HomeMy WebLinkAbout03-3941
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL. NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
.
: Cumberland County
v.
Diane Defrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
: NO. 03 -.JCfi{ /
C. ;u; L <-y- ffZfl1
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
AVISO
Le han demandado a usted en la corte. Si usted qui ere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita 0 en
persona 0 con un abogado y entregar a la corte en forma escrita sus
defensas 0 sus objeciones alas demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero 0 sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
Isl Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: N/A
Assignments of Record to: N/A
Recording Date: N/A
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant (s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness.
Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 1420 Wellgate Lane
MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township
COUNTY: Cumberland
DATE EXECUTED: 02/08/02
DATE RECORDED: 02/22/02 BOOK: 1749 PAGE: 4565
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant (s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
07/25/03:
Principal of debt due
Unpaid Interest at 9.2% *
from 11/01/02
to 07/25/03
(the per diem interest accruing on
this debt is $77.86 and that sum
should be added each day after
07/25/03)
$308,914.28
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
Escrow Overdraft/(Balance)
Late Charges
(monthly late charge of $152.47
should be added in accordance
with the terms of the note
each month after 07/25/03)
Attorneys Fees (anticipated and actual
to 5% of principal)
TOTAL
20,788.62
250.00
280.00
3,080.00
1,219.76
15,445.71
$349,978.37
* This interest rate is subject to adjustment as more fully set
forth in the Note and Mortgage.
7. The attorney's fee set forth above are in conformity with
the mortgage documents and pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $349,978.37 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
l'lij1
f;/L.
Mark ~~Jren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for plaintiff
Attorney I.D. No. 04302
,;
,
ALL..THAT CERTAIN TRACT 01' LAND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, AND DESCRIBED ACCORDING TO A FINAL SUBDIVISION PLAN PREPARED
BY HARTMAN AND ASSOCIATES, REGISTERED pROFESSIONAL ENGINEERS, CAMP HILL,
PENNSYLVANIA, DATED NOVEMBER 1, 1995, AND LAST REVISED FEBRUARY 6, 1996, AND
RECORDED IN PLAN BOOK 72, PAGE 125, AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHEAST SIDE 01' WELLGATE LANE AND A CORNER 01'
LOT NO. 5 ON SAID PLAN; THENCE EXTENDING ALONG SAID LOT SOUTH 16 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE 01' 60.66 FEET TO A POINT AT A CORNER 01' LANDS NOW OR
LATE 01' JOHN H. RUPPERT, SR.; THENCE EXTENDING ALONG SAID LAND SOUTH 15 DEGREES 15
MINUTES 00 SECONDS WEST, A DISTANCE 01' 183.72 FEET TO A POINT AT A CORNER 01' LANDS
NOW OR LATE 01' ELMER J. KLINE; THENCE EXTENDING ALONG SAID LANDS AND CONTINUING
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A DISTANCE 01' 62.11 FEET TO A POINT;
THENCE CONTINUING NORTH 67 DEGREES 45 MINUTES 00 SECONDS WEST, A DISTANCE OF 175.00
FEET TO A POINT AT A CORNER OF LOT NO. 30N SAID PLAN; THENCE EXTENDING ALONG SAID
LOT NO. 14 DEGREES 45 MINUTES 19 SECONDS EAST, A DISTANCE 01' 143.63 FEET TO A POINT
ON THE SOUTHWEST SIDE 01' WELLGATE LANE; THENCE EXTENDING ALONG SAID LANE ALONG A
CURVE TO THE LEFT HAVING A RADIUS 01' 330.00 FEET, THE ARC DISTANCE 01' 177.14 FEET
TO THE POINT AND PLACE 01' BEGINNING.
.
BEING LOT NO.4.
CONTAINING 43,389.77 SQUARE FEET.
SUBJECT TO EASEMENTS. CONDITIONS AND RESTRICTIONS 01' RECORD.
LOAN NO
0005756952
DATE LETTER VER REO DESCRIPTION DATE 08/04/03
05/09/03 OP138 006 ER1 PA Act 6/91-Multi Borrower
p(J~ IJdrUl
May 09, 2003
( er1--_
7007... 0 B ~ COOt) \ Il 0'1. 3'5 '"2 "I
Jeffrey Defranks
1420 Wellgate Ln
Mechanicsburg
PA 17055
Homeowners Name: Diane Defrank
Property Address: 1420 Wellgate Ln, Mechanicsburg PA 17055
Loan Account No.: 0005756952
PF: 1 SC F
EXH\BlT A
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 08/04/03
05/09/03 OP138 006 ER1 PA Act 6/91-Multi Borrower
Original Lender: OPTION ONE MORTGAGE
Current Lender/Servicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 08/04/03
05/09/03 OP138 006 ER1 PA Act 6/91-Multi Borrower
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 08/04/03
05/09/03 OP138 006 ER1 PA Act 6/91-Multi Borrower
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
OP138
PF: 1 SC F 2 SC B
LoAN NO
0005756952
DATE LETTER VER
05/09/03 OP138 006
REQ OESCRIPTION DATE 08/04/03
ER1 PA Act 6/91-Multi Borrower
Re: Loan No. 0005756952
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this Notice,
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in
which the property is located are set forth at the end of this Notice.
It is only necessary to schedule one face-to-face meeting. Advise
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER
05/09/03 OP138
VER REQ DESCRIPTION DATE 08/04/03
006 ER1 PA Act 6/91-Multi Borrower
your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default.) If you have
tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program ana they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
PF: 1 SC F 2 SC B
>
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP138 006
REQ DESCRIPTION DATE 08/04/03
ER1 PA Act 6/91-Multi Borrower
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND
YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance
are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your
application.
OP138
PF:
2 SC B
'.
"
LOAN NO
DATE LETTER VER REO DESCRIPTION DATE 07/28/03
05/09/03 OP171 016 ER1 Part 1 Pennsylvania NOI
May 09, 2003
'fA' 0~N
C~*
,,,o?-. 0"61.0' 000'.
. 0001
7-o:r' (;> 1j'bo
trOd-. sO;-;2-'i
110:;).. '!.'S'3t
lM~.)
(jV\tS.)
Diane Defrank
1420 Wellgate Ln
Mechanicsburg, PA 17055-6758
Homeowners Name: Diane Defrank
Property Address: 1420 Wellgate Ln, Mechanicsburg PA 17055
Loan Account No.: 0005756952
;
PF: 1 SC F
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 07/28/03
05/09/03 OP171 016 ER1 Part 1 Pennsylvania NOI
Original Lender: OPTION ONE MORTGAGE
Current Lender/Servicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
PF: 1 SC F 2 SC B
,
LOAN NO
0005756952
DATE LETTER
05/09/03 OP171
VER REQ DESCRIPTION DATE 07/28/03
016 ER1 Par~ 1 Pennsylvania NOI
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
PF: 1 SC F 2 SC B
,
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP171 016
REO DESCRIPTION DATE 07/28/03
ER1 Part 1 Pennsylvania NOI
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
OP171
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP171 016
REQ DESCRIPTION DATE 07/28/03
ER1 Part 1 Pennsylvania NOI
Re: Loan No. 0005756952
CONSUMER CREDIT COUNSELING AGENCIES - If you meet ~ith one of the
consumer credit counseling agencies listed at the end of this Notice,
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in
~hich the property is located are set forth at the end of this Notice,
or you may contact HUD directly at 800-569-4287 or visit the HUD
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP171 016
REO DESCRIPTION DATE 07/28/03
ER1 Part 1 Pennsylvania NOI
website at www.hud.gov/offices/hsg/sfh/hcc/hccprof14.cfm. It is only
necessary to schedule one face-to-face meeting. Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default.) If you have
tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP171 016
REQ DESCRIPTION DATE 07/28/03
ER1 Part 1 Pennsylvania NOI
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND
YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance
are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your
application.
OP171
PF:
2 SC B
LOAN NO
0005756952
DATE
05/09/03
LETTER
OP172
VER
026
REO
ER1
DESCRIPTION DATE 07/28/03
Part 2 Pennsylvania NOI
Re: Loan No. 0005756952
**********************************************************************
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for
Emergency Mortgage Assistance.)
**********************************************************************
HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
PF: 1 SC F
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP172 026
REQ DESCRIPTION DATE 07/28/03
ER1 Part 2 Pennsylvania NOI
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on
your property located at:
1420 Wellgate Ln, Mechanicsburg PA 17055
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the fOllowing
months and the following amounts are now past due:
(a) Monthly payments: 3 MONTHS @ $ 2,541.12
3 MONTHS @ $ 2,541.12
$ 15,246.72
(b) Previous late charges;
$ 1677.17
(c) Other charges; Escrow, Inspection,
NSF checks
$ 20.00
(d) Other provisions of the mortgage obligation,
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 07/28/03
05/09/03 OP172 026 ER1 Part 2 Pennsylvania NOI
if any
$ 15.00
(e) TOTAL AMOUNT OF (a) (b) and (e) REQUIRED
AS OF THIS DATE
$ 15,925.61
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable) :
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $15,925.61, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash, cashier's check, certified
check or money order made payable and send to:
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER
05/09/03 OP172
VER REQ DESCRIPTION DATE 07/28/03
026 ER1 Part 2 Pennsylvania NOI
Overnight Mail Address
Western Union Quick Collect
3 Ada
Irvine, Ca. 92618
Pay to: Option One Mortgage Corporation
Code City: Option, Ca
You can cure any other default by taking the following action within
thirty (30) days of the date of this letter. (Do not use if not
(applicable.)
OP172
PF:
2 SC B
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP173 012
REQ DESCRIPTION DATE 07/28/03
ER1 Part 3 Pennsylvania NOI
Re: Loan No. 0005756952
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to
exercise its rights to accelerate the mortgage debt.
This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount
past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your
PF: 1 SC F
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP173 012
REQ DESCRIPTION DATE 07/28/03
ER1 Part 3 Pennsylvania NOI
mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be
sold by the Sheriff to payoff the mortgage debt. If the lender refers
your case to its attorneys, but you cure the delinquency before the
lender brings legal proceedings against you, you will still be required
to pay the reasonable attorney's fees that were actually incurred, up
to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable attorney's fees actually incurred by the
lender even if they exceed $50.00. Any attorney's fees will be added to
the amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period, you
will not be required to pay attorney's fees.
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE
05/09/03
LETTER
OP173
VER
012
REQ DESCRIPTION DATE 07/28/03
ER1 Part 3 Pennsylvania NOI
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not
cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriff's
Sale. You may do so by paying the total amount then past due, plus
any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs
connected with the Sheriff's Sale as specified in writing by the
PF: 1 SC F 2 SC B
. .
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP173 012
REQ DESCRIPTION DATE 07/28/03
ER1 Part 3 Pennsylvania NOI
lender and by performing any other requirements under the mortgage.
Curing your default in the manner set forth in this notice will
restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriff's Sale of the mortgaged property
could be held would be approximately (7) SEVEN Months from the date
of this Notice. A notice of the actual date of the Sheriff's Sale
will be sent to you before the sale. Of course, the amount needed
to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment or action will be
by contacting the lender.
OP173
PF:
2 SC B
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP174 029
REQ DESCRIPTION DATE 07/28/03
ER1 Part 4 Pennsylvania NOI
Re: Loan No. 0005756952
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
Attn:
Address:
Phone Number:
Fax Number:
PF: 1 SC F
Option One Mortgage Corporation
7515 Irvine Center Drive
Ed Turner
Irvine, CA. 92618
800-326-1500, Ext. 48004
949-784-6033
LOAN NO
0005756952
DATE LETTER VER
05/09/03 OP174 029
REQ DESCRIPTION DATE 07/28/03
ER1 Part 4 Pennsylvania NOI
Contact Person:
Office hours:
Erica Reeder
Monday through Thursday 8:00 a.m. to 8:00 p.m.
Friday 8:00 a.m. to 5:00 p.m.
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will
end your ownership of the mortgaged property and your right to occupy it.
If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could
be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You
mayor
x
may not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the
other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT TO:
PF: 1 SC F 2 SC B
LOAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 07/28/03
05/09/03 OP174 029 ER1 Part 4 Pennsylvania NOI
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
PF: 1 SC F 2 SC B
. LQAN NO
0005756952
DATE LETTER VER REQ DESCRIPTION DATE 07/28/03
05/09/03 OP174 029 ER1 Part 4 Pennsylvania NOI
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
OP174
PF:
2 SC B
V E R I F I CAT ION
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.
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Ma~ J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
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PRAECIPE FOR ENTRY OF ApPEARANCE
OPTION ONE MORTGAGE
CORPORATION
In The Court of Common Pleas
Of Cumberland County, Pennsylvania
Civil Action Law
vs.
No. 03-3941
DIANE DEFRANK a/k/a
DIANE D. DEFRANK
JEFFREY DEFRANK, Mortgagor
To The Prothonotary of Said County:
Please enter the appearance of Robert D. Kodak, whose address is 407 North front
Street, Harrisburg, Dauphin County, Pennsylvania 17101, as Attorney for Diane DeFrank and
!offt" Dci'm,"" ili, D"'''''~' ;" "" ""'''~'Pri"~
Dated: September 15. 2003 /~
Robert D. Kodak, Esquire I.D. No. 18041
Attorney for Defendants
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SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03941 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
OPTION ONE MORTGAGE
VS
DEFRANK DIANE ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DEFRANK DIANE AKA DIANE D DEFRANK
the
DEFENDANT
, at 1849:00 HOURS, on the 8th day of September, 2003
at 1420 WELLGATE LANE
MECHANICSBURG, PA 17055
by handing to
JEFFREY DEFRANK, HUSBAND
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
8.97
.00
10.00
.00
36.97
.r~~~
R. Thomas Kline .
09/09/2003
MARK UDREN
Sworn and Subscribed to before By:
me this /7 ~ day of
.1r~~ .)(Xn A.D.
n".'-'----G~~
'" f't;rothonotary . -'" I
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03941 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
OPTION ONE MORTGAGE
VS
DEFRANK DIANE ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DEFRANK JEFFREY
the
DEFENDANT
, at 1849:00 HOURS, on the 8th day of September, 2003
at 1420 WELLGATE LANE
MECHANICSBURG, PA 17055
by handing to
JEFFREY DEFRANK
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
r~<",,,<..t"'<~'R
R. Thomas Kline
09/09/2003
MARK UDREN
Sworn and Subscribed to before By:
me this 17!::.
day of
;J..{}f;..3 A.D.
a~.~
Prothonotary
OPTION ONE MORTGAGE CORPORATION
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 03-3941 CIVIL
DIANE DeFRANK alkla DIANE D. DeFRANK
and JEFFREY DeFRANK, Mortgagors
Defendants
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
DEFENDANTS' ANSWER TO PLAINTIFF'S COMPLAINT
AND NOW, this
J'1:L. day of October, 2003, comes Defendants, Diane DeFrank ~d
Jeffrey DeFrank, by and through their attorney, ROBERT D. KODAK, ESQUIRE, KNUPP, KODAK &
IMBLUM, P.C., and files the following Answer to Plaintiffs Complaint, as follows:
I. Admitted.
2. Admitted.
3. Admitted.
4. Denied. After reasonable investigation, Defendants are without sufficient information,
knowledge or belief as to the truth of the allegation. Additionally, Defendants have offered, per Exhibit "A"
attached hereto and made a part hereof, to Deed the property in question over to the Plaintiff in lieu of
foreclosure, free and clear of all other liens and encumbrances.
