The URL can be used to link to this page

Home My WebLink About03-6129 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 ( Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County v, James E. Tschudy Kim D. Tschudy, Last Record Owner : NO, O:S - !r 1;)'1 Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) riJ 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 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion, Hace falta ascentar una comparencia escrita 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 DINERO 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached document, Unless you notify us within 30 days after receipt ofthis Notice and the attached document that the validity ofthe 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: Wilmington National Finance, Inc, Assignments of Record to: Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Recording Date: 4/22/02 Book: 686 Page: 2902 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: 138 South Locust Street a/k/a 138 Locust Street MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 2/1/02 DATE RECORDED: 2/8/02 BOOK: 1748 PAGE: 4182 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 11/11/03 : Principal of debt due Unpaid Interest at 9,4%* from 12/1/02 to 11/11/03 (the per diem interest accruing on this debt is $25.38 and that sum should be added each day after 11/11/03) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $41.21 should be added in accordance with the terms of the note each month after 11/11/03) Deferred Late Charges Other Fees Due Prior Bankruptcy Fees and Costs Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $98,538.15 8,734.48 250.00 280.00 330,08 315,49 24.77 790.00 4,926.91 $114,189.88 * 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 $114,189.88 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. ~'SQU'RE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No, 04302 ALL THAT CERTAIN piece or p~~cel of' 1a~d situate with the building and improvemen~s thereon erected being known as Lot' No, 90 on Plan ot Lots laid out tor. Allen Park Development corp" called Cumberland Park, as recorded in Plan Book 4, Page 86, Cumberland Co. Records, on the southwesterly side ot Locust street, Cumberland Park, Lower Allen Township, Cumberland County, P.ennsylvania. bounded and desoribed as fOllows to wi~: ,( BEGIN/lING at a point on the Southwesterly si,de of Locust Street GO feet wide, said point being at a distance of 275 feet measure.d North 40 degrees JJ minutes we~t from the intersecti.on of the said side of Locust.street with the Northwesterly side of Locus~ Street GO teet wide, both lines prOduced; thence extending along Lot No. 89 South 49 degree" <? minutes West a distance of 127.50 feet to a point; thence extending alcng t~t Nos. 94 and 95 North 51 degrees 21 minutes 30 seconds West a distance of 130,94 feet to a point; thence extending along property now or late of Robert stoner, '/lorth 71 degrees 57 minutes 30 seconds ~ast, a distance of 164.59 feet to a point in tne southwesterly :;ide of Locust street; thence extel1cling along th" said ..ide of Locust Street South 40 degrees 33 minutes East a distance of 65,61 feet to the place of BEGINNING, I HAVING THEREON erected a single dwelling known and numberecl as 138 Locust Street. . September 23, 2003 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi~ is an oftil'ial notice that the morteau on YOllr home is in defalllt, and the lender int..nds to foreclose. Spel'ific information ahollt the nah.re of the defalllt i. provided in the attached I'~" The HOMF:OWNF:R'S MORTr.Ar.F: ASSTSTANCF: PROr.RAM (HF:MAP) mS\)' he ahle to help to save YOllr home. This Noti"e e1(l'lains how the I'rllV"am work.. To .ee ifHRMAP "an help, YOII mnd MF,RT WITH A CONSTTMRR CRRnTT CorJNSF,UNr. AGF:NCV WITHTN 10 nA VS OF THlC nA TF: OF THTS NOTTCR. Take this Noti"e with yon when YOII meet with the COlln.eliqe .<\eI:n"y. The name. addre.s and phone nllmh..r of Con.llmer Credit COlln.eliqe A",ncies ...rvine YOllr Connty are Iided at the end of this Noti"e. If YOII have al\)' qlle.tion., YOII m'l,.V "all the Penn~lvanja HOlldne Finance A~ncy toll free at 1-&00-142-2'197. (persons with impaired heariqe can "all (717) 7&0-1&(9). . This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINVAR VlVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA, PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU IDPOTECA. EXHIBIT A Pagelof6 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: Jame$ E. nchudy 138 S. Locu$t Street Camp HilL P A.. 0006076160 Wilmington National Finance, Inc. Hou$ehold Mortgage Funding Corporation. nn LOAN ACCT. NO,: ORIGINAL LENDER: CURRENT LENDER: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOTJ MAY RF: F,UGIRI,F, FOR FINANCIAl, ASSISTANCF, WHICH CA N SA YF, YOTJR HOMR FROM FORF.CT ,OSTJRF. AND HF.I,P YOTJ M A KF: FITTTJRF. MORTGAGF. P A YMF.NTS 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: o IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, o IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY, TF.MPORARY STAY OF FORF.CT,OSTJRF. - 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 consumer credit counseling agencies listed at the end ofthis Notice, Tms MRF.TING MTJST OCCTJR WTTmN THF. NFXT (~O) DAYS. IF vOlr DO NOT APPLV FOR FMERGFNCV MORTGAGF. ASSTSTANCE VOTT MTTST RRiNG VOTTR MORTGAGF. TTP TO DATE THF. PART OF THIS NOTTCR rALLRD "HOW TO rTJRE VOlJR MORTGAGE DEFATTLT", EXPLAiNS HOW TO BRiNG VOlJR MORTGAGF. TTP TO DATE CONSITMF.R CRF.DTT COIJNSF.UNG AGF.NCTF.S - 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 n~mes, ~cir1ms.'e.' ~nci t.,jephone nllmheTS of r1e.,ien~ter1 con'"mer credit cOllnseling ~Ef'ncie., for the cOllnty in which the property is locMeci are s"t forth ~t th" end of this Notic", It is only necessary to schedule one face-to-face meeting. Advise your lender imm"cii~t.,jy of your intentions, APPI,ICATTON FOR MORTGAGF. ASSISTANCF. - Vour 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. Vour application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting, Page 2 of6 YOU MlJST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TillS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGF.NC.V AC.TTON - Available funds for emergency mortgage assistance are vel)' 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. 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 CIJRF, YOIJR MORTGAGF, DRFAlJI,T (Bring it np to rlatp,). NATTJRF. OF THF. OF.FATJLT - The MORTGAGE debt held by the above lender on your property located at: 138 S. Locust Street Camp Hill, P A., IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of$825.23 Cor January 1. 2003 through September 1.2003 = $7427,07 _.M9Jltbly Late Charges of$41.26 Cor January 1, 2003 through September 1. 2003 = $371.34 Other charges (explain/itemize): Accumulated Late Charges = $315.49 Corporate Advance = $150.00 BPO Fee = $15.00 Expense Advance = $625.00 _'IQ'IAL AMOUNT PAST DUE: $1I~l.90 B, YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not lI<e ifnot applicahle): NLA HOW TO ClJRF. THF. OF.FATJJ,T -- 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 '1;1190:1 90 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Paym~nts must he m;::lrle either hy cH-:h (,;l"hier's che~kJ cf';rtifien check or money nrd~T mHnf'; payahle ::Inti ",p,ntto' Mark.T. TJrlren IV A..odate< 1040 N. Kinf',' HieJIwll.)'. Snite :;00 rherry Hill. N.T 0110:14 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not "'" ifnot "ppJicahle): NLA Page 3 0(6 IF YOU DO NOT CURR THF. DF,F Am,T -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lenrl..r intenrl. to e"erdoe it. rieJlt. to a..celerate the morteav rleht. 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 (or....lo.e upon YOllr mortel\ferl property. IF THF. MORTGAGE IS FORF.CJ.OI'EO 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 begins legal proceedings against you, you will sti1l 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 YOII cllr.. the rle(alllt withill the THIRTY (,10) DAY period, YOII will 1I0t he re'luirerl to pay attorney'. (ee.o. OTHF.R T,F,NOF.R RF,Mf.OTF.S - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, If your debt has been discharged in bankruptcy without your having reaffinned it, then lender cannot pursue this remedy, RIGHT TO CTJRF. THE DF.F AlTT ,T PRIOR TO SHF.RlFF'S SAI,F. