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HomeMy WebLinkAbout99-07214 >, MARK J. UDREN & ASSOCIATES BY: Ma=-k J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SU3:TE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Ernest P. Hartsock 2475 Walkertown Avenue NO. Deltona, F1 32725 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 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 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 AVISO Le han demandado a usted en la torte. 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 notification. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte 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 torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE SSTA DEMANDA A UN AEOGADO IMMEDIATAM=E, NO.TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERI LLAME POR TELEFONO A LA OFICINA COMA DIRECCION SF PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTEN Cumberland County Bar Associati 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 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 wilt 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 nail 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. WREN /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: Gateway Funding Diversified Mortgage Services, L.P. Assignee: Norwest Mortgage, Inc. Recording Date: 7/28/97 Book: 553 Page: 171 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g) The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 593-4 Geneva Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 7/24/97 DATE RECORDED: 7/28/97 BOOK: 1395 PAGE: 978 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) (b) 6. 11/22/99: by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said mortgage as of Principal of debt due and unpaid $52,684.80 Interest at 7.5% from 6/1/99 to 11/22/99 (the per diem interest accruing on this debt is $10.98 and that sum should be added each day after 11/22/99) 1,921.50 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow overdraft/ (Balance) (The monthly escrow on this account is $109.10 and that sum should be added on the first of each month after 11/22/99) 254.16 Late Charges (monthly late charge of $19.36 should be added on the fifteenth of each month after 11/22/99) 96.80 Attorneys Fees (anticipated and actual to 5% of principal) 2,_634..24 TOTAL $58,121.50 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. 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 1983, has not been sent because the Mortgage is insured by the Federal Housing Administration ("FHA") and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant (s) herein in the sum of $58,121.50, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premis99. A Mark/JY Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 EXHIBIT A ALL THAT CERTAIN UNIT, BEING UNIT NO. 593-4 (THE "UNIT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISC. BOOK 357, PAGE 20, AND IN RIGHT OF WAY PLAN BOOK 9, PAGE 24, AS AMENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.7197% INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PLANS. V_ .E_ R I _ F_ I _C_A..T.S_0_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 IS Pa.C.S. Section 4904 relating to unsworn falsification to authorities. MarkJ.'Udren, ESQUIRE MARK lJ. UDREN & ASSOCIATES ?J ? )s b ? cl L 11n1 (?l F._ tiC 17 >z 4 C 1(1J U rn 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 609-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. :NO. 99-7214 Civil Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) PRAECIPE_TO_FILE_PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. MARK J. UDREN & ASSOCIATES Date: January 3, 2000 BY: J. Udren, ESQUIRE ney for Plaintiff , it i?. , e? ri PREMIER PROCESS SERVICES, INC. 1116 Chestnut Street, Darby Pa 19023 (610) 237-0488 or (610) 766.0296 PREMIER PROCESS@AOL.COM VERIFICATION OF SERVICE Plaintiff(s): Court Term & No. NnrweSt Mortgage. Inc. VS. Defendant(s): County Ernest P. Hartsock Cumberland Name of Defendant(s) to Serve: X Ernest P. Hartsock __ Civil Action Complaint in Mortgage Foreclosure .-Civil Action ---- Serve at: --Writ ---- sale.-__ _-_- 2475 Walkertown Avenue .--Notice of Sheriff's Deltona, F132725 -other __- Special Instructions *»********»»*»rt»s»***rtrt****»*»**»****»**»******rt rts»*ss***zz»*»r»***»»rtrt»*»****»***»***rt*»***rt*»****»*z»srt SERVED AND MADE KNOWN TO ERNEST HARTSOCK on tha'Oth day of December 19 99, at 2:00 o'clock P M, at 2475 Walkertown Ave. Deltona FL County of Volusia ggce?lx, in the manner described below: Defendant(s) personally served XX Adult family member with whom Defendant(s) reside(s). Relationship is his fi anre (7?tery1 Ha 1 _ Adult in charge of Defendant(s) residence who refused to give name or relationship. _ Posted Premises located at _ Other Description Age 40 Height 5'5 Weight 140 Race W Sex F Other On the day of l9_, at o'clock M. DEFENDANT NOT FOUND BECAUSE:- Moved - Unknown _No Answer _ Vacant- Other ATTEMPTS MADE AND COMMENTS: »*s»**srtrtrt»*ssrtsrtrtsazrtrt*rt**z»rt*»»rtrtrtrt»zsrtsrt**+»*zrt*»zz»rt**zz»rt*z=srtz»»*rtz*»*zrtzrt»*rt*s»zs»»»*zrtsrt»rtrt*z*ssart** Patte Costa The undersigned understands that the statements herein set forth above are made subject to the penalties .C-S. Section 4 relating relating to sification to authorities. Date December 21? 1999 Process ServerXMff1p¢7 = .-- rtzrtsz»»»»zz»rts»z»zer»z*»z»zz»»z»rt»»zzzz»»»zz»+zz»»z*rt»»zzzrt»»zz*»»zzzzrtz»»tzzrtrtz»zz+»zrtrt»»zzz»z»*»»*zz*a»rtz - --- -------------- CASE NO: 1999-07214 P SHERIFF'S RETURN - NOT FOUND COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST MORTGAGE INC VS. HARTSOCK ERNEST P R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: HARTSOCK ERNEST P but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE FORECLOSURE NOT FOUND as to the within named defendant HARTSOCK ERNEST P DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING W/P.O., RETURN NOT FOUND AS PER ATTY Sheriff's Costs: So answers:' Docketing 18.00 Service 8.06 Not Found Return 5.00 Surcharge 8.00 omas ine, ert $37-.0-F MARK J.9gDREN Sworn and subscribed to before me this day of w e9 . c-Lro A. D . ro ono ary MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 08034 ft09 482-6900 Wei ors:?y Cor'sfy Tin..I Within TO B-- A "i raa f„id Corraoi G-py 0" Th" CriJiral ATTORNEY FOR PLAINTIFF 500 ??I Norwest Mortgage, Inc. :COURT OF COMMON PLEAS U 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff , v. Ernest P. Hartsock q('1- ?,??/ n •.„ ?`? 2475 Walkertown Avenue : NO. l.Ce?c.E Deltona, F1 32725 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 TRUE COPY FROM RECORD UI T-iS1ITCrq wba:mt, I h@fe unto set my ha0d and the wil of s33d :ours at Cartlsie, Pa. Ttds / o day [si AQc«, G .?t9 ?l4 g?rDthonotery AVISO Le han demandado a usted an la carte. Si usted quiere defenderse de estas demandas expue stas an las paginas siguientes, usted tiene veinte (20),d1as de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o an persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas an contra de su persona. Sea avisado que si usted no se dafiencle, la torte tomara medidas y puede continuar la demanda an contra suya sin previo aviso o notificacion. Ademas, 1a torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provis Tones de esta demanda. Usted puede perder diaero c sus propiedades u otro s derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMHEDIATAHENTE, SI NO TSENE ABOGADO O SI NO, LLAME p TE EFONO A LA OFICINA CUYA DIRECCI N E SE ENCUENTRA ESCR TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 !? N NOTICE The amount of your debt is as stated in the atlnclied document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify its within 30 days after receipt of this Notice and the attached document that the valldi(y 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 Ire obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire 1040 N. Icings Highway, Suite 500 Cherry Hill, NJ 08034 (609) 482-6900 fYs .. 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: Gateway Funding Diversified Mortgage Services, L.P. Assignee: Norwest Mortgage, Inc. Recording Date: 7/28/97 Book: 553 Page: 171 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 593-4 Geneva Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 7/24/97 DATE RECORDED: 7/28/97 BOOK: 1395 PAGE: 978 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, i f any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/22/99: Principal of debt due and unpaid $52,684.80 Interest at 7.5% from 6/1/99 to 11/22/99 (the per diem interest accruing on this debt is $10.98 and that sum should be added each day after 11/22/99) 1,921.50 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on'this account is $109.10 and that sum should be added on the first of each month after 11/22/99) 254.16 Late Charges (monthly late charge of $19.36 should be added on the fifteenth of each month after 11/22/99) 96.80 Attorneys Fees (anticipated and actual to 5%; of principal) 2.,_634...24 TOTAL $58,121.50 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, i f applicable. 