5. Denied. It is denied that Defendants retused to pay the installments in question but, rather,
found it impossible to do so; hence, they have offered the property back to Plaintiff with a Deed in Lieu of
Foreclosure.
6. Denied. After reasonable investigation, Defendants are without sufficient informatioh,
knowledge or belief as to the truth of the allegation and proof thereof is demanded at trial.
7. Denied. The attorney's fees in question are not reasonable and should be limited to the actual
amount of attorney's fees incurred by Plaintiff in this case.
8. Admitted.
WHEREFORE, Defendants respectfully request that Plaintiffs Complaint be dismissed and
Judgment be entered in their favor.
Respectfully submitted,
KNUPP, KOD~ IMBLUM, P.c.
~
Robert D. Kodak
407 North Front Street
Post Office Box # 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney J.D. No. 18041
Attorney for Defendants
F: I USER IBONNlEJOIANSW\ WORK\defrank. wpd :070cI03
2
CERTIFICATE OF SERVICE
I, ROBERT D. KODAK, ESQUIRE, hereby certify that I have this date served a true and correct
copy of the Defendants' Answer to Plaintiffs Complaint in the above-captioned matter upon the below
listed individual(s) by causing same to be deposited in the United States mail, first class postage prepaid at
Harrisburg, Dauphin County, Pennsylvania, addressed as follows:
MARK J UDREN ESQUIRE
MARK J UDREN & ASSOCIATES
1040 N KINGS HIGHWAY STE 500
CHERRY HILL NJ 08034
KNUPP, KODAK & IMBLUM, P.c.
~
-----
~
Dated:
/~/f/?
I
Robert D. Kodak
407 North Front Street
Post Office Box 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney J.D. No. 18041
Attorney for Defendants
F: I USERIBONNIEJOIANSWI WORKldefrank. wpd :070cI03
VERIFICATION
I, DIANE DeFRANK and JEFFREY DeFRANK, verify that the statements made in the aforegoing
document :lre true and correct. I understund th:lt false stutements herein are made subject to the penaltip
of 18 Pa. C. S. 94904, relating to unsworn falsification to authorities.
~V/d~4d
.
Diane DeFrank
Dated:
/U;~
kfu~ ~
3930008
F: I USER IBONNIEJOIANSWI WORKldefrank. wpd :0700,03
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and subnitted :in dUpl ;,."'te)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
please list the within matter for the next ArguIeIlt Court.
---------------------------------------------------------------------------------------
CAPTION OF CASE
(enUre caption IlDJSt be stated in full)
Option One Mortgage Corporation
(Plaintiff)
vs.
Diane DeFrank a/k/a Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
(Defendant)
No. 03--3941
Civil
1. State matter to be argued (Le.. plaintiff's lTDtion for new trial. defendant's
denurrer to carplaint. etc.):
Plaintiff's Motion for Summary Judgment
2. Identify COlnlSel. who will argue case:
(a)
for plaintiff' Mark J. Udren, Esquire
Address: 1040 N. Kings Highway. Suite 500
Cherry Hill, NJ 08034
(b)
for defendant: Robert D. Kodak, Esquire
Address: 407 North Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
3. I will notify all parties in writing within two days that this case has
been listed for argunent.
4. ArguIeIlt Court Date: February 4, 2004
../
Dated: DeCEmber I b , 2003
Attm:ney for
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MARK J. UDREN & ASSOCIATES
BY: MARKJ. UDREN,ESQUlRE
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Option One Mortgage Corporation
Plaintiff
ATTORNEY FOR PLAINTIFF
.
: COURT OF COMMON PLEAS
: CIVIL DNISION
: Cumberland County
v.
Diane DeFrank aIkIa Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
.
: NO. 03-3941 Civil Term
Defendants
MOTION FOR SUMMARY JUDGMENT
Plaintiff, Option One Mortgage Corporation, by its Attomey, Mark J. Udren, Esquire,
respectfully requests your Honorable Court to enter an Order granting Summary Judgment in the
above-captioned matter for the following reasons:
I. There are no genuine issues as to any material fact, and therefore, Plaintiff
(moving party) is entitled to Judgment as a matter oflaw.
2. Defendants, Diane DeFrank aIkIa Diane D. DeFrank and Jeffrey DeFrank,
Mortgagor, filed an Answer to the Complaint in which Defendants effectively admitted all of the
allegations in the Complaint.
3. At the time of this pleading, Defendant, Diane DeFrank aIkIa Diane D. DeFrank,
owned the premises being foreclosed without a mortgage payment being made for an excessive
period of time.
4. Defendants admit paragraphs 1,2,3 and 8 of the Complaint outright, thereby
admitting, inter alia, that Defendants are the real owners and/or mortgagors ofthe within
mortgaged property; and, that Plaintiff complied with the statutory pre-foreclosure Notice
requirements.
5. Although Defendants purport to deny and/or fail to deny, in whole or in part,
specifically or by necessary implication the averments contained in paragraphs 4, 5, 6 and 7 of
the Complaint, in reality, said denials are improper and should be deemed as admissions for the
reasons set forth in the attached Memorandum of Law.
6. The Pennsylvania pre-foreclosure Act 6 Notice is not required as the Defendants'
original principal balance on the Mortgage is greater than $50,000.00. 41 P.S. Section 101,
et sea. See Exhibit "A" attached hereto (Mortgage).
7. Plaintiff complied with the Pennsylvania pre-foreclosure Notice requirements of
Act 91 (35 P.S. Section 1680.40Ic, et sea.).
8. Plaintiff has an express contractual right pursuant to the terms ofthe Mortgage to
charge the Defendants attorney's fees as a consequence of the initiation ofthe within action in
Mortgage Foreclosure.
9. In addition to the amounts due and owing as set forth in the Complaint, additional
sums have accumulated since the filing of the Complaint, pursuant to the terms of the Mortgage.
The total amounts due and owing, which sums can be calculated from the face ofthe Complaint,
are as follows:
Principal of debt due and unpaid
$308,914.28
Interest at 9.2%* from 1111/02 to 12115/03 (the per diem interest accruing on
this debt is $77.86 and that sum should be added each day after 12/15/03)
31,923.98
Title Report
250.00
Court Costs (anticipated, excluding Sheriff's Sale costs)
280.00
Escrow OverdraftlBalance
Hazard Insurance
Taxes
$3,080.00
$5,286.84
8,366.84
Late Charges
1,219.76
Suspense Balance
(1,033.28)
NSF Fee
20.00
Other Fees
219.32
Attorney's Fees (anticipated and actual to 5% of principal)
15.445.71
TOTAL
$365,606.61
*This interest rate us subject to adjustment as more fulIy set forth in the Note and
Mortgage.
WHEREFORE, Plaintiff respectfully requests that the Honorable Court grant its Motion
for Summary Judgment, and that Judgment be entered, in rem, as prayed for in the Complaint in
favor of the Plaintiff and against the Defendants, Diane DeFrank aIkIa Diane D. DeFrank and
Jeffrey DeFrank, Mortgagor, in the amount of$365,606.6l, together with ongoing per diem
interest, escrow advances, and any additional recoverable costs to date of Sheriff's Sale; and for
foreclosure and sale of the mortgaged property.
Respectfully submitted,
MARKJ. U REN & ASSOCIATES
By:
Mark J. Udren, Esquire
Attomey for Plaintiff/Movant
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MARKJ. UDREN & ASSOCIATES
BY: MARK J. UDREN, ESQUIRE
A TTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Option One Mortgage Corporation
v.
Diane DeFrank a/k/a Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
.
: NO. 03-3941 Civil Term
Defendants
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire, hereby certify that I served true and correct copies ofPlaintitrs
Motion for Summary Judgment, Brief in Support and Argument Praecipe upon the following
persons named herein at their last known address or their attorney of record.
xxxxxx Regular First Class Mail
Certified Mail
Other (certificate of mailing)
Date Served: December 16,2003
TO: Robert D. Kodak, Esquire
407 North Front Street, P.O. Box 11848
Harrisburg, P A 17108-1848
Attomey for Defendants
MARKJ. U REN & ASSOCIATES
By:
Mark J. Udren, Esqu' e
Attorney for Plaintiff/Movant
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UDREN LAW OFFICES, P.C.
WOODCRESTCORPORATECENTER
111 WOODCREST ROAD
CHERRY HILL, NJ 08003
856-482-6900
Plaintiff
.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Option One Mortgage Corporation
v.
Diane DeFrank aIkIa
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
.
: NO. 03-3941 Civil Term
Defendant( s)
PRAECIPE TO A TT ACH AFFIDAVIT AND VERIFICATION AS TO PLAINTIFF'S
MOTION FOR SUMMARY JUDGMENT
TO THE PROTHONOTARY:
Kindly attach the enclosed Affidavit and Verification to Plaintiff's Motion for Summary
Judgment which was filed on December 17, 2004.
MARK J. UDREN & ASSOCIATES
/YYY/
BY:
Mark J. Udren, Esquire
ATTORNEY FOR PLAINTIFF/MOV ANT
MARKJ. UDREN & ASSOCIATES
BY: MARKJ. UDREN, ESQUIRE
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Option One Mortgage Corporation
ATTORNEY FOR PLAINTIFF
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank aIkIa Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
NO. 03-3941 Civil Term
Defendants
AFFIDAVIT
STATE OF FLORIDA
COUNTY OF DUVAL
SS
I, William Newland, being duly sworn according to law, depose and say:
1. That I am the Asst. Secretary for Option One Mortgage Corporation, the Plaintiff in
the within matter.
2. That in said capacity I am familiar with the account that forms the basis of the instant
foreclosure action and that I am authorized to take this Affidavit.
3. That all notices, if required to be sent to Defendants pursuant to Act 6 of 1974 and Act
91 of 1983, have been sent pursuant to the requirements ofthose Acts on the dates appearing
thereon, copies of said notices being attached to the Complaint as Exhibits, if applicable.
4. The amounts due on the Mortgage were correctly stated as of the date appearing in the
Complaint, in paragraph 6 thereof, and have accumulated since the filing ofthe Complaint, as
follows:
Principal of debt due and unpaid
Interest at 9.2%* from 11/1/02 to 12115/03 (the per diem interest accruing on
this debt is $77.86 and that sum should be added each day after 12/15/03)
Title Report
Court Costs (anticipated, excluding Sheriff's Sale costs)
Escrow OverdraftlBalance
Hazard Insurance
Taxes
$3,080.00
$5,286.84
Late Charges
Suspense Balance
NSF Fee
Other Fees
Attorney's Fees (anticipated and actual to 5% of principal)
TOTAL
*This interest rate us subject to adjustment as more fully set forth in the Note and
Mortgage.
A true and correct copy of the payment history, attested to herein, is attached hereto as
Exhibit "A".
Option One Mortgage Corporation
B~/
Name: illiam Newland
Title: Asst. Secretary
$308,914.28
31,923.98
250.00
280.00
8,366.84
1,219.76
(1,033.28)
20.00
219.32
15.445.71
$365,606.61
,JHI'I-Cc-~1a1a4 11: 55
www,optiononemorlgage,c;om
REQ BY MLS
DIANE DEFRANK
1420 WELL GATE LN
MECHANICSBURG
P.01
OPTION ONE MORTGAGE CORPORATION,.
3 ADA ,:.
IRVINE, CA 92618
TELEPHONE ~O.; 1-S00-648-9605
.
OPTION ONE
MOItTCAGE
Sian Here. Finish Here.
CUSTOMER ACCOUNT ACTIVITY STATEMENT
DATE 01/22/04
PAGE 1
PA 17055
A-rrN: iii $ H OtvHJ f)
-
('6"S~ - J./ %;)-/1 <1 q)
LOAN NUMBER: 0005756952
*~****************.*****.*********.*****************************~**************
-------------------------- CURRENT ACCOUNT INFORMATION ________________________
DATE TOTAL PRINCIPAL LOAN CURRENT
PAYMENT PAYMENT & INTEREST INTEREST PRINCIPAL ESCROW
DUE AMOUNT PAYMENT RATE BALANCE BALANCE
12-01-02 2,541.13 2,541.12 9,20000 308,914.28 7,541.S4-
*******************************************************************************
PROCESS
DATE
DUE
DATE
ACTIVITY FOR PERIOD
TRANSACTION
CODE
01/01/01 - 01/15/04
TRANSACTION
DESCRIPTION
EFFECTIVE DATE
OF TRANSACTION
TRANSACTION
AMOUNT
-------------------------------~-----------------------------------------------
PRIN. PAID/
BALANCE
ESCROW PAID/ ------------OTHER--------_____
INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
12-30-03 12-02
0.00
12-30-03 12-02
825.00
12-30-03 00-00
9.60
12-16-03 12-02
0.00
12-02-03 00-00
9.60
11-17-03 12-02
0.00
10-29-03 00-00
9.60
10-16-03 12-02
0.00
10-16-03 00-00
115.00
10-03-03 00-00
9.15
09-16-03 12-02
0.00
08-25-03 00-00
9.60
168 REPAY OF ESCROW ADVANCE
0.00 0.00 825.00- 825.00
163 HAZARD INSURANCE DEPOSIT
0.00 0.00 825.00
7541.84- NEW PRINCIPAL/ESCROW BALANCES
633 MISC. F/C AND B/R EXPENSES
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 152,47-1 LATE CHARGES FEE 1
633 MISC. F/C AND B/R EXPENSES
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 152.47-1 LATE CHARGES FEE 1
633 MISC. F/C AND B/R EXPENSES
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 152.47-1 LATE CHARGES FEE 1
633 MISC. F/C AND B/R EXPENSES
0.00 0.00 0.00
633 MISC. F/C AND B/R EXPENSES
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 152.47-1 LATE CHARGES FEE 1
633 MISC, F/e AND B/R EXPENSES
0.00 0.00 0.00
EXHIBIT A
CorpOrate Offices '3 Ada "Irvine. Calilomia . 92618-2304
P.O. Bo, 57041'lrvine' Call1ornla' 92519-7041 '900.3l6.1500' Fax 949.754.6100 @
JAN-22-2004 11:55
wWw.optlonontmortgagt.eom
REQ BY ML8
P.02
OPTION ONE MORTGAGE CORPORATION
3 ADA
IRVINE, CA 92618
.