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon .till have the right to cllre the defalllt ann prevent the .ale at any time np to one hOllr hefore the Sheriff'. Sale You may no .0 hy payine; the total amonnt then past ellie, plm any late or other cha1'fl" then elne, rea.onahle attorney'. fee. ann co.t. conneeteel with the foreclosure .ale and any other co.t. connecteel with the Sheriff'. Sale a. .pecifren in writine; hy the leneler anel hy performine; any other re'lnirement. IInder the mortV'ee, 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. F.ARUF.ST POSSTRI,E SHERIFF'S SAJ.F. DATF. - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 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 fmd out at any time exactly what the required payment or action will be by contacting the lender, HOW TO CONTACT THF. J.F.NOF.R: Name of Lender/Servicer: Address: Household Mortgage Services 636 Grand Regency Blvd Brandon. FL.. 33510 800-333-7023 N/A Customer Service Phone Number: Fax Number: Contact Person: F.FFF.CT OF SHF.RIFF'S SAT,F. -- 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. ASSIfMPTlON OF MORTGAGF. -- You May Not 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, Page4of6 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 Is! Mark J, Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 Page 5 0(6 VOUMAV AT.SOHAVF.THF. RTGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTmITION TO PAY OFF TillS DEBT, . TO HAVE TillS 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 CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TillS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR,) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTmITED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER, . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSTTMF.R CRF.nTT COTTNSF.T.TNr. AGF.NCTF.S SF.RVTNG YOlm COTTNTV CTfMRF.RLAND C.OITNTV CCCS of Western Pennsylvania. Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 541-1757 FAX (717) 541-4670 Financial Counseling Services ofFrank1in 31 West 3rd Street Wayoesboro. P A 17268 (717) 762-3285 FAXn/a Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, P A 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of6 ~ I " t ; , ! Jc ~- i 11.1 < j '5 CC ~ d ~ Ii -jz ~ ~ ~ '" i i ~ ~! _ i-ll 1; :e- I "'~ ~c6 .!J~ a:: ~ = as Q ~ i 1 is. ;0 a. ei! e ii~ 8'lil~ >-.. gi!lCS=i <.!!!o~'l!o= .,; ~ 1l'" C "'0(1) @lil<D 5n=~ 8' ciC)! E-S cd .,:Iaistir ~~~sii~ :t::~cl$oe ..a:~"'''- ~=5~~lD -g....>-1il.::= =EcSl;lC Q 'C '" 0 o::gc.. ice ~ .. . . ~~ co --,------ - ~ 0- -1 ~ s i i! " :; s ~I I ~~! '.-1 !a:o I; IUl 00[J ill. r-'I ~ tr i 'a~ 0 !Inl~ ti iC[J[J a: iE: ~ <':i . 0 E ~ ~c a: I~ J ru o o I"- ~ ~~ ....... K ~ ~ r~j~~ J~ "t J .c~~ ! ~ . Ii ~ ~" ~~& '" oj ~ , , .' ;II' 01 plnl.ppl ' . I.".' 18011\111 1" -.s 'lHY.lHOdl'll ! l u 10" 81ldl-' ,,.od8l!1Il181'> ,.,l\l8IIIiiOdlU - :. W8W88JOPUe """ .-",ppu "-'IIIPP'8 U8 JO:l. , 'Jl8-l.nbeJ ~ 8l8OIJdnp I ~"'OJlUll'"", ,""'sd)f~ qqo 01 '__..8p ,"'tIOlIIPP8U1JJ~. i'ntd '88t<l81118A .:;.NWnSNI ON - q IJIVI P81ll1DO - u IIIW P8!lIll80. ... 'P,WOlllUf1IIO(BIJf ~ II8pjOfl'OO"'Y _ __ enbiuny _ 'l....llonl8W V _ "ew P8UI\.I8:J i , t ; ~ ~ f i. i .~ ~ I' l '1'. il 11 J 1 :.~ "'H .......... -- ...._-~ (pe<~-".","- ... ~UlnlOll H::I PfURoI80 ~ ~ ~ ~ ,... _:0 :c ~~ m .0, ::0 zel"" ~'^: 01:0 co o c 00 IJ1IJ1 'I' j .~ . ~i ~. ",i) 4 ~ :;;- " ~ ~ - ~ ~ . j ""! , ~ ;'" .. ~~'i ~ .;e." .~;~ , 'i.'," ----......~-"",~ V E R I FIe A T 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 subj ect to the penal ties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorities. Mark J. MARK J. ~~ " 0' " :--.. ~ ~ 'V V ~ \.\' C, \j '\ \, ~ " ( . :. ~ " , ., {:; SHERIFF'S RETURN - REGULAR CASE NO: 2003-06129 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS TSCHUDY JAMES E ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TSCHUDY JOSH KNOWN HEIR OF KIM D TSCHUDY LAST RECORD OWNER the DEFENDANT , at 1909:00 HOURS, on the 5th day of December, 2003 at 138 SOUTH LOCUST STREET CAMP HILL, PA 17011 by handing to JAMES E TSCHUDY, FATHER 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""~~~~~ R, Thomas Kline 12/09/2003 MARK UDREN me this day of Bv0 ~~~ 1)( Deputy Sheriff Sworn and Subscribed to before '- _1r~'3 qvU A.D, ~(l SHERIFF'S RETURN - REGULAR CASE NO: 2003-06129 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS TSCHUDY JAMES E ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TSCHUDY JAMES E was served upon the at 1909:00 HOURS, on the 5th day of December, 2003 DEFENDANT at 138 SOUTH LOCUST STREET CAMP HILL, PA 17011 JAMES E TSCHUDY by handing to 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 18,00 8,97 .00 10,00 ,00 36,97 Sworn and Subscribed to before me this (~J;( day of c-A~ dthJ3 A,D, 8v-~~ (~(J So Answers: r'~A~~ R. Thomas Kline 12/09/2003 MARK UDREN BY:~ o-b-vJ- t3:,~frHA , ~ \ ,C Deputy Sherlff SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-06129 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS TSCHUDY JAMES E ET AL R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TSCHUDY MELISSA KNOWN HEIR OF KIM TSCHUDY LAST RECORD OWNER but was unable to locate Her in his bailiwick, He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , TSCHUDY MELISSA KNOWN HEIR OF KIM TSCHUDY LAST RECORD OWNER 138 SOUTH LOCUST STREET CAMP HILL, PA 17011 DEFENDANT LIVES IN NEWPORT, Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 6,00 ,00 5,00 10.00 ,00 21,00 R, Thomas Kline Sheriff of Cumberland County MARK UDREN 12/09/2003 Sworn and subscribed to before me this I~R day Of'~~ " J..(J~3 A1.I, j~hofota~ 2Ji(J SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-06129 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS TSCHUDY JAMES E ET AL R, Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: TSCHUDY MELISSA KNOWN HEIR OF KIM TSCHUDY LAST RECORD OWNER but was unable to locate Her in his bailiwick, He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On December 9th, 2003 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County So answers: 6,00 9,00 10.00 37,28 .00 62.28 12/09/2003 MARK UDREN R, Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ~ day of\k~ :)0:_) . ,--~ In The Court of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systems VS, James E. Tschudy et al SERVE: Melissa Tschudy. known heir of Kim D. Tschudy. last record owner No. 03-6129 civil Now, November 24, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Pen:v County to execute tHis Writ, this deputation being made at the request and risk of the Plaintiff. ~("/ ~-~' r ~""""-...< ",f'-.~-4" Sheriff of Cumberland County, PA Affidavit of Service Now, December 8 , 20~, at 11: 08 o'clock A M. served the within Complaint in Mortgage Forclosure upon Melissa Tschudy, aka Melissa White at 450 Buckwalter Rd. Newport, Pa 17074 by handing to Chris White, Defendants husband a True & Attested copy of the original Comp Mtg Fore. and made known to Him the contents thereof. So answers, James T. Bennett 0"~ ~ Deputy Sheri10f Perry County, PA Sworn and subscribed before me this h day of ./Jeu.,vJ.Jt1;20~ -777dif'{[(~f 1'-{aG~ . 1- NOTARIAL SEAL . -l MARGARET F. FLICKINGER, NOTARY PUBLIC BLOOMFIELD BORO., PERRY COUNT\' MYCOMMISSION EXPIRES FEB. 16. 2004 . COSTS SERVICE MILEAGE AFFIDAVIT $ $ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration: COURT OF COMMON PLEAS ATTORNEY FOR PLAINTIFF Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff : CIVIL DIVISION : Cumberland County : NO. 03-6129 civil v. James E. Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) . MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Complaint In Mortgage Foreclosure by publication in accordance with Pennsylvania Rule of Civil Procedure (Pa.R.C,P,) 430(b) (1); and service of all subsequent pleadings, including, inter alia, the Notice of Sheriff's sale, that requires personal service upon Defendants, Kim D. Tschudy, Last Record Owner, and Unknown Heirs of Kim D. Tschudy, Last Record Owner by posting only, of the subject premises located at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011 in accordance with Pa.R.C.P, 430; ,:md in support thereof avers the following: 1. Plaintiff filed a Complaint in Mortgage Foreclosure against the above captioned Defendant(s), 2. The Defendant, Kim D. Tschudy is deceased, A true and correct copy of Proof of Death is attached hereto and marked Exhibit "A". 