8. 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 1983, has not been sent because the Mortgage is insured by the Federal Housing Administration ("FHAII) and the notice is therefore not required. WEIEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $58,121.50, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premise . Mark IJ Y Udren, MARKj'J. UDREN & Attorney for Ply Attorney I.D. Ni ."Mai • s?T u}-1 4Nanulttm?' -' X•1111 M l EHIIIBTT A ALL THAT CERTAIN UNIT, BEING UNIT NO. 593-4 (THE "UNITT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISC. BOOK 357, PAGE 20, AND III RIGHT OF WAY PLAN BOOK 9, PAGE 24, AS AMENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.71979j INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PLANS. V E R I_t'.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. Mark .J.'ddren, ESQUIRE MARK J. LTDREN & ASSOCIATES - -A o'er 11.3 DEC I 2 45 rII 'Jd I Pc I:: ;; :_Ir :I IA MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J Ud ren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. CIVIL DIVISION Charlotte, Nc 28217 Cumberland County Plaintiff = MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue : NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE. TO ANSWER-AND-ASSESSMENT-OF-DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $58,121.50 Interest per Complaint 922.32 From 11/23/99 to 02/14/00 Late charges per Complaint 38.72 From 12/15/99 to 2/14/00 Escrow payment per Complaint 327_.3.0 From 12/01/99 to 02/14/00 TOTAL $ 59 ,4 09 ._8.4 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J RE & ASSOCIATES Mar J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDDI?CnD DATE : `-1a11n() JP- y?? `"t' R PROTHY w.?Jn d V J 10 10 C-I V A U' U ,/b 11 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04_302 1040 N. KINGS H, CHERRY HILL, NJ 0 034 SUITE 500 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, Fl 32725 Defendant(s) DATED: January 14, 2000 TO: Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-7214 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 NOTIFICACION_IMP_ORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA DE SU PAR ACCION IRIDA ASO. DEBIDA DE TRO DE UN TERMINOTDEEDIEZT(10) DIAS DE ESTA NOTIFICACIONN EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE NOT?IFICACION A UN AB GADOEIMMEDIATAMEN ETSITUSTED NOBTIENE ABOGADOA O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA ESCRITA ABAJO TPARA AVERI U OFICINA, CUYA UEDE ICO SEG IR ASSISTENC A LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM SDEEMED TO BE A DEBT COLLECTOR D WZTHIS L BE SUSSED FOR? COLLECT A DEBT. ANY INFORMATION OBTAINE THAT PURPOSE. Q 4 0 d A f f? MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-7214 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF 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: Ernest P. Hartsock Age: Over 18 Residence: As captioned above Employment: Unknown rvame: Title Sworn to and subscribed Compa y: afore me this 4th day of February 2000 a- ublic JOYCE A. FIRMAM WMARY PUBLIC OF NEW MM NMRK J. UDREN, E ,Q. ATIUM Y FUR PLAINTIFF __.??? ? ? ? ? ? ?. ? ?? H; 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 Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, F1 32725 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE =NO. 99-7214 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. X_ Judgment Money Ju Judgment Judgment Judgment Judgment Judgment by Default Prothonotary dgment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY.-. __ Mark_J._Udren,_Esquire -_____ N At this telephone number: _______._6.09=4.82=69.0.0_-___.. ;r MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 !s ATTORNEY FOR PLAINTIFF ! Norwest Mortgage, Inc. :COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff v. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant is) -MORTGAGE FORECLOSURE NO. 99-7214 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 $58,121.50 Interest per Complaint 922.32 From 11/23/99 to 02/14/00 Late charges per Complaint 3$.72 From 12/15/99 to 2/14/00 Escrow payment per Complaint 12-7-3-Q From 12/01/99 to 02/14/00 TOTAL $.59. 4A9_8A I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J RE & ASSOCIATES Mar J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICA A DATE: S J _ P PROTHY SSOCIATES ATTORNEY FOR PLAINTIFF MARK J. UDREN & A BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. :COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) NO 99-7214 Civil PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 593-4 geneva drive Mechanicsburg, PA 17055 Amount due $5.9, 409_._8.4 Interest From February 15.,_200.0 1,-25.1.-7.2 to Date of Sale June-3-,_20.0.0 Per diem 0$10.98 (Costs to be added) $ MARK J. UDREN & ASSOCIATES Y I(Vk/ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF 0 l/?yW? J ` Y l ,/,u[ ? ? r V t ? ? ? ? M ? ? ? ? 3 Q ? ? ? ? ? ? ? ?:_ ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY; Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION County Charlotte, Nc 28217 Plaintiff =MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue :NO. 99-7214 Civil Deltona, F1 32725 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: ( X ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK E & ASSOCIATES MarklJ. Udren, ESQUIRE ATTO EY FOR PLAINTIFF ,?;.:,?? .:,?:?, 't i{ i? ,, 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, NJ 08034 609-482-6900 Norwest Mortgage, Inc. 'COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address ERNEST P. HARTSOCK 2475 WALKERTOWN AVE., DELTONA, FL 32725 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 mort record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lier property: Name Address NONE 11 1 . 11 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 Domestic Relations Section Commonwealth of PA, Department of Revenue 1 COURTHOUSE SQ., CARLISLE, PA 17013 13 N. HANOVER ST., CARLISLE, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 593-4 Geneva Drive, Mechanicsburg, Pa 17055 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 14, 2000 . Udren, ESQ. ev for Plaintiff .v e o' 2 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, NJ 08034 609-482- 6900 Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff =MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue .NO. 99-7214 Civil Deltona, F1 32725 Defendant (s) NOSZCE_OF_SHERIFF!S_SALE_OF REAL-PROPERTY TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, F1 32725 Your house (real estate) at 593-4 Geneva Drive, Mechanicsburg, Pa 17055 is scheduled to be sold at the Sheriff's Sale on June 7, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA, to enforce the court judgment of $59,409.84, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. YOU MAY a ABLE NOTICE O.E_O.WNER'S_RLGHTS _TO?B-aVENT THTS-,SHERIFF' C SALE .? To prevent this Sheriff's Sale, you must take iamiediate_actioa:. 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: 1EO-9J aa2-640.0_ 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.) i i iV f i; it t YOII_MAY_.STILL.. HE -ABLE---TO SAVE .YOUR PROPERTY_ AND-YOU-HAVE-OTHER-RIGHTS EV.EN_IF_THE_ SHERIFF!S_SALE_DOES_TAKE_PLACE.. ?i 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. !.r 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 (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 ASSOCIATION DE LICENCIDADOS LE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 wi--._ 0 i ALL THAT CERTAIN UNIT, BEING UNIT NO. 593-4 (THE "UNIT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISC. BOOK 357, PAGE 20, AND IN RIGHT, OF WAY PLAN BOOK 9, PAGE 24, AS AMENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.7197% INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PLANS. BEING KNOWN AS 593-4 GENEVA DRIVE PROPERTY TAX PARCEL NO. 42-24-0791-163 TITLE TO SAID PREMISES IS VESTED IN ERNEST P. HARTSOCK, SINGLE MAN BY DEED FROM SHARON F. SMYERS, SINGLE WOMAN, DATED 7/24/1997 AND RECORDED 7/28/1997 IN DEED BOOK 161 PAGE 857 r f...