an d eal of said office this day of A.D. b, of R9000 W d D" CwnberlW Ca ft CaMb. PA My CW*MM Eow to Fffd Mwa y d Jw 2010 Norwest Bank Minnesota, NA as Trustee Under In the Court of Common Pleas of The Pooling and Servicing Agreement, dated as of Cumberland County, Pennsylvania January 1, 1999, Option One Mortgage Loan Trust Writ No. 1999-5119 Civil Term 1999-A, Asset-Backed Certificate Series 1999-A without recourse VS Michael A. Kaydo, Sr. and Lisa M. Kaydo Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2007 at 1820 hours, 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: Michael A. Kaydo, Sr., by making known unto Michael Kaydo, Sr., personally, at 6 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2007 at 1745 hours, she 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: Lisa M. Kaydo, by making known unto Lisa M. Kaydo, personally, at 104 Big Spring Terrace, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1430 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael A. Kaydo, Sr. and Lisa M. Kaydo, located at 6 Independence Drive, Mt. Holly Springs, Cumberland County, 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 Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Michael A. Kaydo, Sr. and Lisa M. Kaydo, by regular mail to their last known addresses of 6 Independence Drive, Mt. Holly Springs, PA 17065 and 104 Big Spring Terrace, Newville, PA 17241, respectively. These letters were mailed under the date of April 4, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 13, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren, on behalf of Wells Fargo Bank, N.A. f/k/a Norwest Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 1999-A Asset-Backed Certificates, Series 1999-A. It being the highest bid and best price received for the same, Wells Fargo Bank, N.A. f/k/a Norwest Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 1999-A Asset- Backed Certificates, Series 1999-A, of 6501 Irvine Center Drive, Irvine, CA 92618, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,066.54. Sheriffs Costs: Docketing $30.00 Poundage 20.92 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 1.00 Mileage 24.00 Levy 15.00 Surcharge 30.00 Law Journal 395.00 Patriot News 381.95 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriff s Deed 39.50 $ 1066.54 So Answers: R. Thomas Kline, Sheriff B t C lv Real Estate ergeant I V. /b-1 4, ,14.0 CA_ 5'9.2 !9 s q q' F r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as =COURT OF COMMON PLEAS Trustee Under the Pooling and :CIVIL DIVISION Servicing Agreement, dated as :Cumberland County of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- :MORTGAGE FORECLOSURE Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. :NO. 99-5119-CIVIL Lisa M. Kaydo Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse, 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: 6 Independence Drive, Mount Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 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 Borough of Mt. Holly Springs 200 Harman Street Mt. Holly Springs, PA 17065 V r 4. Name and address of of record: Name the last recorded holder of every mortgage Norwest Bank Minnesota, NA as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, option One Mtg. Loan Trust 1999-A, Asset-Backed Certificate Series 1999-A, without recourse Milo Corporation Address P.O. Box 57038 Irvine, CA 92619-7038 26 Copeland Avenue, P.O. Box 210 Homer, NY 13077 c/o Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 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 Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 6 Independence Drive Mount Holly Springs, PA 17065 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: February 19, 2007 4larK U . uareii, ZOW . Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I:D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, option One Mtg. Loan Trust 1999-A, Asset Backed Certificate Series 1999- A, without recourse Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland.County MORTGAGE FORECLOSURE Michael A. Kaydo, Sr. Lisa M. Kaydo Defendant(s) NO. 99-5119-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael A. Kaydo, Sr. 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly. Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWMR'3 RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 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 TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE-OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 L UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Norwest Bank Minnesota, NA, as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mtg. Loan Trust 1999-A, Asset- Backed Certificate Series 1999- A, without recourse Plaintiff V. Michael A. Kaydo, Sr. Lisa M. Kaydo Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-5119-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lisa M. Kaydo 6 Indepedence Drive Mount Holly Springs, PA 17065 Your house (real estate) at 6 Independence Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at the Sheriffs Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 21 Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,773.45, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled 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)-669-5400. 