3. The Plaintiff inquired with Register of wills Office and was advised record of an Estate having been raised. 4. There are no "known" surviving heirs other than those which may have been previously identified and named as defendants. 5. There may be other "Unknown" surviving heirs, 6. Plaintiff has made a good faith effort to locate all known heirs so as to name them party Defendants pursuant to Pa.R.C.P. 1144(a) (2) by inquiring with the Cumberland County Register of wills Office and conducting a :3kip trace. 7. Although specific heirs may have been located, it is believed that there may be other "unknown heirs", who remain unidentified. WHEREFORE, so as to properly satisfy the Pennsylvania Rules of Court, particularly Pa,R,C.P, 1144(a) (2), (a) (3), where the Plaintiff is required to name as party Defendants in an action in mortgage foreclosure the heirs of a deceased mortgagor(s), if known, and those of a deceased real owner, t:he Plaintiff moves this Honorable Court, and hereby requests an Order, pursuant to Pa.R.C.P. 430 et seq., directing service of the Complaint In Mortgage Foreclosure by publication upon the Defendant, Kim D. Tschudy, Last Record Owner and the Unknown Heirs of Kim D, Tschudy, Last Record Owner; and service of any and all subsequent pleadings including, inter alia, the Notice of Sheriff's Sale, that require personal service by posting only, of the subject premises located at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011. the Cumberland County that the County has no MARK J, UDREN & ASSOCIATES ~I' Mark J, Udren, Esquire Attorney for Plaintiff MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration: COURT OF COMMON PLEAS ATTORNEY FOR PLAINTIFF Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff : CIVIL DIVISION : Cumberland County : NO. 03-6129 Civil v. James E, Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, having filed its Motion For Service Pursuant To Special Order of Court, submits this Memorandum of Law in support hereof, Pennsylvania Rule of Civil Procedure 430 (a) specifically provides, in part, that "(a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service." The purpose of the Motion is to seek special service of the Complaint In Mortgage Foreclosure on Kim D. Tschudy, Last Record Owner and the Unknown Heirs of Kim D. Tschudy, Last Record Owner, It is believed that there may be heirs of the deceased Defendant, yet they are unknown to the Plaintiff. Therefore, because the heirs are "unknown", and thus unidentifiable and unable to be located, service cannot be made under the applicable rule, Pennsylvania Rule of Civil Procedure 1144(a) (2) requires the Plaintiff to name as party Defendants in an action in mortgage foreclosure the heirs of a deceased mortgagor. Pa,R,C.P. 1144 (a) (3) is silent with regard to the heirs of a deceased real owner, As stated in the attached Motion, Defendant, Kim D. Tschudy is deceased. So as to properly satisfy Pa.R.C.P. 1144 (a) (2), (a) (3), a good faith effort to discover the whereabouts of any and all heirs has been made in accordance with Pa.R.C.P. 430(a), as evidenced by the good faith Affidavit of Investigation, attached hereto as Exhibit liB" . Known heirs may have been identified herein. However, so as to properly serve Kim D. Tschudy, Last Record Owner and any surviving heirs who are unknown to the Plaintiff, but who may have have an interest in the mortgaged premises, the Plaintiff seeks service by publication with regard to the Complaint in Mortgage Foreclosure, and posting only, of the mortgaged premises with regard to all subsequent pleadings that require personal service, including, inter alia, the Notice of Sheriff's Sale. Pa,R.C.P. 430(b) (1) provides for service by publication. Further, Pa,R.C.P. 430(b) (2) provides for service by publication on unknown heirs: When service is made by publication upon the heirs and assigns of a named former owner(s) or party in interest, the court may permit publication against the heirs or assigns generally if it is set forth in the complaint or an affidavit that they are unknown, In conformity with Pa.R.C.P. 430 (b) (2), the Plaintiff sets forth, as verified, in the within Motion, that there may be unknown heirs. In order to complete service on the Defendant, Kim D. Tschudy, Last Record Owner by and through her surviving "unknown heirs", so as to move this foreclosure action forward to ultimate disposition, the Plaintiff respectfully requests that this Honorable Court, pursuant to Pa. R. C. P. 430 et seq" and for all the reasons hereinbefore stated, and in the attached Motion, grant a Special Order directing service of the Complaint In Mortgage Foreclosure by publication on Defendant, Kim D. Tschudy, Last Record Owner and the Unknown Heirs of Kim D. Tschudy, Last Record Owner; and service of all subsequent pleadings including that require personal service, inter alia, the Notice of Sheriff's Sale, by posting only, of the subject premises located at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011. Respectfully submitted, MARK J. UDREN & ASSOCIATES /fI0/ Mark J. Udren, Esquire Attorney for Plaintiff This is to certify that this is a true and accurate copy of the death record on ~Ie with the Division of Vital Records, and that I, Charles Hardester, am and was at the time of the issuance of this copy Director, Division of Vital Records of the ?~partment ?f Health for the Commonwealth of Pennsylvania, duly appointed and commIssIOned as dIrected by Act 66 of the General Assembly, approved 29 June 1953, P,L. 304. DEC312003 ~},.. ~"""). Date Issued Director Hl05.143Rft.2!l7 COMMONWEALTH OF PENNSYLVANIA. DEPARTMENT OF HEALTH. VITAL RECORDS CERTIFICATE OF DEATH 003694 TYPElPflD4T ON PERMANENT ......... 44 v... ~/C;e,_ lboJ",F"...,c......." Hershey, FA 11ilQ"~"'fNU_ socw,.SECURlTYHUMlIER Female ,. 183 - 50 - 2004 "'-"CI06llERHlCt>KIo...........___...__ ""'"'" __0 !~O OREO#OUl'Il.Monlrlo..,._1 .. Januar 26 2002 NAlCOf'tlECt:DENT(F".~l_, ,. AGE(I...llirlhoay) UHOEfllYE.Ul - .... ~l """"'~""'" ~o Cumberland 138 South Locust Street AACI!."'_-.-.wr......... ....... OECEOEHT.S USUAL OCClWRlOtl ";-=:~~=;r Ita. Crossing Guard 11.. Township Police Ol!CeDEHT'SMAlUNOADOfIES8lS>-M.~,".ZIpCocloI 138 South Locust Street ,.Camp Hill, PA 17011 MntUl'SHAIoIEFnl.M_.La$Il John E. Gesford ,. ~SIWolE(T~ 11 (",hi loIAIIW.. SWlA.--., --- -- 14. Married ,. White ............... (1_._-- 17c.1i___.. Lower James E. Tschud Allen - ,~. Cumberland 17ill ~-:::'.:::'" MOntEIl'S_(l'"....,......._s..._1 1.. Anna Popp Gesford OFIMAHT'SUM.JHOAOORESS....~-.Z!pCadot 138 South Locust Street eam Hill PA 17011 PlACl!(I~.~..~c..m.rr.y LOCRIOfrI.~......ZlpCoW ._- ~ . ~ . ..,..,.~""""""" O .....00 ~O "--_51..0 ~ OIMrlSPdl" ... SlGNRUAE OF fU James E. Tschud ..0.-- Co. I V'n G A CkA..- ,- '-........ l-__ , I ""'"'" c:ww........COf>dllIoN-......g.._.1lIII 1ICIl.........._~_glvtn..~I. J '; ~ DUElOlOAASACON5EOlJENCE:OFl: [ : OUElOlOAASACONSEOUENCEClF): OUIE'IOfOAASACON5EOUENCEOl'): ,; ) _AUfOlI'SYFI~ IMNNEfIIOFOEArH "'-"_m ff' """'"""'~""" -.. "''''"'' - -- 0 --.. ..0' ~O ..0 - 0 ~""'..._- tMlEOFlf'olJUlW ~,o.r."""l TIIll6!Ol'flJIJAy 1NJUR'till''NOfIIl;'I Dl!SCAlBl!iHOWINJUATOCCUfIlIll!O. ... CDI'TW'WIICIIcIc"""...... .C&lT~PHVSll:lAN~~~auMd___,..""_...._IlI'_du"'ano_II...2Jl ,....._.....r~-"'__.....Cauaa(.l.nd_.....'_._.............................. a o o o PL.ACEOFIkJUAY.A1_.-,-.tKtOrAafb ... ~...-~ .... ..... 0 ,..,,0 l:?,~,.;l,^,'/I "-J,,,;!., . ~ ~ ~ ~ ~ '1'RONOIINCIttQAHOcutTll'Y_l'H1'$IClAH(~"""';>r~jJN"'_~1l>cao.a"'_...\ ,_" To..._......,_.........-..-.,...._...."'..n<lplOC...noI4U.......uNl.,..................._ .Yl!DICA1.DA.MIN.EIIJ~EA Onllle boIl1.ol.......I.....1on .1\dI....1......llg.llon. In rnyoplniOll, dlath fXc:u".d .tIMtl..... """, _ pl_, lnod d~. to 1I..".....(.I.nd Jl.