-_. Norwest Mortgage Inc. In lire court of Common Pleas of Cumberland County, Pennsylvania -vs- No. 99-7214 Civil Ernest P. Hartsock R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing 30.00 Poundage 1.73 Law Library .50 County 1.00 Levy. 15.00 Postpone Sale 20.00 Surcharge 20.00 $ 88.23 Pd By atty 3-15-00 So answers: Sworn and subscribed to before me This ;20 ``day of p,, I;L 1999, A.D. - ' , '- ro honotary R. Thomas Kline, Sheriff By o Real Estate Deputy ck-,, d 7f 31 joy e)3JOJo i .ti MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. 240. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-7214 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, mark J. Udsen, 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: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address ERNEST P. HARTSOCK 2475 WALKERTOWN AVE., DELTONA, FL 32725 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #3- ABOVE r 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: d Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest Amay be ddressaffected by the sale: Name REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 3-3 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 Name and address iof every nterest in ther person. of whom the plaintiff k by the property which may be affectedh knowledge who has any the sale: Address Name Tenants /Occupants 593-4 Geneva Drive, Mechanicsburg, Pa 17055 and I verify that the statements amaLde in or £i Formation t and belief. I tcD understand best of my y personal Pa C.S. sec. 4904relating torunsworn falsificationtt tauthorities. l8 s t MARK J- UDREN & ASSOCIATES DATED: February 14, 2000 Udren, ss52 for Plaintiff 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 609-482-6900 Norwest Mortgage, Inc. :COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Ave..., NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) NOTICE_OF SHERIFF!S_SALE_OF_REAL_PROPERTY TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, F1 32725 Your house (real estate) at 593-4 Geneva Drive, Mechanicsburg, Pa 17055 is scheduled to be sold at the Sheriff's Sale on June 7, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA, to enforce the court judgment of $59,409.84, 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_OWNERSS_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: 16091-482=6900- 2. 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.) .... :. _ ..mot _.4. _MAY_.STILL_BE-ABLE _TO SAVE YOUR PROPERTY.AND YOU.._HAVE_OTHER-RIGHTS N_IF__THE. SHERIFF IS_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 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 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ALL THAT CERTAIN UNIT, BEING UNIT NO. 593-4 (THE "UNIT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILO 111, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISC. BOOK 357, PAGE 20, AND IN RIGHT, OF WAY PLAN BOOK 9, PAGE 24, AS AMENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.71979 INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION 0£ CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PLANS. BEING KNOWN AS 593-4 GENEVA DRIVE PROPERTY TAX PARCEL NO. 42-24-0791-163 TITLE TO SAID PREMISES IS VESTED IN ERNEST P. HARTSOCK, SINGLE MAN BY DEED FROM SHARON F. SMYERS, SINGLE WOMAN, DATED 7/24/1997 AND RECORDED 7/28/1997 IN DEED BOOK 161 PAGE 857 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-7214 COUNTY OF CUMBERLAND) CIVIL tgC Term CIVIL ACTION - LAW TOTHESHERIFFOF Cumberland COUNTY: To satisfy the debt, interest and costs due Nonaest Mortgage Inc from Ernest P 2475 Walkertovn Avenue, Deltona, FL 32725 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell see l ec,a l r>A -?,ri jon (2) You are also directed to anach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or olherwlse disposing thereof; (3) lfproperlyof thedefendant(s) not levied upon an subject to attachment Is found In the possession of anyoneother than a named garnishee, you are directed to notify hinUher that he/she has been added as a garnishee and is enjolned as above slated. Amount Due $59,409.84 Interest from 2/15/00 to 6/7/00 Per Diem Attys Comm .% Any Paid - $111.06 Plaintiff P Date: February 23, 2000 REQUESTING PARTY: Name Mark 7 Udmn Fsa Address: IM N. Kings r;;ghway, su;rP 900 .1r119rcv Hi l t , NJ () F1014 Attorney for: _ plaintiff Telephone:.. r;09-482-69on Supreme Court ID No. 04302 L.L._ $.50 Due Prothy $1.00 Other Costs Curtis R. Long Prothonotary, Civil Division ?Yc?Deputy TRUE COPY FROM RECORD In Teaf)nlony wheraof, I here urxa set my hand and the seal of said Cattjt at Carlisle, Pa. TI 'rL?day ?.Qf othonotary , REAL ESTATE SALE No. a` prt f A , )evf-O the sheriff levied upon the defendant; interest in the real property situated in Cumberland County, Pa., known and numbered as: -• mt and more fully described on Frhibit "A'' filed with ?- this writ and by this reference incorporated herein. VW --: G. t is C8, !' LE i I 87, 031 idJ COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO: 99-7214-CIVIL NORWEST MORTGAGE, INC., Plaintiff (s), VS. ERNEST P. HARTSOCK, Defendant (s) SUGGESTION OF BANKRUPTCY AND NOTICE OF STAY Defendant(s), ERNEST PAUL HARTSOCK, A/K/A ERNEST P. HARTSOCK, respectfully shows the Court as follows: 1. The Defendant(s) filed a Chapter 7 bankruptcy proceeding under the Bankruptcy Code in the United States Bankruptcy Court, Middle District of Florida, Jacksonville Division. 2. Relief was ordered on February 17, 2000 case number 00-01162-3P7. 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on property of the estate. 4. That pursuant to 11 U.S.C. Sec. 362, the filing of that petition acts as an automatic stay against the Defendant or any property constituting the bankruptcy estate- 5. Plaintiff is therefore stayed from further prosecuting this suit against the Defendant or proceeding further in this cause. 6. This Suggestion is filed only to provide Notice of the automatic stay occurring pursuant to 11 U.S.C. §362. I HEREBY CERTIFY that a true copy of the foregoing has been mailed to Mark J. Udren, Esquire, 1040 N. Kings Highway, Suite 500, Cherry Hill, NJ, 08034, this - day of _1Pi4,-Cj4 Ernest Paul Hartsock 909 S. Knott Avenue Anaheim, CA 92804 +?*r N u`n 4-(i y U 1 f (1J C\j fV ?Lu fL U O U J MARK J. UDREN & ASSOC=ATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. :COURT OF COW40N PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff V. -NO. 99-7214 Civil Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) PRAECIPE TO_WITHDRAW_JUDGMENT TO THE PROTHONOTARY: Kindly withdraw the Judgment entered on February 23, 2000 upon Ernest P. Hartsock in the amount of $59,409.84. Defendant(s), Ernest P. Hartsock filed a CHAPTER 7 BANKRUPTCY ON February 17, 2000 CASE - #00=01162. MARK J. UDREN & DATED: June 15, 2000 Mark INT.' Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ? ? m Nll f I MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-7214 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 2.0 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 $58,121.50 Interest per Complaint 2,316.78 From 11/23/99 to 06/20/00 Late charges per Complaint 135.52 From 12/15/99 to 06/20/00 Escrow payment per Complaint 763_._7_0 From 12/01/99 to 06/20/00 TOTAL $61,337-50' I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown. above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J. UDREN & ASSOCIATES Mark J. drek, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT D DATE: -10UQ /P YO PROTHY F c u_iC? 0 03 fJ ° V l) MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL. NJ 08034 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) DATED: January 14, 2000 TO: Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-7214 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 NOTIFICACION_IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IKAEDIATAMENTE 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 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. } 7 Fi u.i C>;;.. :?:'. [>?; - :r:. i=: c. ?:. G? r? 0 :S W N _.? O O 7 O --?'. :J4 ?:1 ?? t ry L') a U ?.S?N.?? 1 ?'??. 