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OPTION ONE
MORTGAGE
TELEPHONE NO.: 1-800-648-9605
CUSTOMER ACCOUNT ACTIVITY STATEMENT
Start Hert. FiniSh Here.
DATE 01/22/04
PAGE 2
DIANE DEFRANK
LOAN NUMBER: 0005756952
ACTIVITY FOR PERIOD 01/01/01 - 01/15/04
PROCESS DUE TRANSACTION TRANSACTION
DATE DATE CODE DESCRIPTION
EFFECTIVE DATE
OF TRANSACTION
------------------_____M_______________________________________________________
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER------_______
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
5286.84
TAX SEARCH FEE
15.00-
8366.84- NEW PRINCIPAL/ESCROW BALANCES
08-20-03 04-02 314 NON ESC DELINQUENT P~OP TAXES
5,271.84- 0.00 0.00 5271.84-
8351.84- NEW PRINCIPAL/ESCROW BALANCES
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
161 ESCROW ADVANCE
0.00 0,00 3080.00
351 HAZARD INSURANCE DISBURSEMENT (PRIMARY POLICY)
0.00 0.00 3080.00-
3080.00-
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0,00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
173 PAYMENT
0.00 0.00 0.00
152 LATE CHARGE ASSESSMENT
0,00 0.00 0.00
173 PAYMENT
171.46 2,369.66
308,914.28
08-25-03 00-00
2,550.00
08-21-03 12-02
5,286.84
08-20-03 08-03
15.00-
08-18-03 12-02
0,00
07-16-03 12-02
0.00
06-18-03 12-02
3,080.00
06-17-03 03-03
3,080.00-
06-16-03 12-02
0.00
05-16-03 12-02
0.00
04-16-03 12-02
0.00
03-17-03 12-02
0,00
02-18-03 12-02
0,00
02-18-03 12-02
850.00
01-16-03 12-02
0.00
12-31-02 11-02
2,700,00
632 STATUTORY EXPENSES
0.00 0.00
161 ESCROW ADVANCE
0.00 0.00
318 DELINQUENT PROP
0.00 0.00
0.00
152.47-1 LATE CHARGES
FEE 1
152.47-1 LATE CHARGES
FEE 1
NEW PRINCIPAL/ESCROW BALANCES
152,47-1 LATE CHARGES
FEE 1
152.47-1 LATE CHARGES
FEE 1
152.47-1 LATE CHARGES
FEE 1
152.47-1 LATE CHARGES
FEE 1
152.47-1 LATE CHARGES
FEE 1
850.00
152.47-1 LATE CHARGES
FEE 1
0.00
158.88
NEW PRINCIPAL/ESCROW BALANCES
Corporale Offices. 3 Ada ./rvir'lG . California. 92618-2304
P.O. Box 57041 . Irvine . CaliloInia' 92619-7041 . 600.326.1500' Fax 949.764.6100 @
JRN-22-2004 11:55
www.optiononemortglge.com
P.03
-.-.
OPTION ONE MORTGAGE CORPORATION "
3 ADA ..
IRVINE, CA 92618
TELEPHONE NO.: 1-800-648-9605
OPTION ONE
MORTGAGE
Stan fie... Flnl.., fie...
REQ BY ML8
CUSTOMER ACCOUNT ACTIVITY STATEMENT
DATE 01/22/04
PAGE 3
DIANE DEFRANK
LOAN NUMBER: 0005756952
ACTIVITY FOR PERIOD 01/01/01 - 01/15/04
PROCESS DUE TRANSACTION TRANSACTION
DATE DATE CODE DESCRIPTION
----------~-~----~-------------------------------~-----------------------------
EFFECTIVE DATE
OF TRANSACTION
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-----------__
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
--~------~---------------------------------------------------------------------
12-16-02 11-02
0.00
11-30-02 10-02
2,550.00
152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00
173 PAYMENT
170.16 2,370.96
309,085,74
11-18-02 10-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
10-31-02 09-02 173 PAYMENT
2,550.00 168.86 2.372.26
309,255.90
10-16-02 09-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
09-30-02 08-02 173 PAYMENT
1,325.00 167.58 2,373,54
309,424.76
09-23-02 08-02 173 PAYMENT
350,00 0.00 0.00 0.00
09-16-02 08-02 152 LATE CHARGE ASSESSMENT
0,00 0.00 0.00 0.00
08-31-02 07-02 173 PAYMENT
300.00 166.30 2,374.82
309,592.34
08-29-02 07-02 173 PAYMENT
300.00 0.00
08-28-02 07-02 173 PAYMENT
300.00 0.00
08-27-02 07-02 173 PAYMENT
350.00 0.00
08-26-02 07-02 173 PAYMENT
400.00 0.00
08-23-02 07-02 173 PAYMENT
300.00 0.00 0.00 0.00
08-16-02 07-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
08-12-02 07-02 173 PAYMENT
1,300.00 0.00
0_00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0,00
0.00
0.00
152.47-1 LATE CHARGES
FEE 1
8.88
NEW PRINCIPAL/ESCROW BALANCES
152,47-1 LATE CHARGES
FEE 1
8.88
NEW PRINCIPAL/ESCROW BALANCES
152.47-1 LATE CHARGES
FEE 1
1,216.12-
NEW PRINCIPAL/ESCROW BALANCES
350,00
152.47-1 LATE CHARGES
FEE 1
2 , 241. 12 -
NEW PRINCIPAL/ESCROW BALANCES
300.00
300.00
350.00
400.00
300.00
152.47-1 LATE CHARGES
FEE 1
1,300.00
Corporale Offices. J Ada .Irvin~ . CalUornia. 92618.2304
P.O. Box 57041 . '"ine . Celi'oml. . 92619.7041 . 600.326.1500' Fa, 949.784.6100 @
JAN-22-2004 11:56
www.optlononomorlgago.com
P.04
OPTION ONE MORTGAGE CORPORATION
3 ADA
IRVINE, CA 92618
.
/ ./
TELEPHONE NO.: 1-800-646-9605
OPTION ONE
MO~TGAGE
REQ BY ML8
CUSTOMER ACCOUNT ACTIVITY STATEMENT
St:BNDEl'ln~ri 2 / 0 4
PAGE 4
DIANE DEFRANK
LOAN NUMBER: 0005756952
ACTIVITY FOR PERIOD 01/01/01 - 01/15/04
PROCESS DUE TRANSACTION TRANSACTION
DATE DATE CODE DESCRIPTION
EFFECTIVE DATE
OF TRANSACTION
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER--------_____
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
07-31-02 06-02 173 PAYMENT
2,705.00 165.04 2,376.08 0.00
309,758.64
07-17-02 06-02 148 RETURN CHECK
0.00 165,04- 2,376.08- 0,00
309,923.68
07-16-02 07-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
06-27-02 06-02 172 PAYMENT
2,693.59 165.04 2,376.08 0.00
309,758.64
06-17-02 06-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
05-30-02 05-02 172 PAYMENT
2,693.59 163.78 2,377.34 0.00
309,923.68
05-16-02 05-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0,00
04-30-02 04-02 173 PAYMENT
0.00 162.54 2,378.58 0.00
310,087.46
04-29-02 04-02 172 PAYMENT
1,633.59 0.00 0.00 0.00
04-24-02 04-02 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00
04-24-02 04-02 148 RETURN CHECK
0.00 162.54- 2,378.58- 0.00
310,250.00
04-17-02 04-02 173 PAYMENT
0.00 162.54 2,378.58 0.00
310,087.46
04-16-02 04-02 172 PAYMENT
1,481.12 0.00 0.00 0.00
04-16-02 04-02 147 MISAPPLICATION REVERSAL
0.00 0.00 0.00 0.00
163.88
NEW PRINCIPAL/ESCROW BALANCES
152.47-1 LATE CHARGES FEE 1
NEW PRINCIPAL/ESCROW BALANCES
152.47-1 LATE CHARGES
FEE 1
152.47 1 LATE CHARGES FEE 1
NEW PRINCIPAL/ESCROW BALANCES
152.47-1 LATE CHARGES
FEE 1
152.47 1 LATE CHARGES FEE 1
NEW PRINCIPAL/ESCROW BALANCES
152.47-1 LATE CHARGES
FEE 1
152.47 1 LATE CHARGES FEE 1
2,693.59-
NEW PRINCIPAL/ESCROW BALANCES
1,633.59
152.47-1 LATE CHARGES
FEE 1
1,060.00
NEW PRINCIPAL/ESCROW BALANCES
04-16-02
2, 541. 12-
NEW PRINCIPAL/ESCROW BALANCES
1,481.12
210.00
Corp"al. om... . 3 Ada' Irvin. . Cali/o,ni. . 92616.2304
P.O. Bo, 57041 'I',ine' C.ii'ornia' 92619.7041 . 600.326.1500' Fax 949.784.6100 ~
JAN-22-2004 11:56
Www.optlononlmortgaue.eom
P.05
OPTION ONE MORTGAGE CORPORATION
3 ADA '.
IRVINE, CA 92618
.
TELEPHONE NO,: 1-800-648-9605
OPTION ONE
MORTGAGE
Start He.... Finish Here.
REQ BY ML8
CUSTOMER ACCOUNT ACTIVITY STATEMENT
DATE 01/22/04
PAGE 5
DIANE DEFRANK
LOAN NUMBER: 0005756952
PROCESS
DATE
DUE
DATE
ACTIVITY FOR PERIOD
TRANSACTION
CODE
01/01/01 - 01/15/04
TRANSACTION
DESCRIPTION
EFFECTIVE DATE
OF TRANSACTION
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-----________
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
04-16-02 04-02 147 MISAPPLICATION REVERSAL
0.00 210.00- 0.00 0.00
310,250.00
04-09-02 04-02 172 PAYMENT
475.00 0.00
04-01-02 04-02 172 PAYMENT
375.00 0.00 0.00
03-25-02 04-02 175 PRINCIPAL PAYMENT
0,00 210.00 0.00
310,040.00
03-22-02 04-02 172 PAYMENT
210.00 0.00 0.00
02-13-02 03-02 170 LOAN CLOSING OR
1,268.64 0.00 1,268.64
02-13-02 04-02 142 LOAN SETUP
0.00 310,250,00- 0.00
310,250.00
0.00
0,00
NEW PRINCIPAL/ESCROW BALANCES
475.00
0.00
375.00
0.00
210.00-
NEW PRINCIPAL/ESCROW BALANCES
0.00 210.00
PREDISTRIBUTED PAYMENT
0.00
0.00
NEW PRINCIPAL/ESCROW BALANCES
Corporale om.e, . 3 Ada . Irvine . Calilornie '92618-2304
P.O. Box 57041 . Irvin. . CoUlornia' 92619-7041 . 600.326.1500' Fex 949.784.6100 @
TOTAL P.05
VERIFICATION
The undersigned, the Plaintiff in the Motion for Summary Judgment, being authorized to
make this Verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the
Motion for Summary Judgment are taken from the business records of the Mortgage held by the
Plaintiff in the ordinary course of business and that those facts are true and correct to the best of
the knowledge, information and belief of the undersigned.
The undersigned understands that this statement is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Dated:
\~\%"~
0,1;00 0,,, Mort"", CW
~~~~
Title: Asst. Secretary
UDREN LAW OFFICES, P.C.
WOODCRESTCORPORATECENTER
111 WOODCREST ROAD
CHERRY HILL, NJ 08003
856-482-6900
Plaintiff
.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
Option One Mortgage Corporation
v.
Diane Defrank aIkIa
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
.
: NO. 03-3941 Civil Term
Defendant( s)
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire hereby certify that I have served a true and correct copy of the
Praecipe to Attach Affidavit and Verification to Plaintiffs Motion for Summary Judgment upon the
following person(s) named herein at their last known address or their attomey of record:
Regular First Class Mail
Certified Mail
Other
Date Served: January~12004
xxxxx
TO: Robert D. Kodak, Esquire
407 North Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
Attorney for Defendants
MARK J. UDREN & ASSOCIATES
/}Yj/
BY:
Mark J. Udren, Esquire
Attorney for Plaintiff/Movant
o
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SAlOIS
SHUFF, FLOWER
& LINDSAY
A1TORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
Faye A. Sheaffer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2003-4035
Jeffrey L. Sheaffer,
Defendant
IN DIVORCE
AND NOW, this
ORDER OF COURT
2'Rtl, day of January 2004, upon agreement of
I
II
I Counsel, this Court's Order of January 21, 2004, is amended to
Svb-,',t
permit Plaintiff Faye A. Sheaffer to ~ her brief in response
d s..>6.....,~~Ier)
"
to Defendant's exceptions, 15 days after the date of fili~ of
Defendant's brief. ~e<:::: d1t?C..1ACd lc.ttc.T
By the Court,
~
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'v1NV^~
AlNOOO a~
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AlNl~~ :to
LAW OFFICES
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
MATTHEW J. ESHELMAN t
KIRK S. SOHONAGE
THOMAS E. FLOWER
LINDSAY GINGRICH MACLAY
JACL YN SMITH
SAID IS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYL VANIA 17013
TELEPHONE: (71 7) 243-6222 - FACSIMILE: (71 7) 243-6486
EMAIL: attorney@ssfl-Iaw.com
www.ssfl-law.com
CAMP HILL OFFICE
2109 MARKET STREET
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
t Board Certified Creditors'
Rights Representation
January 28, 2004
The Honorable Judge J. Wesley Oler, Jr.
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Sheaffer v Sheaffer
Docket 664
Support 2003
Dear Judge Oler:
On December 15, 2003, the Court issued an Order setting a briefing
schedule on exceptions filed to a Support Master's report and
recommendation on the caption case.
Apparently counsel did not receive the Court's Order. On January 21,
2004, the Court issued a second Order.
I represent the Plaintiff and the Defendant is represented by Orris
C. Knepp, III, Esq. Mr. Knepp and I have spoken by telephone and we
are in agreement that the Order enclosed with this letter may be
entered by the Court. The purpose of the Order is to provide me 15
days to review Mr. Knepp's brief before I must file my own. That was
the procedure set out in the December 15, 2003 Order.
I hope the Court can exceed to this request. Thank you for your
help.
Very truly yours,
CJL/pm
Enclosure
SAlOIS, SHUFF,~~WER & LINDSAY
~htJi~
Carol J. LinC)ay
cc: Orris C. Knepp, III, Esq.
'UDREN LAW OFFICES, PoCo
BY: Mark Jo Udren, Esquire
ATTY IoDo NO, 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
ATTORNEY FOR PLAINTIFF
plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Defendant(s)
NO. 03-3941 Civil Term
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the Verification
attached to the Complaint in Mortgage Foreclosure with regard to the
captioned matter.