~........dlO1..,.................................................................................................. AEGISl'flAR'SSlGN.o,ll.lAEAHDNUMBER ~. OATEFll.EDt_.O&y._1 1- ;(Y'O;L ~. EXHIBIT .A MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration: COURT OF COMMON PLEAS Systems, Inc" its successors : CIVIL DIVISION and assigns, as Nominee for : Cumberland County Household Finance Corporation, . its successors and assigns Plaintiff : NO. 03-6129 Civil v. James E, Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) AFFIDAVIT OF GOOD FAITH INVESTIGATION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and hereby sets forth that the undersigned conducted a good faith investigation of the existence of and whereabouts of any surviving heirs of the deceased Defendant mortgagor(s) and real owner(s) by inquiring with the Cumberland County Register of granting of the Administration. wills whether an Estate was raised by the Letters Testamentary and/or Letters of The Register advised the undersigned that no decedent's Estate was raised of record, and Letters were not granted. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S, ~ 4904 relating to unsworn falsification of authorities. Dated: I\aa\bl\ MARK 7;lflj/JY & ASSOCIATES Mark J. Udren, Esquire Attorney for Plaintiff EXHIBIT B VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. MARK J, UDREN & ASSOCIATES Date: \ \QC:J\ tlL\ /flY' Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration : COURT OF COMMON PLEAS ATTORNEY FOR PLAINTIFF Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff : CIVIL DIVISION : Cumberland County : NO. 03-6129 Civil v. James E. Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Defendant(s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of the Motion For Service Pursuant to Special Order of Court upon the following person(s) named herein at their last known address or their attorney of record by: x Regular First Class Mail Certified Mail Other Date Served: \\~O\\)\4 TO: Kim D. Tschudy, Last Record Owner Unknown Heirs of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 MARK J, UDREN & ASSOCIATES 01/ Mark J. Udren, Esquire Attorney for Plaintiff () , :! "'-, ..:::-;) (:;::.:> -""" <- ;...... :.c: o -n ~ rf":; ::TI r- :-5 t-9 ~3~> ~~?iS (~;'1 t'" N ~ --- - \? Ul W ~:J ........: JAN 2 3 20llL \t7 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration: COURT OF COMMON PLEAS ATTORNEY FOR PLAINTIFF Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff : CIVIL DIVISION : Cumberland County : NO, 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) . ~ 0 R D::!J:R AND NOW, this ~ Day of ~~ consideration of Plaintiff's Motion For Service ,200,\ ,upon Pursuant To Special Order Of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Complaint In Mortgage Foreclosure on Kim D, Tschudy, Last Record Owner, and upon any and all Unknown Heirs of Kim D. Tschudy, Last Record Owner shall be complete when Plaintiff or its counselor agent has published in accordance with Pa.R.C.P. 430(b) (1) a Notice of the action once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa,R.C,P, 430, service of all subsequent pleadings that require personal service, including, inter alia, the Notice of Sheriff's Sale, shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011, which is the subject matter of this action in mortgage foreclosure, ~ i\,D\ Or;t:D BY ~ld~~ >- ~~ f:f!;.> ". C- !JP.: g";; g C( p~ ,}~ ..., ('.T c:: I?:::Y .::;;: :~ r.. .'l'"'''::::' J:!::' I~ .c-J!!'> I""':'J q.......,:;: k -.... 1./1<- Q ~ ~J!:P UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST COPRORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff v, James E, Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proof of publication with regard to the captioned matter. DATE: March 9, 2004 UDREN LAW OFFICES, P.C. B~ Ma k ,Udren, ESQUIRE ATTORNEY FOR PLAINTIFF PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Rich Canazaro, Internet Director of THE SENTINEL , of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of publication n :'''<I101Tl8lco OUCh ell .. · kriOwn \0'" ...,.I1IIl!!'"lI,l1\oell . ~l!XfOII>lOdto'" . _...~ tom,1ce payment .. . _~.\O: ~J.o~ ~'" ~~. '95I11!!!1tB *'*"'~. ClIiIilili~1 rr .. .~ ~ YO~v":~~C..1 '~F'::'" ",ouSEHCiUl F~ &~ jjiid rot.~ ....~~,..,! j~t.: comp"'lII}'i%J ~~=.." Cumborlarid ctiIII . 8'Itlo. ..c; . '(OU"'AVEBEE"~~~~ j ~'~~~j ...prov~oI_ =ouoJn8tI"Dr""ilf' wlthou.\Wlllondl ". . " .. . Iv ' ""', It=~&~ ...',{ .YoU' OUNNING"'AM6 YOUBHOut.oTA' . C~.l',c. HAYE A~wYE ,fle!loItIMlI........., I:::~:w"1,.IJi'. .,.......< ....'}It... eaAIILE ".~. ..., .. ~~~ .'" :=.~ 10'. , ..-......Iif..... ~. . 01 "'-"'Y II,..... oIL.-._T~ Cu..-,;d CoIinIy, . ~_.A11 ...--- .........~.. em ..~"::.Illoh Ut:4*ll:. Id. Thoele il8f'l8M IIldobt8d 10 ... doiQOdInt... __ 10 '1'*1<" paymont _. !.lU'1out dea1y to: The Sentinel February 24, 2004 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. February 25, 2004 Sworn to and day of 25th My commission expires: NOTARIAL SEAL \ DARCIE A. NEIL, Notary Public Camsle, Cumbertand County: M gijtttffllll~I!l11 F.~ . irl!S Nov. 24 2 Q.~J PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16,1929), p, L.1784 STATE OF PENNSYLVANIA : ss, COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor ofthe 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 FEBRUARY 27, 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, SWORN TO AND SUBSCRIBED before me this 27 day of FEBRUARY. 2004 NOTARIAL SEAL LOIS E, SNYDER, Notary Public Carlisle BolO, cumberland County My Commission Expires March 5, 2005 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-LaW No. 03-6129 CMI MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUCCESSORS AND ASSIGNS. PLAINTIFF vs. JAMES E. TSCHUDY. KIM D. TSCHUDY, LAST RECORD OWNER. MELISSA TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER and JOSH TSCHUDY. KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER. DEFENDANTS TO: KIM D. TSCHUDY. LAST REC- ORD OWNER, AND UPON ANY AND ALL UNKNOWN HEIRS OF KIM D. TSCHUDY. LAST REC, ORD OWNER. Defendantls), whose last known address is 138 South Locust Street. a/k/a 138 Locust Street, Camp HilI, P A 17011. COMPLAINT IN MORTGAGE FORECLOSURE You are hereby notified that Plain- tiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. ITS SUCCESSORS AND ASSIGNS. AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUC- CESSORS AND ASSIGNS. has flIed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend. against you in the Court of Com- mon Pleas of Cumberland County, Pennsylvania, docketed to No. 03- 6129 Civil, wherein Plaintiff seeks to foreclose on the mortgage se- cured on your property located, 138 South Locust Street a/k/a 138 Lo- cust Street. Camp HilI, PA 17011, whereupon your property would be sold by the Sheriff of Cumberland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above. 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 wrtUng with the Court your de- fenses 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 PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WlTH THE INFORMATION ABOUT HIR- ING A LAWYER. IF YOU CANNOT AFFORFD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA- TION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELI- 3 ,. .' CUMBERLAND LAW JOURNAL GlBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 MARK J. UDREN, ESQUIRE UDREN LAW OFFICES. P.C. Attorneys for Plaintiff Woodcrest Corporate Center 111 Woodcrest Road Suite 200 Cherry Hl11, NJ 08003-3620 (856) 482,6900 Feb. 27 4 -r,.:' \~, Q~r L.. L~'. (.0. ::S,;" '-' ~:;;~ ~~;~ :";1 -< (') S; .; -, ~ ...., = c.~;) J~- - ~~ "'("c" ?;J o -n ::;j- fil f-'~~ -o:l~ 'J'Jj 91.S :::C ::f.~ '~Sf~--: ~i o ~;:: ",.. 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 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v, James E, Tschudy NO. 03-6129 civil Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the plaintiff and against the Defendant(s) James E. Tschudy, Kim D. Tschudy, Last Record Owner, Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner for failure to file an Answer to Plaintiff 1 s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/12/03 to 4/16/04 Late charges per Complaint From 11/12/03 to 4/16/04 $114,189.88 3,984,66 247,26 TOTAL $118,421.80 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237,1, a copy of which is attached hereto. DOREN ~ DAMAGES ARE HEREBY ASSESSED DATE: f4pAil. ~ I j 'J..Do'f Mark J. Udre , ESQUIRE Attorney for Plaintiff AS INDlfATED ~ {~~, ~ PRO PROTHY ~ - C//.