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, NJ 08034 856-482-6900 Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. CIVIL DIVISION Charlotte, Nc 28217 Cumberland County Plaintiff : MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue :NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF COUNTY OF SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us eicher 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: ERNEST P. HARTSOCR Over 18 As captioned above Unknown Over 18 As captioned above Unknown name : Title: rn a Company: (Ita rt' (gP;eubC?11c NOTARIAL SEAL Public LE M. MENOW.PhilaNotary ry l,PPhla, . j. 2003 of Phdade a: S iaLrK__ A 23.. LMCCI?01 FOR PLAINTIFF m- cr `? G C_ 5 ? o 7 i e ij 0 U r:.r 100 11:20-AM BRRRETT BUr'KE iePS3S'?;t..cr,; P. 5/6 - ';i•ormelB(OlficinlFonn7e) n rr•; ss ?? / I UNI T O'S'I'ATE BANKRUPTCY CO T MIDDLE DISTRICT OF FLORIDA - JACKSONVILLE DIVISION In Re: HARTSOC}t. ERNEST PAUL 909 S. KNOTT AVENUE ANAHEIM, CA 92804 Case Number: 00-01 162.3p? Uhl j VIEV`L Chapter: 7 Social Security No(s).: Debtor Debtor: 18744.8004 DISCHARGE 0F DEBTOR . It appearing that the debtor is entitled to a discharge, IT IS ORDERED: 4 The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). BY THE COURT Dated: June 8, 2000 /s/ George L. Proctor ueorge? row ctor Chief United States Bankruptcy Judge SEE BACKSIDE OF THIS ORDER FOR IMPORTANT INFORMATION it IXm37 w--- ? V Jw.rr 1 i Ci r ? r co ... ' E? c._ v ? I U ? 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, NJ 08034 856-482-6900 Norwest Mortgage, Inc. :COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff =MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, F1 32725 NO. 99-7214 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---- __J. -Udren,.-. Esquire-. At this telephone number:_ _____ ._856-482,6900_____ I. I III 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 Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland Count,,, MORTGAGE FORECLOSURE Ernest P. Hartsock 2475 Walkertown Avenue :NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) PRAECIPE FOR TODGMENT 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 Plain.tiffIs damages as follows: As set forth in complaint Interest per Complaint From 11/23/99 to 06/20/00 Late charges per Complaint From 12/15/99 to 06/20/00 Escrow payment per Complaint From 12/01/99 to 06/20/00 TOTAL .> $58,121.50 2,316.78 135.52 -7-6-3-7 0. $_6.11:3.37,50. 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. DAMAGES ARE HEREBY ASSESSED AS DATE: JL&,)F 249t ;;2(' MARK J. UDREN & ASSOCIATES Mark J. Udre , ESQUIRE Attorney for Plaintiff I INDICATED RP O PROTHY MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 'COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. , Ernest P. Hartsock 2475 Walkertown Avenue :NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 593-4 Geneva Drive Mechanicsburg, PA 17055 Amount due $61,_337._50 Interest From June_21,__200.0 1,855.62 to Date of Sale December-6,.-200-0 Per diem 0$10.98 (Costs to be added) MARK J. UDREN & dren, ESQUIRE FOR PLAINTIFF 1 { > Co c u ° 7S z;? _ rT r ^?" ` N i, .. :cz ?D- : 1 t I n L J J 4 o .tf- M ?' ?a r?c IN I = III c. Y ATTORNEY FOR PLAINTIFF i t MARK J. U=REN & ASSOCIATES ?,. BY: Mark J. Udren. Esquire !a. .D. N0. 04302 IT ,TTY I gINGS HIGHWAY, SUITE 500 3.040 N- CHERRY HILL, NJ 08034 856-482-6900 COURT OF COMMON PLEAS Norwest Inc. :CIVIL DIVISION 5024 parkway way Plaza Blvd. ?- 024 p Cumberland County Charlotte, Nc 28217 .MORTGAGE FORECLOSURE Plaintiff V. Ernest P. Hartsock .NO 99-7214 Civil 2475 WalkFlt wn Avenue Deltona, 32725 Defendant (s) C E R T I F I CAT E t he is the attorney for , Esqui.re, hereby states tha e Mark J. Udren tinned bemattercause and it isthat the premises ar not the Plaintiff in the above-cap subject to the provisions of Act 91 : ( X ) An FHA insured mortgage ( ) Non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulf illed. Over 24 months delinquent. made subject to the penalties of 18 Pa. C.S. This certification is lsificatio Sec. 4904 relating to unsworn fan to authorities. MARK J. UDREN & ASSOCIATES Mark;J. dren, ESQUIRE ATTOi EY FOR PLAINTIFF ?f j4 It ? t ? I t. t r i m 3 CV tl' Z J3 Cu v ? U r 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 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 __._._.__I Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of owner(s) or reputed owner(s): Name Address ERNEST P. HARTSOCK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE :NO. 99-7214 Civil 2475 WALKERTOWN AVE., DELTONA, FL 32725 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. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 0 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 593-4 Geneva Drive, Mechanicsburg, Pa 17055 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 1S Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: June 20, 2000 , ESQ. Plaintiff i l IT i 1. r+ b a3 F= ? > i N CC7 saw i? j ;... >i 1 1 a ° Cl " 11 .4 / MARR'J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. N0. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue :NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) NOTICE_OF__SHERIFF_, S _ SALE.- OF- REAL- - PROPERTY TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, Fl 32725 Your house (real estate) at 593-4 Geneva Drive, Mechanicsburg, pa 17055 is scheduled to be sold at the Sheriff's Sale on December 6, 2000, at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $61,337.50, 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_T0_P.REVENT_THIS_SHERIFF2.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)-482m6900. . 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 RIGKTS EVEN _IF_THE_SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff's Sale is not stopped, your property will be sold to the 1. highest bidder. You may find out the price bid by calling 856-4B2-6900. 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 85'-482-6900 1 amount due in the sale. To find out if this has happened, you may never happened to the Sheriff, you will remain the owner of If the t p openY d as fif the sale rom the Buyer is not paid 5, You have the right to remain in the property until the full amount due 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 exceptions money will be paid out in accordance withtthiswschedule receiving that will be money. 3The days after within (reasons y the Scproposed distribution is hedule of Distribution wrong) are filed with the Sheriff within ten is iled. 10) days 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT T WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 72.7-249-3166 '00 11:23AM BARRETT BURKE rl"" ,'-arm BIB (OtliNN Form 1e) y (4/9B) 9, ? (?r `S UNIT?STATE6 BANKRUPTCY COURT MIDDLE DISTRICT OF FLORIDA-JACKSONVILLE DIVISION In Re: HARTSOCK. ERNEST PAUL ANAHEIM, C 92804UE NC, Case Number: 00.01162-3P7 .lW16 10 Chapter: 7 ) Debtor ) Social Security Nola).: Debtor. 187-44.8004 DISCHARGE.00 DEBTOR It appearing that the debtor Is entitled to a discharge, IT IS ORDERED: P.5/6 The debtor Is granted a discharge under section 727 of title 11, Unted States Code, (the Bankruptcy Code). BY THE COURT Dated: Juno 8, 2000 /s/ Geor a L. Proctor eorge roctor Chief United States Bankruptcy Judge SEE BACK SIDE OF THIS ORDER FOR IMPORTANT INFORMATION 017737 i4 l? l i ?n y 3 a; •. Ci J/ - _ C G I 11-u i1 co C3 U ALL THAT CERTAIN- UNIT, BEING UNIT NO. 593-4 (THE "UNIT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBEILAND COUNTY IN MISC. BOOK 357, PAGE 20, AND IN RIGHT. OF WAY PLAN BOOK 9, PAGE 24, AS AENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.71978 INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM Vm DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS A-mPLICABLE TO T17Z UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PLANS. BEING KNOWN AS 593-4 GENEVA DRIVE PROPERTY TAX PARCEL NO. 42-24-0791-163 TITLE TO SAID PREMISES IS VESTED IN ER?NEST P. HARTSOCK, SINGLE MAN BY DEED FROM SHARON F. SMYERS, SINGLE WOMAN, DATEr.. 