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 TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened.. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the. Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717.-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT certain tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc.., dated December B, 19B9 and recorded in Plan Book 64, Page 90, as follows: BEGINNING at a point in western dedicated right of way line of Independence Drive at comer of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and'23; thence along Lot No. 22; .North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence along said dedicated right of way line of Independence Drive, South 19 degrees 32 minutes 29 seconds East 75.59 feet t6 a point, fl a Place of BEGINNING. CONTAINING 0.1735 acre and designated as Lot No..23 on Plan of Liberty Woods. BEING the same premises which Liberty Associates, by deed dated March 3, 1997 and recorded in Cumberland County Deed book 1.55, Page 674, granted and conveyed unto Michael A. Kaydo, Sr., and Lisa M. Kaydo, Mortgagors herein. BEING KNOWN AS: 6 INDEPENDENCE DR., MT. HOLLY SPRINGS, PA 17065 PROPERTY ID NO.: 23-35-2316-113 TITLE TO SAID PREMISES IS VESTED IN MICHAEL A. KAYDO, SR. AND LISA M. KAYDO, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM LIBERTY ASSOCIATES DATED 3/3/97 RECORDED 4/9/97 IN DEED BOOK 155 PAGE 674. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5119 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA, NA, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF JANUARY 1, 1999, OPTION ONE MTG. LOAN TRUST 1999-A, ASSET-BACKED CERTIFICATE SERIES 1999-A, WITHOUT RECOURSE, Plaintiff (s) From MICHAEL A. KAYDO, SR. AND LISA M. KAYDO (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. Amount Due $111,773.45 L.L. Interest FROM 10/14/99 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $30.48 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $85,344.00 Atty's Comm % Atty Paid $3,083.42 Plaintiff Paid Due Prothy $1.00 Other Costs Date: MARCH 2, 2007 (Seal) Curti R. Long, Pr ary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 JUBORIaS OILIsg It'a-d ?I-rh- P ( r\). LOOZ `£i g3nW :aItQ •uialatl pair.zodioaui aauajajaj sitlj .?q put, 1!jm sitli ipiM palg «V„ Iiglgxg uo pagiosap Xllnj a.zotu `sguiadS XIIoH 'IW OAT ICI aauapuadapul 9 su pa iaguznu puu umouX Vd `XlunoD puelzaquinD `gOnojog sSuudS XIIoH -IW ui palumis Xpadozd leas aqj ui Isaaalui s,luLpuajap aqj uodn painal j3tjattS auk LOOZ `£ I qO lt' W uO ZL # aIUS WISH Iua2t a b- i%+ tOJl It "It. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with 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 in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. 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 COPY SALE#72 Sworn to and subscribed be this 18th day of May 2007 A.D. MANWEALTH OF PENNSYLVANIA Notariai Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County NV Commission Expires June 6, 2010 ember. a nc?lvania Asscriation of Notaries N ARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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: April 20, 27, May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, E ' or SWORN TO AND SUBSCRIBED before me this 4 _day of May, 2007 _ NOTARIAL SEAL L" LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 72 Writ No. 1999-5119 Civil Norwest Bank Minnesota, NA as Trustee Under the Pooling and Servicing Agreement, dated as of January 1, 1999, Option One Mortgage Loan Trust 1999-A, Asset Backed Certificate Series 1999-A without recourse vs. Michael A. Kaydo Sr. and Lisa M. Kaydo Atty.: Mark J. Udren ALL THAT certain tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and de- scribed in accordance with a Plan prepared by Walter N. Heine Asso- ciates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: BEGINNING at a point in west- ern dedicated right of way line of Independence Drive at comer of Lot No. 24; thence along Lot No. 24, South 70 degrees 27 minutes 10 seconds West 100.00 feet to a point; thence along Lot No. 18, North 19 degrees 32 minutes 29 seconds West 75.59 feet to a point common to Lots 18, 19, 22 and 23; thence along Lot No. 22, North 70 degrees 27 minutes 10 seconds East 100.00 feet to a point in western dedicated right of way line of Independence Drive; thence along said dedicated right of way line of Independence Drive, South 19 degrees 32 min- utes 29 seconds East 75.59 feet to a point, the Place of BEGINNING. CONTAINING 0.1735 acre and designated as Lot No. 23 on Plan of Liberty Woods. BEING the same premises which Liberty Associates, by deed dated March 3, 1997 and recorded in Cumberland County Deed Book 155, Page 674, granted and con- veyed unto Michael A. Kaydo, Sr., and Lisa M. Kaydo, Mortgagors herein. BEING KNOWN AS: 6 Indepen- dence Dr., Mt. Holly Springs, PA 17065. PROPERTY ID NO.: 23-35-2316- 113. TITLE TO SAID PREMISES IS VESTED IN Michael A. Kaydo, Sr. and Lisa M. Kaydo, His Wife, as tenants by the Entireties by Deed from Liberty Associates dated 3/3/ 97 Recorded 4/9/97 in Deed Book 155 Page 674.