UDREN LAW OFFICES, P.C.
DATED: March 1, 2004
BY:
V E R I FIe A T ION
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer
of the
Corporation which is the servicing agent of plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing complaint
are taken from records maintained by persons supervised by the
undersigned who maintain the business records of the mortgage held
by plaintiff in the ordinary course of business and thflt those
facts are true and correct to the best of
the
knowledge,
!
,
!
I
information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswo~n falsification to authorities.
Date:
QI~/O"3
I I
~Q Q~~
Name: LorQ ^ 'Scd\-\e{
'1'i tIe: Sv-. ~IMI"" Sr.cx,'oJ,'~
Company: Op'4-f....O"'- ~J5e.Gtp.
Diane Defrank a/k/a Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Loan #0005756952
MJU #03070530
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Defendant(s)
NO. 03-3941 Civil Term
PRAECIPE FOR JUDGMENT BASED ON COURT ORDER
AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant(s), Diane DeFrank a/k/a Diane D. DeFrank and Jeffrey DeFrank,
Mortgagor pursuant to the Court's Order dated February 4,2004 (in
accordance with the Complaint) and for foreclosure and sale of the
mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Court Order
Interest per Court Order
From 12/16/03 to 2/4/04
$365,606.61 ,/
3.970.86
TOTAL
$369,577.47
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that no further notice is required
pursuant to Rule PA.R.C.P. 237 & 237.1.
UDREN LAW OFFICES, P.C.
DAMAGES ARE HEREBY ASSESSED AS
DATE: (fl':J/)rL-- 4, Jr.6'1
INDICATED ~
(J~ "''' f;2 ,
PRO~ ~
__.:-M~R-0?-2004 WED 03:50 PM Udren Law Offices, p, C,
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
85Ei~482-6900
Option One Mortgage Corporation
Plaintiff
FAX NO, 8564288007
ATTORNEY FOR PLAINTIFF
p, 04
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane Defrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Defendant(s)
NO. 03-3941 Civil Term
TO: Diane Defrank a/k/a Diane D. DeFrank
Jeffrey Defrank, Mortgagor
C/o Robert D. Kodak, Esq.
407 North Front Street
P.O.' Box' 11B48
Harrisburg, PA 1710B
DATE of Notice: October 1, 2003
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU I-lAVE 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 YOtJRPROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT r~VE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT
A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland county.Ear Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA ElN l':S'!'ADO LlE REBJ:!:J..DIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DERIDA DENTRO DE UN TERMINO DE OIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE 5I USTED NO TIENE ABOGADO,
o SI NO TIENE PINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA. 0
LLAME POR TELEFONO A LA OFICINA, CT.1YA DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCrA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Ear Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9106
NOTICE: PURSUANT TO THE PAIR DEBT COLLECTION PRACTICES ACT, THIS LAW
FIRM IS tlEEMlilD TO BE A DEBT COI.LECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
pURPOSE. (- J~ ~ / /
~ark J. ~_~r~n, Esqu~re
1040 North Kings 'Highway, Suite 500
Cherry Hill, New Jersey 08034
MAR-03-2~0.i.W~03:49 PM Udren Law Offices, P. C,
MARK J. UDREN << ASSOCIATES
BY: Mark J, Udren. Esquire
ATTY I,D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856~4B2.6900
Option One Mortgage corporation
Plaintiff
FAX NO, 8564288007
P. 02
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane Defrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Defendant(s)
NO. 03-3941 Civil Term
TO: Diane Defrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
DATE of Notice:
October 1, 2003
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 ~OUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT !!AVE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
/
NOTICE: PURSU~ 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.
~ Ab /s/
\tatfJ . dren, EsquJ.re
1040 North Kin Highway, Suite 500
Cherry Hill, New Jersey 08034
_ MAR-03-2004 WED 03:50 PM Udren Law Offices, P. C,
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY 1.0. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERny HILL, NJ 08034
856-482-6900
Option One Moregage Corporaeion
Plaintiff
FAX NO, 8564288007
P. 03
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane Defrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
Defendant(sl
NO. 03-3941 Civil Term
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mecnanicsburg, PA 17055
October 1, 2003
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND PILE 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
PAPER TO YOUR LAWYER AT ONCE.' IF YOlJ DO NOT HAVE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORrR B$LOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRI~G A LAWYER. IF yOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, FA 17013
717-249-3166
800-990-9106
NOTIFICACION IMPORTANTE
US TED SE ENCUENTRA Et-l ES,!'ADO DE RJ>;BJ>;LilJIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEB IDA 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, IMI?ORTANTES. DEBE LLEVAR ESTA
NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENClJENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
DATE of Notice:
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
. 2 Liberty Avenue
Carlisle, FA . 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEB'r. ANY INFORMATION OBTAINED WILL ElE' USED FOR THAT
PURPOSE.
lJG(\lJd~:~' Esquire
1040 North Kings Highway, Suite 500
Cherry Hill, New Jersey 08034
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OPTION ONE MORTGAGE
CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DIANE DeFRANK a/k/a DIANE D.
DeFRANK, JEFFREY DeFRANK,
MORTGAGOR,
DEFENDANTS
: 03-3941 CIVIL TERM
IN RE: MOTION OF PLAINTIFF FOR SUMMARY JUDGMENT
BEFORE BAYLEY, J.
ORDER OF COURT
AND NOW, this 4th day of February, 2004, the motion of plaintiff Option One
Mortgage Corporation for summary judgment against Diane DeFrank a/k/a Diane D.
DeFrank and Jeffrey DeFrank, IS GRANTED. Judgment in foreclosure is entered in
favor of plaintiff in the amount of $365,606.61 together with additional interest and costs
as allowed by law to the date of sheriff's sale.
Dale F. Shughart, Jr., Esquire
Mark J. Udren, Esquire
For Plaintiff
Robert D. Kodak, Esquire
For Defendants
:sal
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 03-3941 Civil Term
TO THE SHERIFF:
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Amount due
As set forth in Court Order
Interest per Court Order
From 12/16/03 to 2/4/04
$365,606.61
3,970.86
Interest From 2/5/04
to date of Sale June 9, 2004
Per diem $77.86
$369,577.47
9,810.36
(Costs to be added)
$
W OFFICES, P.C.
M rk J. ~e~, ESQUIRE
A~TORN~U~~i'pLAINTIFF
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION,
Plaintiff (s)
From DIANE DEFRANK A!KIA DIANE D. DEFRANK, JEFFREY DEFRANK
(1) You are directed to levy upon ilie property ofilie defendant (sland to sel! SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach ilie property of the defendant( s) not levied upon in the possession
of
GARNISHEE(S) as fol!ows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) ilie garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or oilierwise disposing thereof;
(3) lfproperty ofilie defendant(s) not levied upon an subject to attachment is found in ilie possession
of anyone oilier than a named gamishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $365,606.61 L.L. $.50
Interest PER COURT ORDER FROM 12/16/03 TO 2/4/04 - $3,970.86 --- INTEREST FROM 2/5/04
TO DATE OF SALE 6/9/04 - PER DIEM $77.86 .- $9,810.36
Atty's Corom % Due Prothy $1.00
Atty Paid $134.97 Other Costs
Plaintiff Paid
Date: MARCH 5, 2004
(Seal)
CURTIS R. LONG
Proilionota!y p em.. r-
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Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-482-6900
Supreme Court ID No. 04302
UDREN LAW OFFICES, P.C.
BY: Mark J, Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 Civil Term
Defendant(s)
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
An FHA insured mortgage
Non-owner occupied
Vacant
X Act 91 procedures have been fulfilled.
Over 24 months delinquent.
This certification is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
UDREN LAW OFFICES, P.C,
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UDREN LAW OFFICES, P.C.
BY: Mark J, Udren, Esquire
ATTY I.D, NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 Civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Diane DeFrank
a/k/a Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
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.
Harvey Hoffman
Address to Follow
5. Name and address of every other person who has any record lien on the
property:
Name Address
None
6. Name and address of every other person who has any record interest in
the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover St.
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance,
Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
UDREN LAW OFFICES, P.C.
DATED: March 1, 2004
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UDREN LAW OFFICES, P.C,
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00
AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle,
PA, to enforce the court judgment of $369,577.47, obtained by Plaintiff
above (the mortgagee) against you. If the sale is postponed, the
property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856) 482-6900.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P,C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00
AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle,
PA, to enforce the court judgment of $369,577.47, obtained by Plaintiff
above (the mortgagee) against you. If the sale is postponed, the
property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffls 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 attorney1s fees. To find out how much you must
pay. you may call: (856)-482-6900.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE,
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I,D. NO, 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
C/o Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 We11gate Lane, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the
court judgment of $369,577.47, obtained by Plaintiff above (the mortgagee)
against you. If the sale is postponed, the property will be relisted for the
Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856) 482-6900.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAXE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORt> 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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
NO. 03-3941 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
C/o Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the
court judgment of $369,577.47, obtained by Plaintiff above (the mortgagee)
against you. If the sale is postponed, the property will be re1isted for the
Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff1s Sale, you must take immediate ac~ion:
1. The sale will be cancelled if you pay to the
charges I costs and reasonable attorney's fees.
you may call: (856) 482-6900.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS DE FlLADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ALL THAT CERTAIN TRACT OF LAND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND
COllNTY, PENNSYLVANIA, AND DESCRIBED ACCORDING TO A FINAL SUBDIVISION PLAN PREPARED
BY llA1tTMAN AND ASSOCJ:ATE:S, REGISTEllED PROFE:SSIONAL ENGINEERS, CAMP HILL,
PENNSYLVANIA, DATED NOVE:MBER ~, ~995, AND LAST REVJ:SED FEBRUARY 6, ~996, ANt>
RECORDED IN PLAN BOOK 72, PAGE ~25, AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHEAST SIDE OF WELLGATE LANE AND A CORml'l OF
LOT NO. 5 ON SAJ:D PLAN; THl!:NCE EXTENDING ALONG SAID LOT SOOTH ~6 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE OF 60.66 FEET TO A POINT AT A CORNER OF LANDS NOW OR
LATE OF JOHN H. RUPPERT, SR.; THENCE EXTENDING ALONG SAID LAND SOUTH ~5 DEGREES ~5
MINUTES 00 SECONDS WEST, A DISTANCE OF ~B3.72 FEET TO A POINT AT A CORNER OF LANDS
NOW OR LATE OF ELMER J. KLINE; Tlll!:NCE EXTENDING ALONG SAID LANDS AND CONTINtT.I:NG
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A DISTANCE OF 62.~~ FEET TO A POINT;
Tlll!:NCE CONTINUING NORTH 67 DEGREE:S 45 MJ:NOTES 00 SECONDS WEST, A DISTANCE OF ~75.00
FEET TO A POINT AT A CORNER OF LOT NO. 30N SAID PLAN; THENCE: EXTENDING ALONG SAID
LOT NO. ~4 DEGREES 45 MINUTES ~9 SECONDS EAST, A DISTANCE OF ~43.63 FEET TO A POINT
ON TIlE SOUTHWEST SIDE OF WELLGATE LANE, THENCE EXTENDING ALONG SAID LANE ALONG A
CURVE TO THE LEPT HAVING A RADIUS OF 330.00 FEET, THE ARC DISTANCE OF 177.~4 FEET
TO THE POINT AND PLACE OF BEGINNING.
BEING LOT NO.4.
CONTAINJ:NG 43, 389 .77 SQUARE FEET.
SUB.:rECT TO EASEMENTS, CONDITIONS AND RESTRICTIONS OF RECORD.
BEING KNOWN AS 1420 WELLGATE LANE MECHANICSBURG, PA 17055
PROPERTY ID NO: 13-11-0270-051
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFRANK, A MARRIED WOMAN BY
DEED FROM JEFFREY A. DEFRANK AND DIANE D. DEFRANK, HUS~~~~ AND WIF
02/08/02 RECORDED 02/22/02 BOOK 250 PAGE 2355. ==,~ E DATED
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UDREN LAW OFFICES, P.C.
BY: Mark J, Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendants, Jeffrey A.
DeFrank & Diane D. DeFrank, have filed Chapter 13 Bankruptcy in the
Middle District of Pennsylvania on April 14, 2004, Bankruptcy Case
No. 04-02279.
Mark J. U ren, squire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
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Option One Mortgage Corporation
VS
Diane DeFrank a!k/a Diane D.
DeFrank and Jeffrey DeFrank
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3941 Civil Term
R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ
is returned STAYED per instructions from Attorney Mark Udren.
Sheriffs Costs:
Docketing
Poundage
Posting Handbills
Advertising
Mileage
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Law Library
Prothonotary
30.00
5.08
15.00
15.00
7.59
15.00
30.00
11 0.40
29.26
.50
1.00
$258.83 paid by attorney
06/07/04
Sworn and subscribed to before me So Answers:
ThiS~dayot('~ r~#~
/ R. Thomas Kline, Sheriff
2004, A.D. C /~IA- 0 ~ #BYJo rL..,L-f~
Prothonotary Real EsJ;; Deputy
\ ,SO
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Real Estate Sale #59
On March 09, 2004 the sherifflevied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 1420 Well gate Lane,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: March 09,2004
By.-.jtc(JrMh
Real Estate Deputy
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
V1Z:
APRIL 16,23,30,2004
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 SALE NO. 119
Writ No. 2003-3941 Clv1l
Option One Mortgage Corporation
vs.
Diane DeFrank a/k/a
Diane D. DeFrank and
Jeffrey DeFrank
Atty.: Mark J. Udren
ALL THAT CERTAIN tract of land
situate in Lower Allen Township,
Cumberland County, Pennsylvania.
and descnbed accordmg to a final
subdivision plan prepared by
Hartman and Associates, Registered
Professional Engineers. Camp Hill,
Pennsylvania, dated November 1.
1995. and last revised February 6.
1996, and recorded in Plan Book
72. Page 125. as follows, to wit:
BEGINNING at a point on the
southeast side of Well gate Lane and
a corner of Lot No. 5 on said plan:
thence extending along said lot South
16 degrees 00 minutes 00 seconds
East, a distance of 60.66 feet to a
point at a corner of lands now or
late of John H. Ruppert. Sr.: thence
extending along sald land South 15
degrees 15 minutes 00 seconds
West, a distance of 183.72 feet to a
point at a corner of lands now or late
of Elmer J. Kline; thence extending
along said lands and continuing
North 74 degrees 36 minutes 00
seconds West, a distance of 62. 11
feet to a point thence continuing North
67 degrees 45 minutes 00 seconds
West, a distance of 175.00 feet to a
point at a corner of Lot No.3 on
said plan: thence extending along
said Lot No. 14 degrees 45 mlnutes
19 seconds East, a distance of 143-
L ~'_lJl;;;-
TO AND SUBSCRIBED before me this
30 day of APRIL 2004
JtA' ~.JL. h/lclJ'A./
NJi. ~HrAt SEAL (j
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2005
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Diane DeFrank aj K! a
Diane D. DeFrank and
Jeffrey DeFrank
Atty.: Mark J. Udren
ALL THAT CERTAIN tract of land
situate in Lower Allen Township,
Cumberland County, Pennsylvania.
and described according to a final
subdivision plan prepared by
Hartman and Associates, Registered
Professional Engineers, Camp Hill,
Pennsylvania, dated November 1,
1995, and last revised February 6.