7/24/1997 AND RECORDED 7/28/1997 IN DEED BOOK 161 PAGE 857 't 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, NJ 08034 856-482-6900 Norwest Mortgage, inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. CIVIL DIVISION Charlotte, Nc 28217 Cumberland County Plaintiff V. = NO. 99-7214 Civil Ernest P. Hartsock 2475 Walkertown Avenue Deltona, Fl 32725 Defendant(s) PRAECIPE TO_FILE_PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. MARK J. UDREN & ASSOCIATES Date: August 18, 2000 Hark J. Udr/en, ESQUIRE Attorney "br Plaintiff V--- ._ t .5. PREMIER PROCESS SERVICES, LLC. Po Box 8271 Cherry Hill, NJ 08002-02 (610)766-0296 or fax (856)740-3651 VERIFICATION OF SERVICE Plaintiff(s): Norwest Mortgage, Inc. Court Term & No. 99.7214 Civil V5. Defendant(s): FILE# 9918141 ATD County Ernest P. Hartsock Cumberland Name of Defendant(s) to Serve: ERNEST P. HARTSOCK Civil Action Complaint in Mortgage Foreclosure Serve _Civil Action at: 2475 WALKERTOWN AVENUE -Writ .XX__Notice of Sheriffs Sale___.. _ DELTONA FLORIDA 32727 _-Other - Special Instructions PLEASE MAKE THREEMATTEMPTS AT SERVICE AND SERVE BY AUGUST 14,2000 SERVED AND MADE KNOWN TO on the day of 20 _, at o'clock M, at Commonwealth of Pennsylvania, in the manner described below: - Defendant(s) personally served - Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s) residence who refused to give name or relationship. Age Height Weight Race Sex Other On the 3rd dayof_ Aua,ct 20M, at 2-54 pm o'clock M, DEFENDANT NOT FOUND BECAUSE:- Moved - Unknown xNo Answer - Vacant- Other ATTEMPTS MADE AND COMMENTS: 7/24 7:30 am, no answer 7/29 9:00 am, no answer The undersigned understands that the statements herein set forth above are made subject to the penalties o 8 a. .. ?1eS S"ction 4904 relating to unswom falsification to authorities. Sua -Biyu,}?i Date__ p/3/nn Process Server/Competent Adult If L C v 1l) 7 17 ci C> I? it S i MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. NO. 99-7214 Civil Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) PRAECIPE_TO__FILE. PROOF_-OF -SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. MARK J. UDREN & ASSOCIATES Date: October 26, 2000 C BY Mark J. Udr n, ESQUIRE Attorney for Plaintiff i Y 10/2.1/2000 TUE 15:09 FAX 813 273 0344 CHOICE LEGAL r AFFIDAVIT OF SERVICE State of NEW JERSEY County of CUMBERLAND Case Number: 99.7214 Court Date: 12/6/2000 Plaintiff: NORWEST MORTGAGE, INC., 5024 PARKWAY PLAZA BLVD., CHARLOTTE, NC 28217 VS. Defendant: ERNEST P. HARTSOCK, 2475 WALKERTOWN AVENUE, DELTONA, FLORIDA 32725, For: Mark J. Udren MARK J. UDREN AND ASSOCIATES 1040 N Kings Hwy Ste 500 Cherry Hill NJ 08034 (21002/002 Common Pleas Court Received by CHOICE PROCESS - TAMPA on the 28th day of August, 2000 at 2:30 pm to be served on ERNEST P. HARTSOCK, 909 S. KNOTT AVENUE, APT. 108, ANAHEIM, CA 92804.. I, CAILOS ANGELES/SOUTHLAND ATTORNEY SERVIC, being duly sworn, depose and say that on the 30th day of August, 2000 at 6:09 pm, l: INDIVIDUALLY SERVED: The within named person with a true copy of this NOTICE OF SHERIFF'S SALE OF REAL PROPERTY with the date and hour endorsed thereon by me, pursuant to F.S. 48.031(1) and informing said person of the contents thereof. MILITARY STATUS: Bases upon inquiry of party served, defendant is not in the military service of the United States of America. I certify that I am over the age of 18, have no interest In the above action, and am a certified process server, in good standing, in the judicial circuit in which the process was served. CA/LOS ANGELES/SOUTHLAND ATTORNEY SERVIC Subscribed and Sworn to before me on the 24th day of October, 2000 by the affiant who is CHOICE PROCESS -TAMPA personally known to me. P.O. Box 1215 Tampa, FL 33601 NOTARY (813) 229-1444 PUBLIC Our Job Serial Number: 2000006674 cw"Ignl 91002-IMcablbae Se m. me. - Pexse, es TWbe, VS.Ov r r a? r c , ? 'z d u i ='_ L3 t r CZ ? _ G u. i ) J C) U 1 •j f i ?s MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, No 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) NO. 99-7214 Civil 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 Sheriffs 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 'IS". 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: November 7, 2000 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NOT 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 NO. 99-7214 Civil Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address ERNEST P. HARTSOCK 909 S. KNOTT AVE., APT. 108, ANAHEIM, CA 92804 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. 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 i n 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 593-4 Geneva Drive, Mechanicsburg, Pa 17055 I verify that the statements made in this affidavit are true and correct t 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: NOVEMBER 7, 2000 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 Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock - -- 2475 -Walkertown -Avenue Deltona, F1 32725 Defendant(s) DATE: July 7, 2000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-7214 Civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL_P.ROPERTY. OWNER(S): ERNEST P. HARTSOCK PROPERTY: 593-4 Geneva Drive Mechanicsburg, Pa 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the -Oumbe=land County Sheriff's Sale on Dec.ember_6 _2.0.0.0., at 10:00 AM, Our at the records COMMISSIONERS HEARING ROOM 2ND FLOOR COURTHOUSE CARLISLE PA_ indicate that you may hold a mortgage or judgmen on the Property which will be extinguished by the sale. You may witsh 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. EXH1BITA i` y i k r ' ) i 1- Y ? 0 Y m ,y Y u`N V tnLL r `a t C Oc`o °?a ?LL ? A Y tEo E `u E9- °$O nuo GNU LLD m r 6 u m ? O m 2m = u<uu m 9 u v a d d ? n O' a o ?«ov RSUU ? oao? m L N co m c F W W O l r UOO a° °? r ` Ny}O c pp V' C U<3Z m d Z ?e 0 Lu I! E J wr Y QOU'tr SL r m ? sS t J V a Y2 ¢ s ?ZU e p T?- Q ? v° E lSl L ? V O Z ? Y ' ry n 9 C Z p0c z? Eam Z<O J r N n1 _V 4 a$ ?31 HiIll a$ b 411 4 111 Ye2E?7 1 ?a CL ss ?? e D ??44a6 m ba{ b b {,'F ?' v jQ(pGGS} F ? ? O F d i LE ? Y CL L L d a E 0 U a a •° L IL P ,L OD - 01000 ra M lF f Q m CUMtFO? i o ? ? ? ? I9n ?A 4 Z Q O ?I O a ? ?Y u v z?? I •o r w {gym . ? .... CJ O 00 I m V O w I o OD O O N a lL N J a t PV 10:35 F-AX 8187664837 SOUMLAND 1@001 VERIFIED RETURN OF SERVICE State of NEW JERSEY I CUMBERLAND County District Court Case Number. 99-7214- CIVIL I Case Name: NORWEST V. HARTSTOCK Received by Gordon Stephens- on 08/29/00 at 10:00 a.m. to be served ORIGINAL ERNEST P HARTSTOCK . FILED WITH COURT 909 S KNOTT AVE., # 108, ANAHEIM, C .92804. 1 do hereby affirm that 08130100 at ? 6:09 PM, I DID SERVE this NOTICE OF SHERIFF'S SALE OF REAL PROPERTY by serving ERNE T P. HARTSTOCK, at the above address. At the time of service, deponent asked ERNEST P. HA TSTOCK if Servee is in active military service for the United States of America or for the State 1 any capacity whatever and received a negative reply. I' I do hereby ackno that I am a Registered Process Server in Califomia in accordance with Califomia ws, a Vha ntere n the above action. I declare under penalty of perjury that the for ' g is trine an nd is declaration was executed on October 13, 2000 at Los enr?et r..ra....:_ Registered Process Serder CHOICE PROCESS- TAMPA PO BOX 1215 TAMPA, FLORIDA 33601 Ref_2000006674 sas #6893 STATE OF CALIFORNIA COUNTY OF LOS ANGELES ISAIAS MEDIPIA COMM. s 1167705 NOYAAY PG6LIC.C4uFONNIA LI LOSANGELF.., COUNtt Q COMM. py. J4N.2, 2002 -' WITNESS my hand and official seal. (SEAL) ISAIAS MEDINA NOTARY I , 00HIBIT B i >. c ? [?- ,r, c: ? ^ _: ' C c:- y. ' ?..i ?.? ; n ?? ' , i'. i ?.I . C ? ? ` .' ? J (J .i fy?.. _ ..,.? 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 Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff V. Ernest P. Hartsock ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County 2475 Walkertown Avenue NO. 99-7214 Civil Deltona, F1 32725 Defendant (s) ORDER OF COURT AND NOW, this A day of ZZJ71J2?'1 20 a(, it is hereby ORDERED that Sheriff Sale of premises located at 593-4 Geneva Drive, Mechanicsburg, PA 17055 shall be relisted by the Cumberland County Sheriff's Department for the March 7, 2001 Sheriff Sale; and IT IS FURTHER ORDERED that a copy of this Order be served upon the Defendant, Ernest P. Hartsock, the Cumberland County Sheriff fIs Department and Edward Schorpp, Solicitor and any lienholders of record within S D days of the date of this order. BY THE COURT: _ ?., :? i .' .,.?:i; c, ?. ,_ ?..., . ?? MARR J. UDREN & ASSOCIATES BY: Mark J. Udrea, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS =CIVIL DIVISION :Cumberland County V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) NO. 99-7214 Civil MOTION TO_RELIST PROPERTY--F-OR_SHERIFF SALE Plaintiff, Norwest Mortgage, Inc., by its attorneys, Mark J. Udren k Associates, moves this Honorable Court to Order a relisting of property for sheriff sale, and in support thereof avers as follows: 1. On December 1, 1999, Plaintiff, Norwest Mortgage, Inc., (hereinafter referred to as "Plaintiffl% instituted foreclosure proceedings regarding real property located at 593-4 Geneva Drive, Mechanicsburg, PA 17055 (hereinafter referred to as "the Premises"). See true and correct copy of first page of filed foreclosure complaint attached as Exhibit "A". 2. As a result of a judgment in foreclosure entered on June 28, 2000, and after due and proper Notice, a Sheriff sale of the Premises was held by the Cumberland County Sheriff's Department on December 6, 2000. 3. Prior to the Sale and in accordance with the Pennsylvania Rules of Civil Procedure, Plaintiff properly advertised the premises for sale and duly served any and all recorded lienholders and any other interested party with the Notice of Sheriff IS Sale. See true and correct copy of Notice of Sheriff's Sale of Real Property and Affidavit of Service Pursuant to Pa.R.C.P.Rule 3129.1 attached hereto as Exhibit "B". 