~ 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 856-482-6900 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner NO. 03-6129 Civil Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) TO: Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 March 22, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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. DATE of Notice: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO, AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS .LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBT'Ii\D WILL BE USED FOR THAT PURPOSE. ~ ~ "--- /s/ Mark 0. Udren, Bsqu~re Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ~TTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-482-6900 Mortgage Electronic Registra~ion Systems, Inc., ~ts successors and ass1gns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. James E, Tschudy Kim D, Tschudy, Last Record Melissa Tschudy, Known Heir Tschudy, Last Record Owner Josh Tschudy, Known Heir of Tschudy, Last Record Owner Defendant(s) Owner of Kim D, Kim D. NO. 03-6129 Civil TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, PA 17011 DATE of Notice: April 2, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS,YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER 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 NOTIFlCACION, 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 SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL, SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND TH!JIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE , D ~R THAT PURPOSE. /s/ Mark J. Udren, B Ulr Woodcrest Corporate Cent r III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. ~Y: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-482-6900 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner NO. 03-6129 Civil Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 DATE of Notice: March 22, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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 Bar Association 2 Liberty Avenue Carlisle, FA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES . DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLE OR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION 0 I ~ WILL BE USED FOR THAT PURPOSE. /s/ Mark J. Udren, quir Woodcrest Corpor~te Cent r 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 856-482-6900 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff v. James E. Tschudy Kim D, Tschudy, Last Record Melissa Tschudy, Known Heir Tschudy, Last Record Owner Josh Tschudy, Known Heir of Tschudy, Last Record Owner Defendant(s) Owner of Kim D, Kim D, NO, 03-6129 Civil TO: Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 DATE of Notice: March 22, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES, DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTA D WILL BE USED FOR THAT PURPOSE. I~ /sV Mark J. Udren Woodcrest Corporate nter 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. 'Bt:. MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO, 03-6129 Civil v. James E, Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: James E. Tschudy Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Kim D. Tschudy, Last Record Owner Over 18 As captioned above Unknown ~ Sworn to and subscribed before me this 16th day ~f April, 2004. '-~~\ ut>- "'\'(\ ,~~l Notary Public Name: Title: Company: MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P,C. TERESA M. KAUCIC NOrm PUBUC Of NEW JS/SEY CoIInIssIon ExpflI8s4lle/8 t);'!i ~ - - () F B ~ c i;\~~ j -...;} ~ :?; ~ '-<--- t',' , , "'T' " .1 " ?,'. -".t ).-. r,"' I...; ,.<. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE James E. Tschudy NO. 03-6129 civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 4/17/04 to Date of Sale September 8, 2004 Per diem @$25.38 $118,421.80 3,680,10 (Costs to be added) $ UDREN LAW OFFICES, P,C. Mark J. Ud n, ESQUIR ATTORNEY FOR PLAINTIFF (CJ ~ ~Ii ~ -~ [II ~~ r -'3 p L ../g, ~ ::--- ") () Q. D )::.~ ~ _ Cnf'- -In ~ ~:..o~~ ",~~.:.:z- ~~O"'l~OD' h ~CCC~c.c~& - _ ~ _ ~ _ ~ ~cV ... .... - ........ j.. r--- :. \ ;: - :: :: ~: ~~ .~ , ., I ----I WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION NO 03-6129 Civil CIVIL ACTION - LAW SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUCCESSORS AND ASSIGNS, Plaintiff (s) From JAMES E. TSCHUDY - KIM D. TSCHUDY, LAST RECORD OWNER - MELISSA TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER - JOSH TSCHUDY, KNOWN HEIR OF KIM D, TSCHUDY, LAST RECORD OWNER (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 enjoiued as above stated, Amount Due $118,421.80 L.L. $,50 Interest FROM 4/17/04 TO DATE OF SALE 9/8/04 - PER DIEM @ 25.38 -- $3,680,10 Atty's Comm % Due Prothy $1.00 Atty Paid $218,25 Other Costs PlaintifTPaid Date: APRIL 21, 2004 CURTIS R. LONG (Seal) Prothono~ <!lY: Aj'J.n"..,. ~ P ,'71Z C/V1..'p..r- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ill 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 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO, 03-6129 Civil 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. 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 856-482-6900 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO, 03-6129 civil AFFIDAVIT PURSUANT TO RULE 3129,1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.), PA 17011 1, Name and address of Owner(s) or reputed Owner(s): Name Address James E, Tschudy 138 South Locust Street Camphill, PA 17011 Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp.), PA 17011 Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camphill, PA 17011 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 None 4, Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein, See Caption above. 5, Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Commonwealth of PA Bureau of Individual Tax, Inheritance Tax Division, 6th Floor, Strawberry Square, Dept, 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax, Procedures Branch, Phila, , PA 19105 Special PO BOX 12051 Dept, Of Public Welfare TPL Casulty Unit, Estate Recovery Program, PO BOX 8486, willow Oak Bldg., Harrisburg, PA 17105-8486 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, Dept, 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 138 South Locust Street a/k/a 138 Locust Street, Camp Hill (Lower Allen Twp.), PA 17011 138 South Locust Street a/k/a 138 Locust Street, Camp Hill (Lower Allen Twp,) , PA 17011 Any and All Unknown Heirs of Kim D. Tschudy, Last Record Owner 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: April 16, 2004 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E, Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO, 03-6129 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E, Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 b~ 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, amount due 6900, The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-482- 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. home back, You may also have other rights and defenses, or ways of getting your 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 FILADELFIA 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 856-482-6900 Mortgage Electronic Registration Systems, Inc" its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v, James E, Tschudy NO, 03-6129 civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) . NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 p~event 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 b~ 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. amount due 6900, The sale will go through only if the buyer pays the Sheriff the full in the sale, To find out if this has happened, you may call 856-482- 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 TBLEPHONE 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 FILADELFIA 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 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E, Tschudy Kim D, Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D, Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF ~ COURT OF COMMON PLEAS , CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D, Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp,) , PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.), PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 FILADELFIA 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 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: All and Any Unknown Heirs of Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp.), PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 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 judgmentj 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UD~~N LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.), PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 Sheriffts 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 attorneyts 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. 