1996, and recorded in Plan Book
72. Page 125. as follows, to wit:
BEGINNING at a point on the
southeast side of Weligate Lane and
a corner of Lot No. 5 on Bald plan;
thence extending along said lot South
16 degrees 00 minutes 00 seconds
East. a distance of 60.66 feet to a
point at a comer of lands now or
late of John H. Ruppert, Sr.; thence
extending along said land South 15
degrees 15 minutes 00 seconds
West. a distance of 183.72 feet to a
point at a comer of lands now or late
of Elmer J. Kline; thence extending
along said lands and continuing
North 74 degrees 36 minutes 00
seconds West, a distance of 62.11
feet to a point: thence continuing North
67 degrees 45 minutes 00 seconds
West. a distance of 175.00 feet to a
point at a comer of Lot No.3 on
said plan; thence extending along
said Lot No. 14 degrees 45 mlnute.
19 seconds East. a distance of 143.
.63 feet to a point on the southwest
alde of Wellgate Lane: thence extend-
ing along said lane along a curve to
the left having a radius of 330.00
feet, the arc distance of 177.14 feet
to the point and place of beginning.
BEING Lot No.4.
CONTAINING 43.389.77 square
feet.
SUBJECT to easements, condi.
tions and restrictions of record.
BEING KNOWN AS 1420 Wellgate
Lane. Mechanicsburg, PA 17055.
PROPERTI lD NO: 13-\\-0270-
05l.
TITLE TO SAID PREMISES IS
VESTED IN Diane D. DeFrank. a
married woman by deed from Jef-
frey A. DeF'rank and Diane D. De.
Frank. husband and wife dated 02/
08/02 recorded 02/22/02 Book
250 Page 2355.
~VVV.l.'-l.' _
30 day of.
~L~~./
N
NOTK
LOIS E. SNY
Carlisle Bora,
My Commissio~
UDREN LAW OFFICES, P,C,
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
PRAECIPE TO ISSUE WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Interest From 02/05/04
to Date of Sale 09/07/05
Per diem @$79.26
$369.577.47
46.050.06
Amount due
(Costs to be added)
$
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLV ANlA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION - LAW
TO THE SHERlFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Option One Mortgage Corporation Plaintiff (s)
From Diane DeFrank a/k/a Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane, Mechanicsburg, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47
L.L.
Interest from 2/5/04 to date of sale 9/7/05
Per diem@$79.26
Atty's Comm %
Atty Paid
Other Costs
$46,050.06
Due prothy $1.00
Atby
'PlaHllilfPaid $406.30
Date: June 6, 2005
(Seal)
CURTIS R. LONG
Prothonotary
By: "'~a ,K', ~~ 9J.Z'
Deputy
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address: Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Attorney for: Plaintiff
Telephone: 856-669-5400
Supreme Court ID 04302
,--------
Middle District of Pennsylvania
Case No. 1 :04-bk-02279-MDF
Chapter 7
D':SJ1\PtD
%
Form B18 (Official Form 18)(12103)
United SOltes Bankruptcy Court
In reo Deblor(s) (narne(s) used by the debtor(s) in the last 6 years, including married, maiden, trade, and address):
Jeffrey A. Defrank Diane D. Defrank
1420 WELLGATE LANE 1420 WELLGATE LANE
MECHANICSBURG, PA 17055 MECHANICSBURG, PA 17055
Social Security No.:
xxx-xx-5OJ 1
Employer's Tax I.D. No.:
xxx-xx-5200
DISCHARGE OF DEBTOR
It appearing that the debtor is entitled to a discharge,
IT IS ORDERED:
The debtor is granted a discharge under section 727 of title 11, United States Code. (the Bankruptcy Code).
BY TIlE COURT
Dated: 4/13/05
7f~:lOa ~
United States Bankruptcy Judge
SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION.
.... '.
FORM B 18 continued (1/97)
EXPLANATION OF BANKRUPTCY DISCHARGE
IN A CHAPTER 7 CASE
This court order grants a discharge to the person named as the debtor. It is not a dismissal of the case
and it does not determine how much money, if any, the trustee will pay to creditors.
Collection of Discharl!ed Debt. Probibited
The discharge prohibits any attempt to collect from the debtor a debt that has been discbarged. For
example, a creditor is not permitted to contact a debtor by mail, pbone, or otherwise, to file or continue a lawsuit, to
attach wages or other property, or to take any other action to collect a discharged debt from the debtor. [In a case
involving community property:] [There are also special rules that protect certain community property owned by the
debtor's spouse, even if that spouse did not file a bankruptcy case.] A creditor who violates this order can be required
to pay damages and attorney's fees to the debtor.
However, a creditor may have the right to enforce a valid lien, such as a mortgage or security interest,
against the debtor's property after the bankruptcy, if that lien was not avoided or eliminated in the bankruptcy case.
Also, a debtor may voluntarily pay any debt that has been discharged.
Debts That are Discbarl!ed
The chapter 7 discharge order eliminates a debtor's legal obligation to pay a debt that is discharged,
Most, but not all, types of debts are discharged if the debt existed on the date the bankruptcy case was filed. (If this
case was begun under a different chapter of tbe Bankruptcy Code and converted to chapter 7, the discharge applies to
debts owed when the bankruptcy case was converted.)
Debt. that are Not Discbarl!ed.
Some of the common types of debts which are !lQ1 discharged in a chapter 7 bankruptcy case are:
a. Debts for most taxes:
b, Debts that are in the nature of alimony, maintenance, or support;
c. Debts for most student loans;
d. Debts for most fines, penalties, forfeitures, or criminal restitution obligations:
e. Debts for personal injuries or death caused by the debtor's operation of a motor vehicle while intoxicated;
f. Some debts which were not properly listed by the debtor;
g. Debts that the bankruptcy court specifically has decided or will decide in this bankruptcy case are not
discharged;
h. Debts for which the debtor has given up the discharge protections by signing a reaffirmation agreement in
compliance with the Bankruptcy Code requirements for reaffirmation of debts.
This information is only a general summary of the bankruptcy discharge. Tbere are exceptions
to these general rules. Because the law is complicated, you may want to consult an attorney to detennine the
exact effect of the discharge in this case.
UDREN LAW OFFICES, P,C.
BY: Mark J, Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
An FHA insured mortgage
Non-owner occupied
Vacant
X Act 91 procedures have been fulfilled.
Over 24 months delinquent.
This certification is m
Sec. 4904 relating to unswo
18 Pa. C.S.
.C.
ark J. Udren, QUIRE
TTORNEY FOR PLAINTIFF
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UDREN LAW OFFICES, P.C.
BY, Mark J, Udren, Esquire
ATTY I,D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
None
,.
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4. Name and address of the last recorded holder of every mortgage of
record:
Name
plaintiff herein.
Address
See Caption above.
Harvey Hoffman
Address to follow
PNC Bank N A
500 West Jefferson Street
Louisville, KY 40202
c/o Frank Federman
2 Penn Center Plaza, Suite 900
Philadelphia, PA 19102
5. Name and address of every other person who has any record lien on the
property:
Name Address
None
6. Name and address of every other person who has any record interest in
the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover St.
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: May 31, 2005
Mark J. U ren, ESQ.
Attorney for Plaintiff
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10: 00 AM in the commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this SheriffJs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment. late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment. if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
...
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE,
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORP 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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P,C.
BY: Mark J. Udren, Esquire
ATTY I.D, NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffls Sale, you must take immediate action:
1. The sale will be canceled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856) -669-5400.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
j
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was 'paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I,D, NO. 04302
WOODCREST CORPORATE CENTER
~~~ WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a NO. 03-3941 civil Term
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NOTICE OF SHERIFF S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
c/o Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff1s Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
{See notice on page two on how
/
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE,
1. If the Sheriff1s Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a NO. 03-3941 civil Term
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NOTICE OF SHERIFF S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
c/o Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: (856)-669-5400.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.}
The sooner you contact one, the
(See notice on page two on how
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE,
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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ALL THAT CERTAIN TRACT OF LAND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, AND DESCRIBED ACCORDING TO A FINAL SUBDIVISION PLAN PREPARED
BY HARTMAN AND ASSOCIATES, REGISTERED PROFESSIONAL ENGINEERS, CAMP HILL,
PENNSYLVANIA, DATED NOVEMBER 1, 1995, AND LAST REVISED FEBRUARY 6, 1996, AND
RECORDED IN PLAN BOOK 72, PAGE 125, AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHEAST SIDE OF WELLGATE LANE AND A CORNER OF
~OT NO. 5 ON SAID PLAN; THENCE EXTENDING ALONG SAID LOT SOUTH 16 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE OF 60.66 FEET TO A POINT AT A CORNER OF LANDS NOW OR
LATE OF JOHN H. RUPPERT, SR., THENCE EXTENDING ALONG SAID LAND SOUTH 15 DEGREES 15
MINUTES 00 SECONDS WEST, A DISTANCE OF 183.72 FEET TO A POINT AT A CORNER OF LANDS
NOW OR LATE OF ELMER J. KLINE; THENCE EXTENDING ALONG SAID LANDS AND CONTINUING
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A DISTANCE OF 62.11 FEET TO A POINT;
THENCE CONTINUING NORTH 67 DEGREES 45 MINUTES 00 SECONDS WEST, A DISTANCE OF 175.00
FEET TO A POINT AT A CORNER OF LOT NO. 30N SAID PLAN, THENCE EXTENDING ALONG SAID
LOT NO. 14 DEGREES 45 MINUTES 19 SECONDS EAST, A DISTANCE OF 143.63 FEET TO A POINT
ON THE SOUTHWEST SIDE OF WELLGATE LANE, THENCE EXTENDING ALONG SAID LANE ALONG A
CURVE TO THE LEFT HAVING A RADIUS OF 330.00 FEET, THE ARC DISTANCE OF 177.14 FEET
TO THE POINT AND PLACE OF BEGINNING.
BEING LOT NO.4.
CONTAINING 43,389.77 SQUARE FEET.
SUBJECT TO EASEMENTS, CONDITIONS AND RESTRICTIONS OF RECORD.
BEING KNOWN AS:
PROPERTY ID NO. ;
1420 WELLGATE LANE, MECHANICSBURG, PA 17055
13-11-0270-051
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFRANK, A MARRIED WOMAN BY
DEED FROM JEFFREY A. DEFRANK AND DIANE D. DEFRANK, HUSBAND AND WIFE DATED
02/08/02 RECORDED 02/22/02 IN DEED BOOK 250 PAGE 2355.
-.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
~~~ WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 03-3941 Civil Term
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendants, Diane DeFrank
aka Diane D. DeFrank and Jeffrey DeFrank have filed Chapter 13
Bankruptcy in the Middle District of Pennsylvania on July 13, 2005,
Bankruptcy Case No. #05-04616.
Mark J.
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
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Option One Mortgage Corporation
VS
Diane DeFrank a/kJa Diane D. DeFrank
And Jeffrey DeFrank
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3941 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Mark 1. Udren.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Levy
Mileage
Certified Mail
Surcharge
Law Journal
Share of Bills
Prothonotary
30.00
5.83
15.00
15.00
15.00
22.40
3.86
30.00
141.00
18.20
1.00
$297.29
Sworn and subscribed to before me
2005, A.D.
Prothonotary
So An;~r~
r~t"5~e?'~
R. Thomas Kline, Sheriff
BY \'!J ~JU)..{h
Real Esta e Sergeant
(1
\,00 OL.6/)'1'1L-
~ 1L.f~OV
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
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
Plaintiff herein.
Address
. ,
See Capt10n above.
Harvey Hoffman
Address to follow
PNC Bank N A
500 West Jefferson Street
Louisville, KY 40202
c/o Frank Federman
2 Penn Center Plaza, Suite 900
Philadelphia, PA 19102
5. Name and address of every other person who has any record lien on the
property:
Name Address
None
6. Name and address of every other person who has any record interest in
the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover St.
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esq.
407 North Front Street
PO Box 11848
Harrisburg, PA 17108
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: May 31, 2005
Mark J. U ren, ESQ.
Attorney for Plaintiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
~11 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: 18561 -669-5400.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the'price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was .paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
1~1 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at
10: 00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call, (856) 669-5400.
mortgagee the back payment, late
To find out how much you must pay,
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights.
more chance you will have of stopping the sale.
to obtain an attorney.)
The sooner you contact one, the
(See notice on page two on how
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is'not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ALL THAT CERTAIN TRACT OF LAND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND
COUNTy, PENNSYLVANIA. AND DESCRIBED ACCORD!NG TO A FINAL SUBDIVISION PLAN PREPARED
BY HARTMAN AND ASSOCIATES, REGISTERED PROFESSIONAL ENGINEERS. CAMP HILL.
PENNSYLVANIA, DATED NOVEMBER 1, 1995, AND LAST REVISED FEBRUARY 6. 1996, AND
RECORDED IN PLAN BOOK 72, PAGE 125. AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHEAST SIDE OF WELLGATE LANE AND A CORNER OF
LOT NO. 5 ON SAID PLAN, THENCE EXTENDING ALONG SAID LOT SOUTH 16 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE OF 60.66 FEET TO A POINT AT A CORNER OF LANDS NOW OR
LATE OF JOHN H. RUPPERT, SR., THENCE EXTENDING ALONG SAID LAND SOUTH 15 DEGREES 15
MINUTES 00 SECONDS WEST, A DISTANCE OF 183.72 FEET TO A POINT AT A CORNER OF LANDS
NOW OR LATE OF ELMER J. KLINE; THENCE EXTENDING ALONG SAID LANDS AND CONTINUING
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A DISTANCE OF 62.11 FEET TO A POINT;
THENCE CONTINUING NORTH 67 DEGREES 45 MINUTES 00 SECONDS WEST, A DISTANCE OF 175.00
FEET TO A POINT AT A CORNER OF LOT NO. 30N SAID PLAN, THENCE EXTENDING ALONG SAID
LOT NO. 14 DEGREES 45 MINUTES 19 SECONDS EAST, A DISTANCE OF 143.63 FEET TO A POINT
ON THE SOUTHWEST SIDE OF WELLGATE LANE, THENCE EXTENDING ALONG SAID LANE ALONG A
CURVE TO THE LEFT HAVING A RADIUS OF 330.00 FEET, THE ARC DISTANCE OF 177.14 FEET
TO THE POINT AND PLACE OF BEGINNING.