4. On December 6, 2000, the date of the sale, the Sheriff offered the Premises for sale. 5. No one appeared at the Sheriff sale to bid and/or otherwise purchase the subject premises. As a result, the Sheriff marked the file "closed". 6. Undersigned counsel for Plaintiff discussed this matter with Edward Schorpp, Esquire, Solicitor (hereinafter referred to as "the Solicitor'I)for the Cumberland County Sheriff's Department. 7. The Solicitor agreed to allow the property to be relisted for the Sheriff Is Sale scheduled for March 7, 2001. e. The Sheriffs Department has no objection to the premises being relisted for the Sheriff Is Sale scheduled for March 7, 2001. 9. Plaintiff desires that the subject premises be relisted for Sheriff Sale on March 7, 2001 so as to purchase the Premises as attorney on the Writ, reflecting the fact that nobody, after due and proper advertisement and notice, appeared to bid for the Premises. But for the Sheriff "closing" the Sale, a Sheriff's Deed Poll could have gone to the Plaintiff as attorney on the Writ. WHEREFORE, Plaintiff prays and respectfully requests that the Honorable Court Order that Sheriff Sale in the within matter be relisted by the Cumberland County Sheriff Is Department fgx'March 7, 2001. Respectfully /s?ubmitte , Mark J. Uauew Ass ciat BY: , Inc. 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, that he is authorized to take this Verification and does so because of the exigencies regarding this matter; and that the statements made in the foregoing Motion to Relist Property for Sheriff Sale are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of IS Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ESQUIRE & ASSOCIATES Copy MARK J. UDREN & ASSOCIATES By: Mark J. Udren, Esquire ATTY I.D. No.. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 82-6900 ATTORNEY FOR PLAINTIFF 609-4 Norwest Mortgage, Inc. COURT OF COMMON PLEAS ;CIVIL DIVISION' 5024 Parkway Plaza Blvd. Cumberland County Charlotte, Nc 28217 Plaintiff v. n _ o Ernest P. Hartsock .rte / y No. 99- _oco rn _' M 2475 Walkertown Avenue T? T'o Deltona, Fl 32725 co 66 Defendant (s) COMPLAINT IN MORTGAGE FORECLOSURE ?p o O M YOU HAVE BEEN SUED IN COURT. If•you wis14 to defend against ?ile slam set forth in the following pages, you must take action entering nwritten days after this complaint and Notice are served, by 4 a appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against without youou are warned that if you fail to do so the case may proceed and a r notice judgment may be entered against you by the Court ithoutcfurther relief for any money claimed in the Complaint or for any ert or' other requested by the Plaintiff. You may lose money or prop y rights important to you. THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE YOU A SHOULD TARE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORT BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICF Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ? 1 •II', 4 1 11 MARK a- UDREN & ASSOCIATES BY: Mark J. Udren ATTORNEY FOR PLAINTIFF ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd COURT OF COMMON PLEAS . Charlotte, Nc 28217 :CIVIL DIVISION Plaintiff Cumberland County C CD V. - Ernest P. Hartsock =. 2475 Walkertown Avenue Delto :NO. 99-7214 Civil " - -` na, F1 32725 befendant (s) ?J 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 is Sale, 'fa true and correct copy of which is attached hereto as Exhibit °A°, was sent to every recorded lienholder and Prae ipe other for theeWrit eof Ex cut on on the of date the date of (s) appearing eon filing of the Certificates of,Mailing. he attached 2. A Notice of Sheriff is 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 "Bn. 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 "Bit. 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit :,El:. 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: November 7, 2000 MARK J. UDREN &• ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udrea, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. :COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 Walkertown Avenue NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Mortgage, Inc., Plaintiff in the (above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address ERNEST P. HARTSOCK 909 S. KNOTT AVE., APT. 108, ANAHEIM, CA 92804 i 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. 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. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 COURTHOUSE SQ., CARLISLE, PA 17013 13 N. HANOVER ST., CARLISLE, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 593-4 Geneva Drive, Mechanicsburg, Pa 17055 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 unswor3i falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: NOVEMBER 7, 2000 Mark J. Udr n, 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 Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff V. Ernest P. Hartsock -- --- -2475.-Walkertown-Avenue, --- Deltona, F1 32725 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-7214 Civil- I DATE: 17uly 7, 2000 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE QF REAL PROPERTY OWNER(S) : ERNEST P. HARTSOCK IF PROPERTY: 593-4 Geneva Drive Mechanicsburg, Pa 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cuumherland County Sheriff's Sale on I)Ac_ember 6 2000, at 10:00 AM, at the COMMISSIONERS HEARING ROOM 2ND FLOOR COURTHOUSE CARLISLE PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. E"---- - - l E iISITA Y Y ? noosa .b ? ' E ? l ? ti . ' ? €g 4Ftn$ s s gr ; 5 l o E? S? m e = 0 iu v ? 0 ? .. n ? S E O3 ? ml O V C' Y g bgEB 5 {' =? mm^ S ?LL ,y p Gi p za °BE I ` `o g o g ji 5 m - m? o yy e c> €L m ? ?' ? ECEGLE fi E $ a E n 5. pm O 7u va' ??dl+? 0 ?„ n ' Y aV fi i 4R ? gg ?fi ? ? W eo. p 8 Yl.C ma?? m `2 maa^i? a lp 9 E3 N E r }Q ? S E D n ?63I C ° u mph m Emm .Gm r n m ??ri m E v a°. a Y y m p? mm0 C Sou ??O? m 3 E 4 f2 0 i ?. m 1 IW- W O rr F Q " ` M `u (? ?? o n E 0> m 2 t^ 3E w 'o LL?'? 0 L ^ 3oyy n u i ? 1 Yp J?zi a - • ?v ?'? ' a 1 ?a o v i .-- E? 0 ? i_ o zm e o m ? u \ aT? ?- C m i eU C m ? 'j' Cam. { J V Y mdC m LT U t E D Eaw m¢r Z 0 zi O N t ? e m m 9 „ N I ?1 Q ? 7 f D 1 ? o ? 0 ) J w 10 00 J ON 0o0 NI t J ]I. i Gu{{??Mr11_Fc m os O I ,?,' m 2 m. P bOm ?DVO O w O CAN co 10:35 F.AL 8187884837 SOUTHLAND IM 001 VERIFIED Case Number. Case Name: 99-7214- CIVIL NORWEST V. Received by Gordon Stephens- on 08/290 at 10:00 a.m. to be served ORIGINAL ERNEST P HARTSTOCK . FILED WITH COURT 909 S KNOTT AVE., # 108, ANAHEIM, C1. 92804. I do hereby affirm that 08/30100 at 6:09 PM, 1 DID SERVE this NOTICE OF SHERIFF'S SALE OF REAL PROPERTY by serving ERNE T P. HARTSTOCK at the above address. At the time of service, deponent asked ERNEST P. HA TSTOCK if Servee is in active military service for the United States of America or for the State Ih any capacity whatever and received a negative reply. I do hereby ackno that I am a Registered Process Server in California in accordance with Califomia ws, a he nter n the above action. I declare under penalty of perjury that the for g is an is declaration was executed on October 13, 2000 at Los Ange , California. CHOICE PROCESS- TAMPA PO BOX 1215 TAMPA, FLORIDA 33601 Ref:2d000o6674 sas #6893 STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) WITNESS my hand and official seal. ISAIAS MEDINA5 Q cOFAM, s 1107n -? NOTARY PUSU=AUFORWA LI LOSANGELEScOUNiY 0 OOMlI. EXP. JAN. 7.2002 " (SEAL) ISAIAS MEDINA NOTARY PU LIC 1 rs"rii81T S i , ¦ II ? c.n! t• y MARK J. UDREN & ASSOCIATES BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc 5024 Parkway Plaza Hlvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS = CIVIL DIVISION :Cumberland County V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 :NO. 99-7214 Civil Defendant(s) PLAINTIFF! S_MEMORANDDI•S_OF LAW _• Facts. Plaintiff relies on the recitation of facts set forth in the attached Motion and incorporates same as if fully set forth herein. I=• Argument. Withdrawal of the subject Premises from Sheriff Sale was conducted in error. The Premises were properly advertised for sale in accordance with the rules of civil procedure. Likewise, all Defendants, recorded lienholders and every other interested party was duly served with the Notice of Sheriff is Sale. See, Exhibit "B" attached hereto. Thus, relisting of the premises for Sale confers no prejudice nor detriment to the Defendant who failed to enter