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. the full amount due is At that time, the 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 T~REN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camphill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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.) ~U 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. 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. the full amount due is At that time, the 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 FILADELFIA 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: August 3, 2004 BY: Mark J. U reIT ESQUIRE Attorney for ~laintiff Mortl'lle ElodTOolc JleIisW'tlOD S~st-.InC.. eI...... P\llilltUIf.sl.... . ",. Ja_ E. T..,hudy. eL al.. J)deollllDt(l) f .,.... . ~._. _.)1 ~, ' \ '.<'~ \' '.' '.\ \!- ~_--"--C . //' service of I'ret- by .. _t"'l "'='~=__"~O"'fI' l.tll ~..~U.....I..........a -...., _..-- 1-806-31.8-7171 ,.l'S IIlt.......tIo~a1 PI... . 1iW Vi.-u"O)" i~ .-...- t&r.....pcll=. M!'I5!4'!b1.I.ll... 1--- \ I UUjU!;I"'L"''''-~~~''''''''::'' \ MoL ADgellque S_v.. III W_"'''' RoooCl SUIt< 200 CIltlTY Hm. NJ 08803-3610 1_..-.-.----- -,--- AFFJDA Vl'l' OF SERYlCE __Individual \ s.rvI<e.' -. .,,, _Mcu.sa TsChudy, known beir of J{lm D. .T,!,"h""~ _ . _ ..~. f'lo." <1:"......0"&...1 \ _..~---- ----- - I --_.._-~.... ----.-.-- - - - ~. -. -- - ....."" .. -. .- - - f;i;;j,t~ ...!i i"E~~!t"J!f;{ f.'.""!.;t!.J /-'1'1 " !!, D=te,l"nme ~f ~!.... tMt..l\n t'hP. L1 da1 of :TULI/ , in N.-....rt. PA.tl'7tr7A Place 0. Service' o.t 4:MJ 811_- ,,-"ad ll,c undorsigncd "",,"vod the documents deseribed as Noth:e of Sheriff's Sale of Ileal PropertY A trUe and \:oaect.copy uf1he..foresaid"documctli:(.} ww;'Jer,'ed- on;. Melissa Tschudy, known heir orKlm D. Tschudy iVi ... .., . th .,', ~ -,..~ _r....... - - +0 b- _.....A I.f" By per3t\!ln!!y <!e!wermg. ...em m\~ k!O:c!~\lI!'~~'''! ."'E ;;~.R.... , ~ :;,.. .- DoeUJJlent" ~erv~;. - . Service of "ro~es' on! Penon. S~rvlNi~ add Metbod. of Service, L j By dt:iivcrwg thQiu iiiiU th~ hands of suitable age and discretion :residing at the :l'lace of Service, whose relationship to the J"'!'!'''''. to ,.;., oeTVed is _ --.......... ^. 7 ::.: ~.._.~....,... ... ~~~:~:.::.::=,....~:_~~~~ ~~~:::oc=~,p~.~~,~~~~~~~,.). ~. r..d~!.n~;~'" Awrox. Age~; Appl'ox.. Height -1ii:' ; Appl'ox. WeIght / SC' ~ To the: be:;t of. my .know.k4:le_!!Id.~i"'f,.tI!i6;rr.l;l;07I.Ylas.~Bedi.:..;m.:Ufr.M~..,>Gt- ". the time of service. _..... slgnature or :5en-er: Unden;igncd dcvl....,. u,,;lc. i'c,;lalty-ef i'''*".)........S\lloeCJi'.c.dA.,d.zwom ~.befO!....!:J'A.tbio ... ....,. ." ~.. ...., n~ ~ r/ mat tn~oregul1l1ll,.. ''- ........ ....U...... ...:.. . . ~ \i4>} Ili .. ,.. ..... 1>'1 .=-,. (L r I . / .....-...v~ l ,.., ~/~tv~?-- .~ ;;:/ c,..;-~~~1'. '-G:.::;~ Sisn~ -Js"",... ~.) N"'''''''' h. ((;ommiOGion ,..pi"") APS International, Ltd. :D. 1'( - .3 - 03" APS FRe 8: 0671........1 " "0 Co> t:"~ ""'"" J:>. c::: C, I O"l -0 ~ is' (.v (;1 o -'J --< ::t:':r, rn.".._ ,-- '-"c 'cpD"1 _/J C) .~l! ~f;' (J.:!..l -0 .,;...~ 0'" '~-I "'. 5.J ~c 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff l COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) SUGGESTION OF BANKRUP~1CY To the Prothonotary: Kindly note on the record that the above Defendant, James E. Tschudy & Tammy J. Tschudy have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on August 9, 2004, Bankruptcy Case No. 04-bk-04789. 03090108 Mark J. UDREN L Attorne \^ , Ud en,- Esquire OFFICES, P.C. for Plaintiff o F~ , "" C..:::> C? ..c- ::::;;. (:'::- G:;: en -c; c..J c:~ 0' Mortgage Electronic Registrations Systems Inc., et al VS James E. Tschudy et al In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-6129 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark J. Udren. Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Surcharge Law Journal Patriot News Share of Bills 30.00 17.45 15.00 15.00 .50 1.00 15.00 20.02 30.00 367.70 347.89 30.49 $890.05 Sworn and subscribed to before me ~.r~er;,: ./.-# fl _ A I ~u--.-~..r~ This ~ day of ~_ , n R. Thomas Kline, Sheriff 2004, A.D. '-ft'. 0, YJ,-ct{h./,~ BY J~J'mJ.;fh Prothonotary Real E~e Deputy I,SV c..k.- 4 .., 0 } "1 f!<v /$$D11) 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address James E. Tschudy 138 South Locust Street Camphill, PA 17011 Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp.) , PA 17011 Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street C~mphill, PA 17011 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 None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Commonwealth of PA Bureau of Individual Tax, Inheritance Tax Division, 6th Floor, Strawberry Square, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax, Procedures Branch, Phila., PA 19105 Special PO BOX 12051 Dept. Of Public Welfare TPL Casul ty Unit, Estate Recovery Program, PO BOX 8486, Willow Oak Bldg., Harrisburg, PA 17105-8486 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, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any. inte,rest in the property which may be affected by the sale: Name Address Tenants/Occupants 138 South Locust Street a/k/a 138 Locust Street, Camp Hill (Lower Allen Twp.) , PA 17011 138 South Locust Street a/k/a 138 Locust Street, Camp Hill (Lower Allen Twp.), PA 17011 Any and All Unknown Heirs of Kim D. Tschudy, Last Record Owner 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: April 16, 2004 Mark J. U ren, ES . Attorney for Plaintiff 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 Mortgage Electronic Registration Systems, Inc., i'ts successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 SQuth Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 pal', 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 S,AVE 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 h.e 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. amount due 6900. The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-482- 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 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camphill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 YOll 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. 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 clays 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. the full amount due is At that time, the 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 FILADELFIA 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 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp.) , PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.) , PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 attorneyls 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 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: All and Any Unknown Heirs of Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill (Lower Allen Twp.), PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camphill (Lower Allen Twp.), PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor,Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT Ci:RTIIIN piece or parcel of' la~d situate with the building and improvements thereon erected being known as Lot' No. 90 on Plan of Lots laid out for. Allen Park Development Corp., called Cumberland Park, as recorded in Plan Book 4, rage 86, Cumberland Co. Reoords, on tho southWesterly side of Loeust street, Cumberland Park, Lower 1\llon Township, Cumberland County, Pennsylvania, bounded and described as fo~lows to wit: " j BEGINNING at a point on the southwesterly side of Locust Street 60 feet wide, said point being at a distanoe of 275 feet m~asured North ~o degrees JJ minutes we~t from the intersection of the said side of Locust 'street with the Northwesterly side of Locust Str",et GO 'feet wide, beth lines preduced; .thence extending along Let No. 89 seuth 49 degrees 27 minutes West a distance of 127.50 feet to a point; thence extending aleng l~t Nos. 94 and 95 North 51 degrees 21 minutes 30 seconds West a distance of 130.94 feet to a point: thence extending along property now or late of Robert stoner, 'North 71 degrees 57 minutes 30 s",conds ~"st, a distance of 164.59 feet to a point in the Southwesterly side of Locust street: thence extending along the said side of !.ocust street South 40 degrees 33 minutes East a distance or 65.61 feet to the place of BEGINNING. HAVING THEREON ereeted a single dwelling known and numbered s 138 Locust street. -,-,,~~,---""'~.