BEING LOT NO.4.
CONTAINING 43,389.77 SQUARE FEET.
SUBJECT TO EASEMENTS, CONDITIONS AND RESTRICTIONS OF RECORD.
BEING KNOWN AS:
1420 WELLGATE LANE, MECHANICSBURG, PA 17055
PROPERTY ID NO.
13-11-0270-051
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFRANK, A MARRIED WOMAN BY
DEED FROM JEFFREY A. DEFRANK AND DIANE D. DEFRANK, HUSBAND AND WIFE DATED
02/08/02 RECORDED 02/22/02 IN DEED BOOK 250 PAGE 2355.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt. interest and costs due Option One Mortgage Corporation Plaintiff (s)
From Diane DeFrank a/k/a Diane D. DeFrank
NO 03-3941 Civil
CIVIL ACTION - LAW
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane, Mechanicsburg, PA 17055
(I) You are directed to levy upon the property of the defendant (s)and to sell see legal description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47
L.L.
Interest from 2/5/04 to date of sale 917/05
Per diem @$79.26
Atty's Connn %
Ally Paid
Other Costs
$46,050.06
Due Prothy $1.00
MA-)'
PI.iDtiff Paid $406.30
Date: June 6, 2005
(Seal)
Prothonotary
By: ~~a ,k' ~.4, -9:f
Deputy
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address: Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Attorney for: Plaintiff
Telephone: 856-669-5400
Supreme Court ID 04302
Real Estate Sale #59
On June 13, 2005 the Sherifflevied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 1420 Wellgate Lane,
Mechanicsburg, more fully described on Exhibit "A"
Date: June 13,2005
By:~,~-.--:tt
Real Estatl5:~ty
ca
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c:v:tJ
I::::::J
GV
G;;;1
filed with this writ and by this reference incorporated herein.
SE:\ d B- Nflf SUUl
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\j1~M3~isl)31 it'jQ 'j:) i.:i~'6'
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
55.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
9.1.1 ~ Ie -s; d tJ() -,::;-
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.
S ORN TO AND SUBSCRIBED before me this
IS- dayof n, c2CJCJ6
LSEA
LOIS E. SNYDER, Notary Public
Ca"sle,Bo,o. Cumbe,'and County
My CommlSSloo Expires March 5, 2009
REAL ESTATE SALE NO. 511
Writ No. 2003-3941 Civil
Option One Mortgage Corporation
vs.
Diane DeFrank, a(kj a
Diane D. DeFrank and
Jeffrey DeFrank
Atty.: Mark J, Udren
ALL THAT CERTAIN tract of land
situate in LQwer Allen Township,
Cumberland County. Pennsylvania,
and described according to a Final
Subdivision Plan prepared by Hart-
man and Associates. Registered Pro-
fessional Engineers, Camp Hlll,
Pennsylvania. dated November I,
1995. and last revised February 6,
1996. and recorded in Plan Book
72. Page 125, as follows. to wit:
BEGINNING at a point on the
southeast side of Wellgate Lane and
a comer of Lot No. 5 on said plan;
thence extending along said lot
South 16 degrees 00 minutes 00
seconds East, a distance of 60.66
feet to a point at a comer of lands
now or late of John H. Ruppert. Sr.;
thence extending along said land
South 15 degrees 15 minutes 00
seconds West. a distance of 183.72
feet to a point at a comer of lands
now or late ofElmerJ. Kline; thence
extendmg along said lands and con-
tinuing North 74 degrees 36 min-
utes 00 seconds West. a distance
of 62.11 feet to a point; thence con-
tinuing North 67 degrees 45 min-
utes 00 seconds West. a distance
of 175.00 feet to a pOint at a corner
of Lot No. 3 on saId plan; thence
extending along saId Lot No. 14 de-
grees 45 minutes 19 seconds East.
a dIstance of 143.63 feet to a point
on the southwest side of Wellgate
Lane: thence eKtending along said
lane along a curve to the left having
a radtus of 330.00 feet, the arc dis-
tance of 177.14 feet to the point
and place of beginning.
BEING Lot No.4.
CONTAINING 43.389.77 square
feet.
SUBJECT to easements. condi-
tions and restrictions of record.
BEING KNOWN AS: 1420 WelIgate
Lane. Mecbanicsburg. PA 17055.
PROPERlY 1D NO.: 13-11-0270-
051.
TITLE TO SAID PREMISES IS
VESTED IN Diane D. DeFrank. a
married woman by Deed from Jef-
frey A. DeFrank and Diane D. De-
Frank. husband and wife dated 02/
08/02 recorded 02{22/02 in Deed
Book 250. Page 2355.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
PRAECIPE TO ISSUE WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due $369.577.47
Interest From 2/5/04 66.922.73
to Date of Sale March 8, 2006
Ongoing Per Diem of $87.71
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
UDREN LAW OFFICES, P.C.
Mark
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION,
Plaintiff (s)
From DIANE DEFRANK AlKlA DIANE D. DEFRANK AND JEFFREY DEFRANK
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION,
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47
L.L.
Interest FROM 2/5/04 TO DATE OF SALE 3/8/06 ONGOING PER DIEM OF $87.71 TO ACTUAL
DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $66,922.73
Atty's Comm % Due Prothy $1.00
Atty Paid $718.59
Plaintiff Paid
Other Costs
Date: DECEMBER 7,2005
CURTIS R. LONG
(Seal)
Proth~ry
'Iiy: (J/)- "
,P ~A."V~j
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICE, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 04302
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
Diane Dorothea DeFrank
Jeffrey Allan DeFrank
CHAPTER 13
CASE NO.: 1-05-bk-04616
Debtor(s)
ORDER DISMISSING CASE
It appearing that the above-named debtor(s) has/have failed to file the required
documents and it having been determined after notice that the case should be dismissed.
it is
ORDERED that the case of the above-named debtor(s) be and it hereby is
dismissed and it is further
ORDERED that the trustee hereby is discharged from further responsibility in this
case. and it is further
ORDERED that all pending adversary proceedings in this case be and they hereby
are dismissed. and it is further
ORDERED that any outstanding fees are immediately due and payable to the U.S.
Bankruptcy Court.
B)' tIlt Com1:.
JVa~
7b",<<, '-"'l
This electronic order is signed and filed on the same date.
Dated: September 8, 2005
MDPA.DISMISS1.WPT REV 6105
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are
not subject to the provisions of Act 91 because it is:
An FHA insured mortgage
Non-owner occupied
X 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.
UDREN LAW OFFICES, P.C.
Mark J. Udren, ESQUIRE
ATTORNEY FOR PLAINTIFF
-:,.'"
,
~., 1
'-.'.,
(,
UDREN LAW OFFICES, P.C.
BY~ Mark J. Udren, Esquire
~
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane
Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and
record lien
Name
address of every judgment creditor
on the real property to be sold:
Address
whose judgment
is a
Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128-0946
4. ~Name
re~rd:
.
Name
and address of the last recorded holder of every mortgage of
Address
Plaintiff herein.
See Caption above.
PNC Bank NA
500 West Jefferseon Street
Louisville, KY 40202
Thomas J. Abraham and
Sheryl L. Abraham
945 Siddonsburg Road
Lewisberry, PA 17339
5. Name and address of every other person who has any record lien on
the property:
Name Address
None
6. Name and address
in the property and
Name
of every other person
whose interest may be
Address
who has any record interest
affected by the sale:
Real Estate Tax Dept.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants
1420 Wellgate Lane
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.
UDREN LAW OFFICES, P.C.
DATED: December 5, 2005
Mark J. Udren, ESQ.
Attorney for Plaintiff
..
( - ~\
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...
.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call: (856) -669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
-.
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. TO find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
S. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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ATTORNEY FOR PLAINTIFF
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Salel 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 attorney1s fees. To find out how much you must
pay. you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
~~
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped. your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013
717-249-3166
800-990-9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 03-3941 Civil Term
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant (s), JEFFREY A.
DeFRANK AND DIANE D. DeFRANK has filed Chapter 13 Bankruptcy in the
MIDDLE District of Pennsylvania (HARRISBURG) on OCTOBER 14, 2005,
Bankruptcy Case No. 05-08998.
M
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
C,)
,'"
C:J
Option One Mortgage Corporation
VS
Diane DeFrank a/kJa Diane D.
DeFrank and Jeffrey DeFrank
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3941 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Mark Udren.
Sheriffs Costs:
Docketing
Surcharge
Prothonotary
Poundage
Levy
Advertising
Posting Handbills
Share of Bills
Mileage
30.00
30.00
1.00
2.79
15.00
15.00
15.00
21.05
12.32
$142.16
Sworn and subscribed to before me
~\
~~
~~
R. Thomas Kline, Sheriff
2006, A.D.
Prothonotary
BY\JC)~
Real Esta Sergeant
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upREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane
Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s)
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS # 1 ABOVE
3. Name and
record lien
Name
address of every judgment creditor
on the real property to be sold:
Address
whose judgment
is a
Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128-0946
~
4, Name and address of the last recorded holder of every mortgage of
record:
Name Address
plaintiff herein.
See Caption above.
PNC Bank NA
500 West Jefferseon Street
Louisville, KY 40202
Thomas J. Abraham and
Sheryl L. Abraham
945 Siddonsburg Road
Lewisberry, PA 17339
5. Name and address of every other person who has any record lien on
the property:
Name Address
None
6. Name and address
in the property and
Name
of every other person
whose interest may be
Address
who has any record interest
affected by the sale:
Real Estate Tax Dept.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsb'lrg, 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_
UDREN LAW OFFICES, P.C.
DATED: December 5, 2005
Mark J. Udren, ESQ.
Attorney for Plaintiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY 1.0. NO. 04302
WOOD CREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff1s Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorneyrs fees. To find out how much you must
pay. you may call: (856) -669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
YO~ MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
,..
\<'
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant s)
NO. 03-3941 civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 8, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA, to enforce the court judgment of $369,577.47, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffls Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call, (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
st~ike 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
the more chance you will have of stopping the sale.
how to obtain an attorney.)
sooner you contact one,
(See notice on page two on
~
,
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffls Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that ~ime, the
6. You may be entitled to a share of the money which was paid fo~ your
house. A schedule of distribution of the money bid for your house will be =iled by
the Sheriff within 30 days afte~ the sale. This schedule will s~ate who will be
receiving that money. The money will be paid out in accordance with this schedule
unless excep~ions (reasons why the proposed distribution is wrong) ar~ filed with the
Sherif= 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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
~~ THP~ 2ERTkIN TRA~T OF ~ S:TUATE IN LO~~R ALLER TOWNS~I~, CUMBEP~~'
COm.~, PENNSY',V.A.NIl.., AND DESCRIBED ACCORDING TO 1-~ FINA:.., SUED1:.,,'ISION ?L~lU\ PREP1>..REt;
B~ HARTY~ MID ASSOCIATES, REG=STEP~D PROFESSION~ ENGIh~ERS, C]>~ E:L~,
PENNSYLVA.KIA, DATED NO"iJ'"'l<'.......MBER .:., 1995, J..RD LAST RE\'ISED FEBRUJ..RY 6, 1996, AIm
P~:ORDED IN p~ BOOK 72, PAGE 125, AS FO~LOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHEAST SIDE O~ WELL GATE LANE AND A CORNER O~
LO':' NO.3 ON SA.:tD PLAN; THENCE EXTENDING J...LONG SAID LOT SDtT':'E 16 DEGREES 00 YJh'iJ'TES
DD SECOh~S EAS~, A DISTANCE O~ 60.66 FEET TO A POI~ A7 A COP~R OF ~s NOW OR
LF~E OF JOHN E. RUPPERT, SR.; THENCE EXTENDING ALONG SAID LAND SOu~R ~5 DEGREES 15
MINUTES 00 SECONDS WEST, A DISTANCE OF l83.72 FEET TO A POI~ A~ A ~ORNER OF iJU~S
NOW OR :uJ>..TE OF EL..1'.1ER .:J. Ki.INE i THENCE E:i:TE'NDING A.i,ONG SJ..ln :i:...ANDS AND CD:N"TINtTING
NORTH 74 DEGREES 36 MINUTES 00 SE~ONDS WES~, A DIS~ANCE ~F 6:.l1 FEET TO A POI1\T;
THENCE CO~INUING NOR~H 67 DEGREES 45 MI~~ES 00 SECONDS WES~, A DI3TAN=E OF 175.00
FEET TO A POI~ AT A CORNER OF LOT NO. 30N SAID PLAN; THENCE EXTENDING ALONG Sh~D
~OT NO. 14 DEGREES 45 MINUTES 19 SECOh~S EAST, A D!STAN~E OF 143.63 FEET TO A POIN7
OK 7RE SO~~HWEST SIDE OF WELLGATE ~; THEN2E EXTENDING ALONG S~ID ~ ~~ONG h
2TIRVE TO THE LEFT HAVING A RP~IUS OF 330.0C FEET, THE ~~c DISTANCE OF :77.14 FEET
TO THE POINT AND PLACE OF BEGINNING.
BErNG LOT NO.4.
COl1TAINING 42,389.77 SQUARE FE~T.
SUBJECT TO EASEME~~S, COh~I~IONS AND RESTRICTIONS OF RECOP~.
BEING KNOWN .AS:
1420 Wellgate Lane, Mechanicsburg, PA 17CSS
PROPERTY :CD NO.
13-11-0270-031
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFPJiliK, A MARRIED WOMAN BY
D~ED FROM JEFFREY A. DEFRANK AND DI_~E D. DEFRANK, HUSBAND AND WIFE DATED
2;8/02 RECORDED 2/22/02 IN DEED BOOK 230 PAGE 2355.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION,
Plaintiff (s)
From DIANE DEFRANK AlKlA DIANE D. DEFRANK AND JEFFREY DEFRANK
(I) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION,
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47
L.L.
Interest FROM 2/5/04 TO DATE OF SALE 3/8/06 ONGOING PER DIEM OF $87.71 TO ACTUAL
DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $66,922.73
Atty's Comm % Due Prothy $1.00
Atty Paid $718.59
Plaintiff Paid
Other Costs
Date: DECEMBER 7, 2005
CURTIS R. LONG
(Seal)
Prothonotary ~
~~c P. t'~r,-)
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICE, P.c.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No, 04302
Real Estate Sale # 53
On Decemberl2, 2005 the Sherifflevied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 1420 Wellgate Lane,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: December 12,2005
BYU&-~J~
Real Estate' Sergeant
bZ :b 'V 8- 330 SOBl
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.:I.:Hll3HS 3Hl .:10331.:1.:10
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Diane DeFrank
a/k/a Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 03-3941 Civil Term
TO THE SHERIFF:
PRAECIPE TO ISSUE WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Amount due
$369.577.47
Interest From 2/5/04 73.499.84
to Date of Sale Seotember 6, 2006
Ongoing Per Diem of $77.86
to actual date of sale including if sale is
held at a later date
(Costs to be added)
$
OFFICES, P.C.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION,
Plaintiff (s)
From DIANE DEFRANK AlKJA DIANE D. DEFRANK, JEFFREY DEFRANK, MORTGAGOR
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47 L.L.