an appearance in this matter and did not bid nor otherwise attempt to pursue any interest he may have had with regard to the Sheriff Sale of the premises on December 6, 2000. But for the Sheriff "closing" the sale, the Plaintiff would have obtained a Deed from the Sheriff as attorney on the Writ. Plaintiff stands to suffer significantly to its detriment if the property is not relisted for Sheriff Sale. Plaintiff has expended significant resources in prosecuting the within foreclosure action necessitated by the Defendant's failure to repay the underlying loan obligation in this matter. The Sheriff's Department does .ot object to relisting of the sale and by and through its Solicitor, has consented to allow the premises to be relisted for sale on March 7, 2001. By: Respectfully Submitted, N7r dren, Esquire Attorney for Plaintiff/Movant Norwest Mortgage, Inc. i is 1 MARK J. UDREN & ASSOCIATES 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 -69 00 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff V. Ernest P. Hartsock ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS =CIVIL DIVISION :Cumberland County 2475 Walkertown Avenue NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) CERTIFICATE- _OF-SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of Plaintiff's Motion to Relist Property for Sheriff Sale upon the following person named herein at their last known address or their attorney of record. _XXK Regular First Class Mail Date Served: December 29, 2000 TO: Edward Schorpp, Solicitor Ernest P. Hartsock 10 E. High Street 2475 Walkertown Avenue Carlisle, PA 17013 Deltona, Florida 32725 Cumberland County Sheriff's Department Cumberland County Courthouse One Courthouse Squara Carlisle, PA 17013 MARK J. Q & ASSOCI BY: ark dren, Esquire Attorney for Plaintiff/Movant Norwest Mortgage, Inc. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant (s) NO. 99-7214 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant (s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January 30, 2001 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, Nc 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. _NO. 99-7214 Civil Ernest P. Hartsock 2475 Walkertown Avenue Deltona, F1 32725 Defendant(s) DATE: January 15, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL-PRQPERTY OWNER(S) : ERNEST P. HARTSOCK PROPERTY: 593-4 Geneva Drive Mechanicsburg, Pa 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumber-land county sheriff's sale on March,-2.091, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR COURTHOUSE CARLISLE PA Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. L::.:: ;TES L - nr -?._ bE ? .. C u ^ ¢ Hsu! F p??nc ? 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I iy m _ n _¢ o? 3y° G- 6 d ? ? q Y N$ L C m v ¢I'Ifl ?? nn$ LL a N E`?'m rn ¢.Sw LL En m Br 18Y 21 .I 1 1 1 I Rm d 0 0 W yi Q ¢ 3 OU? $ M(Q= H UQ6o- m LL uj N $ OWZ~ J (n 5Z z ?o v (rr C ,m - 3 m s .0 m E W e s 'm R 0 E `m a E ° 3 c F a m m c E U 18 1 m_ Z 2 m li » v g co mmd Ea C9 a Zo € 2a J N M V' IA t0 h N Or r co v Lo S N a IIG1111 nonciiinnn w inj i00 Case Number. Case Name: 10:35 FAX 8187004837 VERIFIE[ )f NEW JERSEY 99-7214- CIVIL NORWEST V. Received by Gordon Stephens- on ERNEST P HARTSTOCK 909 S KNOTT AVE., A 108, ANAHEIM, SOVML?ND N OF SERVICE at 10:00 a.m. to be served GRIGINAL FILED WITH COURT 92804. I do hereby affirm that 08/30/00 at 06:09 PM, I DID SERVE this NOTICE OF SHERIFF'S SALE OF REAL PROPERTY by serving ERNEST P. HARTSTOCK, at the above address. At the time of service, deponent asked ERNEST P. HA TSTOCK if Servee is in active military service for the United States of America or for the State 6 any capacity whatever and received a negative reply. I do hereby ha that I am a Registered Process Server i California in accordance with Califomia ws, a a ha nteres "n the above action. . I declare under penalty of perjurythat the for g is tru an c e nd is declaration was executed on October 13, 2000 at Los Registered Process Seller CHOICE PROCESS- TAMPA PO BOX 1215 TAMPA, FLORIDA 33601 Ref 2000006674 sas #5893 STATE OF CALIFORNIA COUNTY OF LOS ANGELES WITNESS my hand and official seal. Wt' ISAIAS MEDINA NOTARY 0 ISAIAS MHDIy O _ NOTARYPUBL7Ctq? ORNIAQ < LOS sWGEL.ES COUNTY n COMm, DD'. JAN. Z, 2002 (SEAL) i ns: i NZRR J. IIDREN & ASSOCIATES BY: Mark L r. Uftem, Esquire ATTr I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 C3MRY WILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Mortgage, Inc. 'COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CI= DIVISION Charlotte, NC 28217 _Cumberland County Plaintiff V. Ernest P. Hartsock 2475 Walkertown Avenue NO. 99-7214 Civil' Deltona,. F1 32725 Defendant (s) ORDER OF COURT AND NOW, this 6i'?4 day of ( 200% , it is.hereby ORDERED that Sheriff Sale of premises located at 593-4 Geneva Drive, Mechanicsburg, P2L.17OSS shall be ie13.sted by the Cumberland County' Sheriff !s Depax-tmext for the March 7, 2001 Sheriff-Sale; and IT IS FURTHER ORDERED that a copy of this Order be served upon the Defendant, Ernest P. Hartsock, the Cumberland County Sheriff's Department and Edward schorpp, solicitor and any lienholders of record within 30 days of the date of this Order. BY THE COURT= COPY T TRU8 COPY FROM RECORD M Te3tiwny4tlme3, l race um.0 set my Woo and ft 3" of safe Cm 91 G±*. PG-. at J STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND Robert P Ziegler h ------------------------------ t Ss. ------ ---------------------------- --- Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which WElls Fargo Home Mtg Inc ------------------------------------ is the grantee the same having been sold to said grantee on the ___ 7th March -------------------------------------------- day of --Execution - June day of -------__--- Civil Number _____??14____, at the suit of °--- -- A. D. 01 - _, under and by virtue of a writ_________ --------------- issued on the -------------- 28th- ---------------- 00 A. D., _____, out of the Court of Comman Pleas of said County as of 1999 ------------------------------------------------ Term,: Norwest Mtg Inc •"-"-" ----------------------------------- against ___ Ernest-P Ilartsock 410 duly recorded in Sheriffs Deed Book No--------- 41_, Page ------------- is IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 2i---- day of - - -- - -- o2^t ?`_-7- -- R=rder of Deeds Norwest Mortgage, Inc. -vs- Ernest P.Hartsock In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-7214 Civi I R. Thomas Kline Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Shcriffmailed a notice of the pendency of the action to the defendant Ernest P.1-lartsock by Certified Mail Return Receipt Requested, Restricted Delivery Deliver To Addressee Only to his last known address 2475 Walkertown Avenue. Deltona, FL. This letter was mailed under the date of October 4, 2000 and returned to the Sheriff's Office on October 10, 2000 with reason checked MOVED LEFT NO FORWARDING ADDRESS. Kathy J. Clarke, Deputy Sheriff, who being duly sworn according to law, says on October 5, 2000 at 3:15 o'clock P.M. EDST, she posted a coy of Real Estate Writ Notice Poster and Description on the property of Ernest P. I-Iarlsock located at 593-4 Geneva Drive, Cumberland County Pennsylvania according to law. R. Thomas Kline, Sheirff who being duly sworn according to law, says 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 defendant to wit: Ernest P. Hartsock by regular snail to his last known address 2475 Walkertown Avenue, Deltona, FL. This letter was mailed under the date of October 18, 2000 and returned to the Sheriff's Office on November 2, 2000 with reason checked moved left no forwarding address. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7, 2001 at 10:00 o'clock A.M., E.S.T. and sold same for the sum of $1.00 to Attorney Dale Shughart for Wells Fargo Home Mortgage Inc. f/k/a Norest Mortgage Inc. It being highest bid and best price received for the same Wells Fargo Home Mortgage Inc. f/k/a Norwest Mortgage Inc., of 405 SW 5°i Street, Des Moines, IA 50328, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $737.55 it being costs. Sheriff's Costs Docketing $30.00 Poundage 14.46 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 20.00 County 1.00 Mileage 6.82 Certified Mail 7.02 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 242.15 Patriot News 216.60 Share of Bills 23.00 Distribution of Proceeds 25.00 Sheriff's Deed 50 $737.55 Sworn and Subscribed to Before Me This •5 Day of 2001, A.D. (2t .. l. grro honotary So Answers: R. Thomas Kline, Sheriff BY 0Ct IV( -d Deputy Sheriff t- _;c of . ?