~":"~~--:"""""""""~j:~-:"'~~:" ..,-c."..~__.....,_,-:""'.,..,__--,.----.,.-:'""_, .-.- --. . .-' BEING KNOWN AS l38 SOUTH LOCUST STREET A/K/A 138 LOCUST STREET, CAMPHILL (LOWER ALLEN TWP.) , PA 170ll PROPERTY ID NO: 13-23-0555-057 TITLE TO SAID PREMISES IS VESTED IN JAMES E. TSCHUDY AND KIM D. TSCHUDY (DECEASED) , HUSBAND AND WIFE BY DEED FROM ANNA GESFORD, SINGLE WOMAN, DATED 5/21/93, RECORDED 6/3/93, IN DEED BOOK 136, PAGE 13. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUCCESSORS AND ASSIGNS, Plaintiff (s) From JAMES E. TSCHUDY - KIM D. TSCHUDY, LAST RECORD OWNER. MELISSA TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER - JOSH TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER (I) You are directed 1:0 levy upon the property of the defendant (s)and to sell SEE LEGAL NO 03-6129 Civil CIVIL ACTION - LAW 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due $118,421.80 1.1. $.50 Interest FROM 4/17/04 TO DATE OF SALE 9/8104 - PER DlEM@25.38 -- $3,680.10 Atty.s Comm % Due Prothy $1.00 Atty Paid $218.25 Other Costs Plaintiff Paid Date: APRIL 21, 2004 CURTIS R. LONG (Seal) Prothonotary --.J3y: ~&-t... 9 !rov,........r- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale #18 On May 17, 2004 the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A Known and numbered as 138 S. Locust St., a/k1a 138 Locust St. Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 17,2004 By:.J()~j""Vt(i C) Real Estatg Deputy ~\WJf\I,\SH}\3d \111 ~~ 110 \I II ~d~ .,\ ",' :'J~:)) J,llluu" " - ^'"'l> ,U11l311S 1H~ ,0 j.d,'> ~". ~ ~ ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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 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 ofthe 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. 18 Writ No. 2003.6129 elvll Mortgage Electronic Registration Systems, Inc., its successor and assigns. as Nominee for Household Finance Corporation, its successors and assigns vs. James E. Tschudy; Kim D. Tschudy. Last Record Owner: Mel1ssa Tschudy. Known Heir of Kim D. Tschudy. Last Record Owner; and ,Josh Tschudy. Known Heir of Kim D. Tschudy, Last Record Owner Atty.: Mark J. Udren ALL THAT CERTAIN piece or parcel ofland slluate with the build- ing and improvements thereon erected being known as Lot No. 90 on Plan of Lots laid out for Allen Park Development Corp.. called . ......__.t D.....\r ...... ,..a..........r1...d.J.I1".._ ~~ tv/ . ~"'" co~. Editm SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 ~-f -<J) ~. J:n<,~/;) N~tlll!'SEAl if-- LOIS E. SNYDER, Nolafy Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2005 , ."'~-, - Kim D. Tschudy. Last Record Owner; Melissa Tschudy. Known Heir of Kim D. Tschudy, Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Atty.: Mark J. Udren ALL THAT CERTAIN piece or parcel ofland situate with the build- ing and improvements thereon erected being known as Lot No. 90 on Plan of Lots laid out for Allen Park Development Corp., called Cumberland Park, as recorded in Plan Book 4. Page 86. Cumberland Co. Records, on the Southwesterly side of Locust Street, Cumberland Park, Lower Allen Township, Cumberland County, Pennsylvania, bounded and descnhed as follows to wit: BEGINNING at a point on the Southwesterly side of Locust Street 60 feet wide, said point being at a distance of275 feet measured North 40 degrees 33 minutes west from the intersection of the said side of Locust Street with the Northwest- erly side of Locust Street 60 feet wide. both lines produced: thence extending along Lot No. 89 South 49 degrees 27 minutes West a dis- tance of 127.50 feet to a point; thence extending along Lot Nos. 94 and 95 North 51 degrees 21 min- utes 30 seconds West a distance of 130.94 feet to a point: thence ex- tending along property now or late of Robert Stoner. North 71 degrees 57 minutes 30 seconds East, a dis- tance of 164.59 feet to a pOint tn the Southwesterly side of Locust Street; thence extending along the said side of Locust Street South 40 degrees 33 minutes East a distance of 65.61 feet to the place of BE- GINNING. HAVING THEREON erected a single dwelltng known and num- bered 138 Locust Street, BEING KNOWN AS 138 South Locust Street a/k/a 138 Locust Street, Camp Hill {Lower Allen Twp.l. PA 1701 1. PROPERlY ID NO: 13-23-0555- 057. TITLE TO SAID PREMISES IS VESTED IN James E. Tschudy and Kim D. Tschudy (deceased), hus- band and wife by Deed from Anna Gesford. single woman, dated 51 21/93. recorded 6/3/93. in Deed Book 136. Page 13. V-<::A^-4)J~ . NctfAt\a LOIS E. SNYDE' Carlisle Boro, Cu' My Commission Exi THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Connnonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being dilly 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 Connnonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 27th day(s) of July and the 3rd and 10th day(s) of August 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COPY SALE#18 PUBLICATION Sworn to and ~:,:~e~~r~s 23rd day of ~.~2'4 A.D. Terry l. Russell, N~iP%/f~i/'/l~ Oty of Horrlsburg. DaUPhl~~~~ ~UBLIC My CommiSsion Expires June 6, 20~ll" . . M,mber.P,nn.yl"nl,A"ociMlhbHlt/lillii on expIres June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 347.89 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... , .. , 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Interest From 04/17/04 to Date of Sale September 7, 2005 Per diem @$25.38 $118,421.80 12.918.42 Amount due (Costs to be added) $ ;z) ~ ~ r '- [? -bil. '- D --... ~ }^i () C> ~ \/ <>.v -.. w () r - c- ....a 8 I }-J tv t VJ -..c:: ~ C; t, + "'v '- C/\--()~-~ C/)--aVtQoN~- 60~()~QC' g \jC 000.0 I I , ::: " :::: " ~ ~ - , , "'- - , - , , ~ "' ~ U;~ UV) :.0 l) .....)() r0V : ~ fL , ~Ib . lA..I +-- .'fti- c.).. ~ 0 - c.:> ~n CJ"'I --1 5~ Rip :;;.;:,. -,..,fil W -.uC:J ;.'. J.,. C) ">c.j ::r :r~ (}<:') -". ~=-) ~!l (;~? ~i"~ t...) ?~ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-6129 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUCCESSORS AND ASSIGNS Plaintiff (s) From JAMES E. TSCHUDY, KIM D. TSCHUDY, LAST RECORD OWNER, MELISSA TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER, JOSH TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER (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 ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $118,421.80 L.L. Interest FROM 411 7/04 TO DATE OF SALE 9/7/05 PER DIEM @25.38 - $12,918.42 Atty's Carom % Due Prothy $1.00 Atty Paid $1I20.80 Other Costs Plaintiff Paid Date: MARCH 30, 2005 CURTIS R. LONG (Seal) prothod; ---..Ily: ~ 0 P. 7f(/t'fid-~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Conrt ID No. 04302 , ~, " -~ IN THE UNITED STATES BANKRUPTCY COURT FOR TIlE MIDDLE DISTRlCT OF PENNSYL VANIA INRE: James E. Tschudy Tammy 1. Tschudy Debtor(s) CHAPTER 13 CASE NO. 1-04-bk-04789 MDF Household Financial Services, Inc. Movant vs. James E. Tschudy Tammy J. Tschudy Debtor(s) / Respondent(s) and Charles J. DeHart, Ill, Trustee / Respondent ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY AND NOW, in said district, upon Motion of Movant above, it is ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided under 11 V.S.C. ~362, is modified with respect to premises: 138 South Locust St. Camp Hill, P A 17011 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriff's Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. BY THE COURT, ?:b~a~~ .hili:< /JIll<) Date: February 16, 2005 This electronic order is signed andjiled on the same date. --- r' ~" 0; '1 ~I'm ,~ ," 2004 . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Mortgage Electronic Registration: COURT OF COMMON PLEAS Systems, Inc., its successors : CIVIL DIVISION and assigns, as Nominee for : Cumberland County Household Finance Corporation, its successors and assigns plaintiff :NO. 03-6129 civil ATTORNEY FOR PLAINTIFF AND NOW, this v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) . 