Interest FROM 2/5/04 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $77.86 TO ACTUAL
DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $73,499.84
Atty's Comm % Due Prothy $1.00
Arty Paid $875.75 Other Costs
Plaintiff Paid
Date: MAY 31, 2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.c.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SIDTE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court In No. 04302
.---------.
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYL VANIA
INRE:
Jeffrey A DeFrank
Diane D DeFrank
Chapter 13
Case No.: 1-05-bk-08998
Debtor(s)
ORDER DISMISSING CASE
At Harrisburg, in said district, upon consideration of the Trustee's Motion to dismiss case
for material default and it having been determined after notice and hearing and Debtor's failure to
appear at said hearing that the case should be dismissed, it is
ORDERED that the case of the above-named dehtor(s) be and it hereby is dismissed and
it is further
ORDERED that the trustee hereby is discharged from furtherresponsibility in this case, and
it is further
ORDERED that all pending adversary proceedings in this case be and they hereby are
dismissed, and it is further
ORDERED that any outstanding fees are immediately due and payable to the U.S.
Bankruptcy Court.
By the Court.
~~~!;
This electronic order is signed and filed on the same date.
Dated: March 24, 2006
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
C E R T I F I CAT E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are
not subject to the provisions of Act 91 because it is:
An FHA insured mortgage
Non-owner occupied
Vacant
X Act 91 procedures have been fulfilled.
Over 24 months delinquent.
This certification is made subject to the penalti s of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authori ies.
Mark J. Udren, ESQUIRE
ATTORNEY FOR PLAINTIFF
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane,
Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
3. Name and
record lien
Name
address of every judgment creditor whose judgment is a
on the real property to be sold:
Address
None
",
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4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC Bank NA
500 West Jefferson Street
Louisville, KY 40202
c/o Frank Federman, Esquire
2 Penn Center Plaza, Suite 900
Philadelphia, PA 19102
Harvey Hoffman Address to Follow
5. Name and address of every other person who has any record lien on
the property:
Name Address
None
6. Name and address
in the property and
Name
of every other person
whose interest may be
Address
who has any record interest
affected by the sale:
Real Estate Tax Dept.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
"
-
I verify that the statements made in this affidavit are tru and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject 0 the
penalties of 18 Pa.C.S. sec. 4904 relating to unsworn fals'fication to
authorities.
DATED: May 30, 2006
OFFICES, P. .
Mark J. Udren, ESQ.
Attorney for Plaintiff
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Fl., Courthouse,
Carlisle, PA , to enforce the court judgment of $369,577.47, obtained
by plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment. if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
,
l
'-
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full ,amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800- 990- 9108
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
c/o Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Fl., Courthouse,
Carlisle, PA , to enforce the court judgment of $369,577.47, obtained
by Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
~
~
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. TO find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until
paid to the Sheriff and the Sheriff gives a deed to the buyer.
buyer may bring legal proceedings to evict you.
the full amount due is
At that time, the
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
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
....
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.?-..L:U '!'EA.'!' CEP..'l"A=N ':'E,AC= OF LAND S=TUATE nr LOWER AL~ZN ':'OWNSHI?, C:JM:BERLAND
COmrr!, P:E:NN'Sy!.t.......AN'I.?~. AND OESC:9~BED ACCORDntG '!C A PINAL SUBDIVISION PLAN PREPARED
3Y HARTMAN AND ASSOCIATES, ?...EG::STElU!:D P~OFESSIONAL ENGZNEERS, CAMP nL:U,
?:sNNSYLil'AN~. DATEO NOVEMBEP.. 1, 19-95. AND LAST RE\i.ISED FEBRUARY 6, :'996, ~~
P...ECORDED :N PLAN BOOK 72, PAGE 125, AS FOLLOWS, ':'0 WIT:
EEG:I:NN"'"..HG AT A PODlT ON Tl!E SOUTEEAST SZDE OF WELLGATE LANE AND A CORNER OF
LOT NO. 5 ON SAID PLAN, TEENCE EXTENDING ALONG SAID LOT SOUTH 16 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE OF 60.66 FEET TO A POINT AT A CORNER OF LANDS NOW OR
llTE OF JOHN H. RUPPERT, SR., -r=CE =ENDD1G ALONG SAID ~ SOUTR 15 DEGREES 15
MINUTES 00 SECONPS WEST, A DISTANCE OF 183.72 FEET TO A POINT AT A CORNER OF LANDS
NOW OR LATE OF ELMER u. KLZ:NE; THENC~ EXTENDING ALONG SAID LANDS AND CON'rJ:NODJG
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A D:I:STANCE OF 62.11 FEET TO A POrNT;
TE:ENCE CONTINUING NORTH 67 DEGREES 45 MINUTES 00 SECONDS WEST, A DISTANCE OF 175.00
FEET TO A PODlT AT A CORNER OF LOT NO. 30N SA.l.'"D PLAN, TREN"" =ENDrNG ALONG SAID
LOT NO. 14 DEGREES 45 MINUTES 19 SECONDS EAST, A DISTANCE OF 143.63 FEET TO A POL~
ON THE SOUTHWEST S:tDE OF WELLGATE LANE, THENCE EZTEND:tNG ALONG SAID LANE ALONG A
CURVE TO THE LEFT aAVING A RAD:tUS OF 330.00 FEET. TEE _~C DISTANCE OF 177.14 FEET
TO ':'SE ponrr AND PUCE 01" BEGI:NNING.
:BEING LOT NO.4.
CONTAINrNG 43,389.77 SQUARE FEET.
StlllJECT TO EASEMENTS, CONDITIONS AND RESTP.ICTrONS OF RECORD.
PROPERTY ID NO. :
1420 WELLGATE LANE
MECHANICSBURG, PA 17055
13-11-0270-051
BEING KNOWN AS:
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFRANK, A MARRIED WOMAN BY
DEED FROM JEFFREY A. DEFRANK AND DIANE D. DEFRANK, HUSBAND AND WIFE DATED
2/8/02 RECORDED 2/22/02 IN DEED BOOK 250 PAGE 2355.
"
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
NO. 03-3941 Civil Term
Defendant(s)
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire, hereby certify that I have served
true and correct copies of the Notice of Sale upon the following
person (s) named herein at their last known address or their
attorney of record.
Regular First Class Mail
Certified Mail
Other (certificate of mailing)
Date Served: August 4, 1006
xxxxxx
xxxxxx
TO: USA, US Attorney
US Department of Justice
Federal Building
228 Walnut Street-P.O. Box 11754
Harribsurg, PA 17108
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HARRISBURG, PA 17108
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· Complete items 1, 2, and 3. Also complete
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1. Article Addressed to:
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D. Is delivery address different from item 1? 0 Yes
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USA, US ATTORNEY
US DEPARTMENT OF JUSTICE
FEDERAL BUILDING
228 WALNUT STREET-P.O. BOX 11754
HARRISBURG, PA 17108
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PS Form 3811, February 2004
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
ATTORNEY FOR PLAINTIFF
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
NO. 03-3941 Civil Term
Defendant(s)
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire, hereby certify that I have served
true and correct copies of the Notice of Sale upon the following
person (s) named herein at their last known address or their
attorney of record.
Regular First Class Mail
Certified Mail
Other (certificate of mailing)
Date Served: August I, 2006
TO: Jeffrey DeFrank, MOrtgagor
Diane DeFrank aka Diane D. DeFrank
c/o Robert D. Kodak, Esquire
407 Front Street
P.O. Box 11848
Harrisburg, PA 17108
xxxxxx
xxxxxx
ES, P.C.
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__.....___.____, c/o Robert D. Kodak, Esquire __.._____________..__
CIty, StIIIe,ZIP< 407 Front Street, P.O. Box 11848
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Complete items 1, 2, and 3. Also complete
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. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article Addressed to:
Jeffrey DeFrank, Mortgagor
Diane DeFrank a/k/a
Diane D. DeFrank
c/o Robert D. Kodak! Esquire
407 Front Street, P.O. Box 11848
Harrisburg, PA 17108
2. Afttcle Number
(ii;Jnsfer from service label)
PS Fpnn 3811. February 2004
o Agent
o Addressee
B. Received by ( Printed NamellJ~ ,~. ,r~.livery
D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
3. Service Type
~Certlfied Mail 0 Express Mail
D~istered 1S.Betum Receipt for Merchandise
o Insured Mail 0 ~.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
7005 3110 0002 1953 367J
Domestic Return Receipt
102595-o2-M-1540
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
1.1.1. WOODCREST ROAD, SUITE 200
CHERRY BILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.ROLE 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
3129.
This Affidavit is made subject to
relating to unsworn falsification
Dated: September 1, 2006
rth by Pa Rule C.P.
Section 4904
, P.C.
BY:
Mark J. Udren, Esquire
Attorney for Plaintiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane,
Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address
Cumberland County Adult
probation
1 Courthouse Square
Carlisle, PA 17013-3387
Jennifer Leisenring
4105 Lisburg Road
Mechanicsburg, PA 17055
Ryan M. Lutz
742A N. Chestnut Street
Palmyra, PA 17078
Aaron Sweigert
50 East Maple Street, Apt. #13
Palmyra, PA 17078
Jennifer Reulens
P.O. Box 2013
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC Bank NA
500 West Jefferson Street
Louisville, KY 40202
c/o Frank Federman, Esquire
2 Penn Center Plaza, Suite 900
Philadelphia, PA 19102
Harvey Hoffman
40 W. Green Street
Mechanicsburg, PA 17055
6305 Locust Lane
Mechanicsburg, PA 17055
5006 Seneca Drive
Mechanicsburg, PA 17050
1200 Yverdon Drive
Camp Hill, PA 17011
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
Internal Revenue Service
Technical Support Group
William Green Federal Building
600 Arch Street, Room 3259
Philadelphia, PA 17108
USA, US Attorney
US Department of Justice
Federal Building
228 Walnut Street, P.O. Box 11754
Harrisburg, PA 17108
US Attorney General
US Department of Justice
Main Justice Building, Room 5111
10~ & Constitution Avenue NW
Washington, DC 20531
Real Estate Tax Dept.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, po Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
I verify that the statements made in this affidavit
correct to the best of my personal knowled
I understand that false statements her in a
penalties of 18 Pa.C.S. sec. 4904 rela i t
authorities.
un
are true and
ormation and belief.
subject to e
rn falsif' ation to
DATED: September 1, 2006
Ma J. Udren, Esquire
Attorney for Plaintiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY RILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 03-3941 Civil Term
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
DATE: May 30, 2006
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Diane Defrank,a/k/a Diane D. Defrank
MORTGAGOR(S): Jeffrey Defrank
PROPERTY: 1420 Wellgate Lane, Mechanicsburg, PA 17055
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland
County Sheriff I s Sale on September 6, 2006, at 10: 00 AM, at the
Commissioners Hearing Room, 2nd Fl., 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.
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IlAlUUSBURG. PA 17108
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r- r- ~::. WILLIAM GREEN FEDERAL BUILDING ..........
.....n.... 600 ARCH STREET, ROOM 3259 ..........
CIIy. SlIfe, pHILADELPHIA, PA 19106
EXHIBIT A
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EXHIBIT A
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted DeliveFy is desired.
. Print your name and add11lss on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
US ATIORNEY GENERAL
US DEPARTMENT OF JUSTICE
MAIN JUSTICE BUll..DING, ROOM 5111
10TH & CONSTITUTION A VENUE NW
WASHINGTON, DC 20531
. .
. . .
~ Sign~{J~
o Agent
o Addressee
B. ReceivAUG( PO~ 'tUU)O T C. Date of Delivery
. D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
f.io-
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3iEType
CertIfled Mail 0 Express Mail
o Istered ~ ;;um Receipt for Merchandise
o Insured Mail Ci'bQ.D.
4. Restricted Delivery? (Extr8 Fee) 0 Yes
2. Article Number
(transfer from service label)
. PS Form 3811 , February 2004
7005 3110 0002 1953 3758
102595-02.M-1540
Domestic Return Receipt
.. .
· ~ompJete items 1, 2, and 3. Also complete
Item 4/f Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
USA, US ATIORNEY
US DEPARTMENT OF JUSTICE
FEDERAL BUll..DING
228 WALNUT STREET-P.O. BOX 11754
HARRISBURG, PA 17108
2. Article Number
(Transfer from service label)
"'PS Form 3811, February 2004
o Ii" t 'f - "'0 0 rr "!(,N ON fJEllVr flY
_0 Agent
o Addressee
C.Qa1DttIlVery
D. Is delivery address dlffer8ntfrom Item 1? 0 Yes
If YES, enter delivery address below: 0 No
Service Type
Mall 0 Express Mall
o Registered ~~m Receipt for Merchandise
o Insured Mail Otb.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
7005 3110 0002 1953 3772
Domestic Retum Receipt
102595-o2-M-1540
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article Addressed to:
INTERNAL REVENUE SERVICE
TECHNICAL SUPPORT GROUP
WILLIAM GREEN FEDERAL BUILDING
600 A.I.IeII STREET, ROOM 3259
PBILt\MLPHIA, PA 19106
2. Artlel
(Tran.
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~lceType
eel Mali~ Express Mall
o ~etum Receipt for Marchandis
o Insured Mall 0 C.O.D.
4. Restricted Delivery? .(J;xtra Fef3) 0 Yes
EXHIBIT A
12595-o2-M-15<
Option One Mortgage Corporation
VS
Diane DeFrank and Jeffrey Defrank
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3941 Civil Term
Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states
that on July 3,2006 at 10:45 o'clock AM, he served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Diane DeFrank and Jeffrey Defrank, by making known to Jeffrey
DeFrank, personally and husband of Diane DeFrank., at 1420 Wellgate Lane,
Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time
handing to him personally the said true and correct copy of the same.
Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states
that on July 3,2006 at 10:45 o'clock A.M., he posted a true copy of the within Real state
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Diane DeFrank and Jeffrey DeFrank located at 1420 Wellgate Lane, Mechanicsburg,
Pennsylvania 17055 according -to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Diane DeFrank and Jeffrey DeFrank, by regular mail to their last
known address of 1420 Wellgate Lane, Mechanicsburg, Pennsylvania 17055. This letter
was mailed under the date of July 14, 2006 and never returned to the Sheriffs Office.