• ID5fv4 MARK J. UDREN k ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 DT. KINGS HIGHWAY, SUITI: 500 CHERRY HILL, NJ 08034 656-482-6900 ATTORNEY POR PLAINTIFF Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. :CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Ernest P. Hartsock 2475 VIalkertown Avenue NO. 99-7214 Civil Delt:ona, F1 32725 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 593-4 Geneva Drive, Mechanicsburg, Pa 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Addressi ERNEST P. HARTSOCK 2475 WALKERTOWN AVE., DELTONA, FL 32725 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 Addresst NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 1 G. Name and address of every other pe rson who has any record interest, in Name the property and whose interest may `'c affected by the sago; Adri, -mss REAL, ESTATE: TAX DEPT. 1 COURTHOUSE S c Q• , 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 ha the s sale: who has any interest in the property which may be affected by the sale: Name Addy, s Tenants/Occupants 593-4 Geneva Drive, Mechanicsburg, Pa 17055 -T verify that the statements made in this affidavit are truce to the best of my personal knowledge or information and and correct understand that false statements herein are made subject to the penal I belf. of 18 Pa.C.S. sec. 4904 relating to unsr,5orn falsification to authorities. ties MARK J, ODREN & ASSOCIATES DATED; June 20, 2000 . r Mark J. U ren, ESQ. Attorney or Plaintiff , i MARK J. UDREN & ASSOCIATES ATTOR14E FOR PLAINTIFF BY: Mark J. Udren, Esquire ATT'I.D. NO. 04302 10,10 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Mortgage, Inc. COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. : CIVIL DIVISION Charlotte, Nc 28217 :Cumberland County Plaintiff : MORTGAGE FOP.ECLOSURE V. Ernest P. Ffartsock 2475 Walkertown Avenue NO. 99-7214 Civil Deltona, F1 32725 Defendant(s) NOIICE_OF__SHERIEF!S_SALE_OF--REAL_PROPERTY TO: ERNEST P. HARTSOCK 2475 Walkertown Avenue Deltona, F1 32725 Your house (real estate) at 593-4 Geneva Drive, Mechanicsburg, Pa 17055 is scheduled to be sold at the Sheriffs Sale on December 6, 2000, at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $61,337.50, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next .railable Sale. NOTICE-OF O.WNER!S_RIGHTS YOU-MAY-BE-ABLE TO-PREVENT THIS-SHERI£FLS-SALE To prevent this Sheriff's Sale, you must take immediate-ac_tion:. 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: _085.6).._4-82=630.0_.. 2. You may be able to stop the sale by filing a petition asking the Court to strike of 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 41 EVEN-IF--THE SHERIFFS SALE DOES.-TAKE 'C.ACE. f 1. If th-d Sheriff's Sale is not stopped, your property wi.i oe sold to the highest bidder. You may find out the price bid by calling H96-482-6000. 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 th^ buyer pays the Sheriff LM full amount due in the sale. To find out if this has happened, you may call 856-182-6900. a 4. IS the amount due from the Buyer is not paid to the Sheriff, you will remain i the owner of the property as if the sale never happened. I 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 thy: buyer. At that time, the buyer may bring legal pr,.?ceedings 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 mill be filed by the Sheriff: within 30 daps 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. 1 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 Hai Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS.DE FILADELFIA-_ Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-31,66 ??.-•i?v..'.. . 100 11:234il1 6RRRE11 F;i!Nr;E 'corm a1B (Official Form 14) F ?a> UNI`I"I i i 3`IATE A&-`?:RUPTC`f (:''ORT ivIlD •ILE DISTF111 `I' OF FLORIDA - JACKS 0"NIJILLE DIVISi.). ! In Fie: H--ITSOCK EVINESTPAUL gog S. PtP?IOTT AVENUE ANAHEIM, CA 92804 r f i Case Number: 00.01162-3PY Chapter: 7 Debtor Sxial Security PJo{:;;.: Debtor: 18744-8004 DISCHARGE-00 DEBTOR It appearing that the debtor is entitled to a discharge, BT IS ORDERED: P. 5/6 The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). Dated: June 8, 2000 BY THE COURT /s/ Geor a L. Proctor ,Z`-eorge . roaor Chief United States Bankruptcy Judge SEE BACK SIDE OFTHIS ORDER FOR IMPORTANT INFORMATION C-1 M"M ALL THAT CERTAIN UNIT, BEING UNIT NO. 593-4 (THE "UNIT"), OF THE SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS, AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISC. BOOK 357, PAGE 20, AND IN RIGHT OF WAY PLAN BOOK 9, PAGE 24, AS AMENDED IN MISC. BOOK 362, PAGE 1111, AND PLAN BOOK 57, PAGE 132. TOGETHER WITH AN UNDIVIDED 1.71979 INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS, AS AMENDED AFORESAID. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO TIM UNIT BEING CONVEYED HEREIN, PURSUANT TO THE FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM AND FIRST AMENDMENT TO DECLARATION PLATS AND PUNS. BEING KNOWN AS 593-4 GENEVA DRIVE PROPERTY TAX PARCEL NO. 42-24-0791-163 TITLE TO SAID PREMISES IS VESTED IN ERNEST P. -iA.RTSOCK, SINGLE MAN BY DEED FROM SHARON F. SMYERS, SINGLE WOMAN, DATED 7/24/1997 AND RECORDED 7/28/1997 IN DEED BOOK 161 PAGE 857 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-7214 CIVIL 19c Term COUNTY OF CUMBERLAND) CIVIL ACTION . LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Nonvest Mortgage, Inc. 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Plaintiff 856-482-6900 Supreme Court ID No. 04302 from Ernest P. Hartsock 2475 Walker-town Avenue Deltona Fl 32725 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See legal description (2) You are also directed to attach the properly 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 properly of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment isfound inthe possession of anyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $61,337.50 L.L. Interest from 6/21/00 to date of salel2/6/00 Per them @ $10.98 - $1,859-62 Due Frothy $4: go Atty's Comm % Other Costs Ally Paid $220.79 Plaintiff Paid Date: June 28. 2000 REQUESTING PARTY: Name Mark J. Udren, Address: Attorney for Telephone: Curtis R. Long Prothonotary, Civil Division Deputy F 11---l __ __ , _ a9Irv the sheriff levied upon thedefendantZ g'"'?-- Jil Interest in the real property situated in Fcnow and numbered as Cumberland County, Pa., dQ6tL and more `u : ed in Exhibit "A" filed with 00 this writ and by this reference incorporated herein. 2 By; date. i7rg ?J 1T 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 swom, according to law, deposes and says that the Cumberland Law Joumal, 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 Joumal on the following dates, viz: OCTOBER 27, NOVEMBER 3,10, 2000 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. REAL ESTATE BALE NO. 1 Writ No. 1990.7214 Civil Norwest Mortgage, Inc. VS. Ernest P. Harlsock Atty.: Mark J. Udren ALL THAT CERTAIN unit, being Unit No. 593-4 (the 'Unit'(, of the Sungulld 114 a condominium, located In Upper Allen Township, Cumber- land County, Pennsylvania. which Unit is designated in the declara. non of Sungulld 111, a condominium (the -Declantlon or Condominium'( and declaration plats and plans, as recorded in the. Recorder's Office of Cumberland County In Misc. Book 357. Page 20. and In right of way Plan Book 9, Page 24, as amended In Misc. Book 362, Page 1111, and Plan Book 57, Page 132. TOGETHER with an undivided 1.7197% Interest in comment cle- Roger M, Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 HOTAIaAL SEAL V L045 E. SNYOER, M tary Public Ccriidn :43ro, Cvmbadand Covnr/, PA /1.Y C:!n,nirint [apir..t Moak S. M01 iS. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 597, Approved May 10, 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 rbg 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 Slate 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 31st day of October and the 71h and 14th day(s) of November 2000. 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 ' Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ........ ....... ....................r ......................................................... COPY Swor t crib d before me this 1st day of Dece er 2000 A.D. SALE #1 Soal /1 Tony L. RUUW. Notoxy Puj Hrmss .DxpNnt:oun MycommisstonExpres,lane6,zooz N ARY PUBLIC Member, Pennsylvania Assodetanof Nagr)+mommission expires June 6, 2002 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 $ 215.10 Probating same Notary Fee(s) $ 1.50 Total $ 216.60 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 ....................................................................