;~:..~~
. ~
R. Thomas Kline, Sheriff
BY ik~mJjj,
Real Estate ergeant
EXHIBIT B
_.. . _.. --
r
UDRBN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Plaintiff
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
NO. 03-3941 Civil Term
Defendant(s)
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire, hereby certify that I have served
true and correct copies of the Notice of Sale upon the following
person (s) named herein at their last known address or their
attorney of record.
Regular First Class Mail
Certified Mail
Other (certificate of mailing)
Date Served: August 4, 1006
xxxxxx
xxxxxx
TO: USA, US Attorney
US Department of Justice
Federal Building
228 Walnut Street-P.O. Box 11754
Harribsurg, PA 17108
EXHIBIT B
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~... US DEPARTMENT OF JUSTICE ................
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EXH\B\\ a
. Complete items 1, 2, and 3. Also complete
item 4 If Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front If space permits.
1. ArtIcle Addressed to:
..
USA, US ATIORNEY
US DEPARTMENf OF JUSTICE
FEDERAL Bun.DING
228 WALNUT STREET. P.O. BOX 11754
HARRISBURG, PA 17108
o Agent
o Addressee
i, I ~ ( .,C.. Oate of Oe!lvery
D. Is deliveIY adcIIess different from item 1? 0 Yes
If YES. enter delivery address below: 0 No
1iice Type
rtlfled Ma 0 Express Mail
o isterecI ~:X~ Receipt for Merchandise
o Insured Mail ~
4. Restricted De1iveIY? (Extra Fee) 0 Yes
7005 3110 0002 1953 3789
2. Article Number
(TIansfer from service label)
PS Form 3811 . February 2004
l
Domestic Retum Receipt
102595-02-M-1540
EXHIB'T B
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Option One Mortgage
Corporation
ATTORNEY FOR PLAINTIFF
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
NO. 03-3941 Civil Term
Defendant(s)
CERTIFICATE OF SERVICE
I, Mark J. Udren, Esquire, hereby certify that I have served
true and correct copies of the Notice of Sale upon the following
person (s) named herein at their last known address or their
attorney of record.
Regular First Class Mail
Certified Mail
Other (certificate of mailing)
Date Served: August I, 2006
TO: Jeffrey DeFrank, MOrtgagor
Diane DeFrank aka Diane D. DeFrank
c/o Robert D. Kodak, Esquire
407 Front Street
P.O. Box 11848
Harrisburg, PA 17108
xxxxxx
xxxxxx
ES, P.C.
By:
Mark J Udren
Attorney for
Esquire
laintiff
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
Jeffrey DeFrank, Mortgagor
Diane DePrank a/k/a
Diane D. DePrank
c/o Robert D. Kodak, Esquire
407 Pront Street, P.O. Box 11848
Harrisburg, PA 17108
2. AftIcle Number
ntansrer from service I8beI)
PS E1mn 3811, February 2004
o Agent
o Addressee
B. Received by (Printed Namel.r;, ~. ,~.IIVery
D. Is delivery address different from item 1? 0 Yes
If YES. enter delivery address below: 0 No
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o1\8gistered 'lS..Betum Receipt for Merchandise
o Insured Mall 0 C':b.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
7005 3110 0002 1953 3b?J
102595-02-M-1540
Domestic Return Receipt
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Option One Mtg Loan Trust 2002-2 Trustee is the grantee the same having
been sold to said grantee on the 26th day of December A.D., 2006, under and by virtue of a writ
Execution issued on the 31st day of Mav, A.D., 2006, out of the Court of Common Pleas of said County
as of Civil Term, 2003 Number 3941, at the suit of Ootion One Mtg Corp against Diane aka Diane D &
Jeffrey DeFrank is duly recorded in Deed Book No. 278, Page 528.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this c:2 G
day of
f).J2.C.
,A.D~~'
~~-..c...., CIIMl '"
My CcnIiialon EJpINe lie FIrIt MondaY 01 JIn. 2010
Recorder of Deeds
Option One Mortgage Corporation
VS
Diane DeFrank and Jeffrey Defrank
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3941 Civil Term
Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states
that on July 3,2006 at 10:45 o'clock AM, he served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Diane DeFrank and Jeffrey Defrank, by making known to Jeffrey
DeFrank, personally and husband of Diane DeFrank, at 1420 Wellgate Lane,
Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time
handing to him personally the said true and correct copy of the same.
Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states
that on July 3,2006 at 10:45 o'clock A.M., he posted a true copy ofthe within Real state
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Diane DeFrank and Jeffrey DeFrank located at 1420 Wellgate Lane, Mechanicsburg,
Pennsylvania 17055 according -to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency ofthe action to the within named
defendant, to wit: Diane DeFrank and Jeffrey DeFrank, by regular mail to their last
known address of 1420 Wellgate Lane, Mechanicsburg, Pennsylvania 17055. This letter
was mailed under the date of July 14,2006 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on September 6, 2006 at 10:00 o'clock AM. He sold the same for
the sum of$1.00 to Mark Ddren on behalf of Wells Fargo Bank, N.A, as trustee for
Option One Mortgage Loan Trust 2002-2 Asset-Backed Certificates Series 2002-2. It
being the highest bid and best price received for the same, Wells Fargo Bank, N.A, as
trustee for Option One Mortgage Loan Trust 2002-2 Asset-Backed Certificates, Series
2002-2 of6501 Irvine Center Drive, Irvine, CA, 92618 being the buyer in this execution,
paid to SheriffR. Thomas Kline the sum of$987.57.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
$30.00
19.36
15.00
15.00
30.00
10.00
Prothonotary
Mileage
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
So Answers:
1.00
13.20
15.00
30.00
407.00
318.20
19.31
25.00
39.50
$ 987.57
..:s3l1'",,,,..r"."')./. . /'-;::/
or ~~~< ~,P~ .~~ .
R. Thomas KlIne, Shenn --.-="<--? ~. ~
BY.JC~
Real Estat ergeant
,0"
./ I.I(P~
6eeA
(l.JI-
0000 .-11)'0
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~
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Option One Mortgage Corporation, 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: 1420 Wellgate Lane,
Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
Diane DeFrank a/k/a
Diane D. DeFrank
1420 Wellgate Lane
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
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 tecorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC Bank NA
500 West Jefferson Street
Louisville, KY 40202
c/o Frank Federman, Esquire
2 Penn Center Plaza, Suite 900
Philadelphia, PA 19102
Harvey Hoffman
Address to Follow
5. Name and address of every other person who has any record lien on
the property:
Name Address
None
6. Name and address of every other person who has any record interest
in the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants
1420 Wellgate Lane
Mechanicsburg, PA 17055
Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
I verify that the statements made in this affidavit are tru and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject 0 the
penalties of 18 Pa.C.S. sec. 4904 relating to unsworn fals'fication to
authorities.
DATED: May 30, 2006
Mark J. Udren, ESQ.
Attorney for Plaintiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant(s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Diane DeFrank a/k/a
Diane D. DeFrank
c/o Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Fl., Courthouse,
Carlisle, PA , to enforce the court judgment of $369,577.47, obtained
by Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the
buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your
house. A schedule of distribution of the money bid for your house will be filed by
the Sheriff within 30 days after the sale. This schedule will state who will be
receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
~
. ~
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Option One Mortgage
Corporation
PO Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Diane DeFrank a/k/a
Diane D. DeFrank
Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Defendant{s)
NO. 03-3941 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Jeffrey DeFrank, Mortgagor
1420 Wellgate Lane
Mechanicsburg, PA 17055
Your house (real estate) at 1420 Wellgate Lane, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at
10:00 AM in the Commissioners Hearing Room, 2nd Fl., Courthouse,
Carlisle, PA , to enforce the court judgment of $369,577.47, obtained
by Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must
pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You may
also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,
the more chance you will have of stopping the sale. (See notice on page two on
how to obtain an attorney.)
~
. ~
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid
price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full
amount due in the sale. To find out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will
remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the
buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your
house. A schedule of distribution of the money bid for your house will be filed by
the Sheriff within 30 days after the sale. This schedule will state who will be
receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ALL TE.;:'.T CERTAIN TRACT OF LAlID SITUATE IN LOWER .:;LLEN TOWNSEIP, CDMBERLAND
COUNT!, PENNS7L-~-ANIJl., AlID DESCl".IBED .;'CCORDING TO A FINAL SUED.!. VISION PLAN PREPARED
3Y :crARTMAN A:ND ASSOC::"~.TES, ?..EGISTERED PROFESSIONAL ENGINEERS, c..U1P !UI.L,
?ENNSYL'vAN!:A, DATED NOVEMBER 1, 1995, A..."ID LAST REV'ISED FEBRUAP.Y 15, :'.996, .AND
?..ECORDED IN PLAN BOOK 72, PAGE 125, AS FOLLOWS, TO WIT:
BEGINNING .;'T A POINT ON TEE SOUTHEAST SIDE OF WELLGATE LANE AND A CORNER OF
LOT NO. 5 ON SAID PLAN; TEENCE EXTENDING ALONG SAID LOT SOOTB 16 DEGREES 00 MINUTES
00 SECONDS EAST, A DISTANCE OF 60.66 FEET TO A POINT AT A CORNER OF LANDS NOW OR
LATE OF JOHN' E. RUPPERT, SR.; TEENCE EX:':'ENDING ALONG SAID !.AND SOUTH 15 DEGREES 15
MINUTES 00 SECONDS WEST, A DISTANCE OF 183.72 FEET TO A POINT AT A CORNER OF LANDS
NOW OR LATE OF ELMER ::;. KLINE; THENC:!!: EXTENDING ALONG SAID LANDS AND CONTINUING
NORTH 74 DEGREES 36 MINUTES 00 SECONDS WEST, A DISTANCE OF 62.11 FEET TO A POINT;
THENCE CONTINUING NORTH 67 DEGREES 45 MINUTES 00 SECONDS WEST, A DISTANC:!!: OF 175.00
FEET TO A POINT AT A CORNER OF LOT NO. 30N SA.-n PLAN; THENCE EXTENDING ALONG SAID
LOT NO. 14 DEGREES 45 MINUTES 19 SECONDS EAST, A DISTANCE OF 143.63 FEET TO A POINT
ON THE SOUTHWEST SIDE OF WELL GATE LANE; THENCE EXTENDING ALONG SAID LANE ALONG A
C'JRVE TO TEE LEFT HAVING .r... RADIUS OF 330.00 FEET, TEE .;.RC DISTANCE OF 177.1.4 FEET
TO THE POINT AJ:m PLACE OF BEGI:NNING.
3EING LOT NO.4.
CONTAINING 43,389.77 SQUARE FEET.
SUBJEC'::' TO EASEMENTS, CONDITIONS AND RESTRICTIONS OF RECORD.
BEING KNOWN AS:
1420 WELLGATE LANE
MECHANICSBURG, PA 17055
PROPERTY ID NO. :
13-11-0270-051
TITLE TO SAID PREMISES IS VESTED IN DIANE D. DEFRANK, A MARRIED WOMAN BY
DEED FROM JEFFREY A. DEFRANK AND DIANE D. DEFRANK, HUSBAND AND WIFE DATED
2/8/02 RECORDED 2/22/02 IN DEED BOOK 250 PAGE 2355.
WRIT OF EXECUTION ~rrd/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-3941 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION,
Plaintiff (s)
From DIANE DEFRANK AIKIA DIANE D. DEFRANK, JEFFREY DEFRANK, MORTGAGOR
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $369,577.47 L.L.
Interest FROM 2/5/04 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $77.86 TO ACTUAL
DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $73,499.84
Atty's Conun % Due Prothy $1.00
Atty Paid $875.75 Other Costs
Plaintiff Paid
Date: MAY 31,2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCRESTCORPORATECENTER
111 WOODCREST ROAD, SUITE 200
CHERRY fiLL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ill No. 04302
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Real Estate Sale # 77
On June 06, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 1420 Wellgate Ln.,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 06, 2006
By:
J6til AI\~
Real ~~~ Sergeant
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
July 21, July 28, and August 4,2006
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.
SWORN TO AND SUBSCRIBED before me this
4 day of August. 2006
NOTARIA SEAL
LOIS E. SNYDER, Notary Public
j Car!i';le Boro, Cumberland County I
f Cnrrrr!!SSion t=:'(Pfrpt~ r\:';nrGh 5, 200:1.,
~,,,,''''''n...'',,~~1I7'"'~_''''"''''''''''''-'-''''''''''''' ...,_.....-.w=-,'~__..,.."..". ~.:"o.....,
REAL ESTATE SALE NO. 77
Writ No. 2003-3941 Civil
Option One Mortgage Corporation
vs.
Diane DeFrank a/k/a Diane D.
DeFrank and Jeffrey DeFrank
Atty.: Mark J. Udren
ALL THAT CERTAIN tract of land
situate in Lower Allen Township,
Cumberland County, Pennsylvania,
and described according to a Final
Subdivision Plan prepared by
Hartman and Associates, Registered
Professional Engineers, Camp Hill,
Pennsylvania, dated November I,
1995, and last revised February 6,
1996, and recorded in Plan Book
72, Page 125, as follows, to wit:
BEGINNING at a point on the
southeast side of Wellgate Lane and
a comer of Lot No. 5 on said plan;
thence extending along said lot
South 16 degrees 00 minutes 00
seconds East, a distance of 60.66
feet to a point at a comer of lands
now or late of John H. Ruppert, Sr.;
thence extending along said land
South 15 degrees 15 minutes 00
seconds West, a distance of 183.72
feet to a point at a comer of lands
now or late of Elmer J. Kline; thence
extending along said lands and con-
tinuing North 74 degrees 36 min-
utes 00 seconds West, a distance
of 62.11 feet to a point; thence con-
tinuing North 67 degrees 45 min-
utes 00 seconds West, a distance
of 175.00 feet to a point at a comer
of Lot No. 3 on said plan; thence
extending along said Lot No. 14 de-
grees 45 minutes 19 seconds East,
a distance of 143.63 feet to a point
on the southwest side of Wellgate
Lane; thence extending along said
lane along a curve to the left having
a radius of 330.00 feet, the arc dis-
tance of 177.14 feet to the point
and place of beginning.
Being Lot No.4.
CONTAINING 43,389.77 square
feet.
Subject to easements, conditions
and restrictions of record.
BEING KNOWN AS: 1420 Well-
gate Lane, Mechanicsburg, PA
17055.
PROPERlY ID NO.: 13-11-0270-
051.
TITLE TO SAID PREMISES IS
VESTED IN Diane D. DeFrank, a
married woman by deed from Jef-
frey A. DeFrank and Diane D.
DeFrank, husband and wife dated
2/8/02 recorded 2/22/02 in Deed
Book 250 Page 2355.
Ill" ~
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the
2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is du1y authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
S ALE #77
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
}'.