3f'J 0 R D -E R :( J - Day of F"e.bru..o.r 2001 consideration of Plaintiff's Motion For ServO e Pursuant To , upon Special Order Of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Complaint In Mortgage Foreclosure on Kim D. Tschudy, Last Record Owner, and upon any and all Unknown Heirs of Kim D. Tschudy, Last Record Owner shall be complete when Plaintiff or its counselor agent has published in accordance with Pa.R.C.P. 430(b) (1) a Notice of the action once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service of all subsequent pleadings that require personal service, including, inter alia, the Notice of Sheriff's Sale, 'shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011, which is the subject matter of this action in mortgage foreclosure. BY THE COURT: )51 ~ B. ~If 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil 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 penalt'es of 18 Pa. C.S. Sec. 4904 relating to unsworn falsific tion to authorities. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF o f-- ,.." -:.::;;::Jo c...:> "-" ~if: ~ ':;",. ::.0 ~., c::> o .. .-1 III n1r= -~Jm -:-)0 ()(l.) ;Bf~ -~'l ~5,; .< -c:> ..,j", <...) C0 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil of PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camphill, PA 17011 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 450 Buckwalter Road Newport, PA 17074 - Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federal Estate Tax Special Procedures Branch Department of Public Welfare TPL Casualty Unit Estate Recovery Building Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue Bureau of Individual Tax, Inheritance Strawberry Square, Dept. 280601, 6th Floor Harrisburg, PA 17128 P.O. Box 12051 Philadelphia, PA 19105 P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 - 7. Name and address of every 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 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 Any and All Unknown Heirs of Kim D. Tschudy, Last Record Owner 138 South Locust, a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: March 24, 2005 n c'- '" ,= t,;;."') 1..1' :K :l-.;" :':0 (..} o o "n :.:? f'Plpg -8fT) :.]7 !,:~.ic) -:"~ "rl ('-):=-' " t) f~n-~ .- :< -:J c.) G) .' 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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 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. 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 E 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 backJ if you act immediately arter 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 OFPICE 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 .-ee,.-' n c;; ....' c::::> C.:'; "" ::<C % (....) co -;;J. -:'~ n ~-1 .-l \:-r-: r,'p -nt::;:1 -~_)"'r IJC) ::,.:1+'-1 .. ") :;~~ --;"l.. j ~;~(\~ .,::;" ~:2. (,? ", - '" 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: All and Any Unknown Heirs of Kim D. Schudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, ( Lower Allen Township) PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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: (8561 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 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 immed~ately after the sale. YOU SHOULD TAKE THIS PAPER TO YOllR I.AWYER 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 Cl ~;:: .--' (~ ~}~ ~2:'~. ::';:-:J c~) c:J <;:;\ -' ~C-f", {'r' "f'~ ~ctD) ~' } '"" l),f-"-") ,->~ -~',.' ,,' '? ;;~2. .\" -0-;-' '~:~ " ::? ~-.::. (,..1 - i ;'" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE TO: Melissa Tschudy, Known Heir of Kim 40 Buckwalter Road Newport, PA 17074 NO. 03-6129 Civil OF REAL PROPERTY D. Tschudy, Last Record Owner Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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 (lO) 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 c.~ o <;(~ :::C --("~ f;'f:;", ~::::,{~ -,-j"--\ -l),C? -'''i;_:~:\ }~~i?, ':-:-\ i:.! (. ~ C:---4 ~:.r: '5- -~;;; ~~, ,'-. -0, ::>... (..,) .. c.,) t'-" ~3:1, .~ IIJ 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 v. 1 COURT OF COMMON PLEAS 1 CIVIL DIVISION I Cumberland County iMORTGAGE FORECLOSURE ~ Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE TO: Josh Tschudy, Known Heir of Kim D. 138 South Locust Street Camp Hill, PA 17011 03-6129 civil OF REAL PROPERTY Tschudy, Last Record Owner Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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. 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 Q ,-> t::~ ~ :::-;: S;'; c" o ~, o -n _1 :r: -r. rn?,:;: ~~~ -:~l '.:-;i9 ~~ \\1, ~-\ -,- :iJ '-'-" <.:? (~, 1'0 , . ~ 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ~ COURT OF COMMON PLEAS ~ CIVIL DIVISION ! Cumberland County i MORTGAGE FORECLOEURE ~ and v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 03-6129 Civil Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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. 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 Sheriffl 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 0 ..., 0 c= ~:: (:'::.'! -1') en ~ ...... ---,,,, -=-r: ::.~;;" rilp ;;.~ -r-,rn C~) :;j'::: 0 r ) , :,0 .'1- ~., ',,} -i :~~J _.0... ..( .) ( .. ~ .) J 1. ( 0~ ~:'l .'> ~j (..J ~';:J -'. I'v "'..;: ~ 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE o THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to he captioned matter. UDREN LAW OFFICES, P.C. D~'e' April 28, 2005 , ESQUIRE laintiff , Mortgage El<<lronlc Registration S)'$teIJIs. Inc., ct al.. P.laintiff(s) vs. James F.. TsChudy, d. at., Defendant(s) Sen'lc:e of PrMeJl\ by Jft~ APS International, Ltd. ~L ] -800-328-717] _n --<:::. APS tt41'E1tNATlONAt, APS Intenlation:.1 Plaza 7800 GleDroy Rd. MInIle:apDlls, MN 55439#3122 AFFIDAVIT OF SERV]CE - Individual UDREN LAW OFFICES. P.c. Ms. Ciltdy G~mel 111 Woodcrest Rd. S.ite 200 Ch<Tf)' Ilill, NJ 08003,,)'20 Service 0' Process oa: -Melissa Tscbundy, known heir of Kim Tsmundy Court Case No. 03-6129 51"lcur: .;:{,-;;S-It-;;tiv;';' lss. Cmmtyof; Si1I1<J(1t... ) Name uf Servet": GAll l~ _ /) ~ .li~~~t... alJ S" TltiJi,f. , undersigned, being duly sworn, deJXlses unti :suyi:i , that at the time of service, slhe was over the age of twenty-one, was nota party to this action; DaleffimeolService: thatonlhe -LLdayof /1m"... ,200:;-",al ~o'clock ? M Place of Service: at ._i~_~:u:~'~a!~.!.~~_____ ,in ~~et}xlJ..r~ .n~J~ Service of Process on: the undersigned served the docwnents described as: Notice of_~b_e~ff's S~I._!fRe~l~r~..~~y_ ...... ._.. _._.___ A true and correct copy Qfthe aforesaid documcnl{s) was served on: ~~.!~~u~~!:.!<-no~.~~_~!.~~~hund~_____ ,~,,___.. .___h.'.'_. .. [1 By personally delivering them into the hands of Ihe person to he served. l)d By delivering them into the hands of 7)~ ",,;V tp NIT( , a person of suitable age and discretion residin~ at the Place of Service, ~,~~J("".,,~~l J U..!f) whose re;auonsmp to t.'1-.; person 1'0 bC'SLTVCd1S~--.:..:.:..~~'-I1U"" -1_ -- .......":~:~':'";. -- -" -'_'_ Documents Served: Penon Served, and Method of Service: ni:-3,;jpti.:;~ ;:of 1",;;;'s3n- -Th,;-'pCi'3Vi"'r rccc;-..ingdocu'ffiOii.ts i;:;-dc3.cribi.:d-.G:i fc!.bw3:- Re<eiving Documenls: Sex..flL; Skin Color IIlltlr6 ; Hair Color lj<..U(.. .. tJ .r--' ~J Approx. Age ";;1 ; Approx. Height ,,/0 ; Facial Hair Approx. Weight AIM ,}(}-il ~ 10 tile best of my lmowh~ugl: ;:tilU bet1~r, :;;aiu ~n:i()fl W4.~, 1Jv~ ~Hg"'O!;Ci'j1J ute ;,;3 iviti'ttar). "'~ . the time of service, '~gm~t~r!"'~ IJf ~",n:~r~ lln.je!sig!1~tj Q{:,,=-!ar(:s lmdc.r ~11~Uy ofp~rJury thlJt th~ f{\rp.O"oi1'H'T 1<;; tnlf' ~nfl rOO'f'r-.1 ~j~/_t;:tlC::rk::__...__~__._~- S1snntl.1tl of Scr:er (~c) APS lnten.ational, Ltd. APS File II: 071339-0001 sl\b~rihf.:rI and ~wnrn to hr.fnTf: ml"' rhi,\; H--o.:~~;O~-2f~_~L_: .10~~ .. ~c~.::::-: .I'flO1wNoT4llV ~:r;~IC~~ MY C(jMMm~ir\1 !=Yr'F:;:r; ::lri~r i '::,' ~ I,", ',: ":~I'; _.....,..~.-~ C) ~.~~ ;: c' >< _.\ _c. t-'" 0 ~~ -'(1 d' -'" 7- --': \ t.,) -, '::~;. - - r'" >oJ) -...-....." 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. James E. Tschudy Kim D. Tschudy, Last Record NO. 03-6129 Civil Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.Fl.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a -true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto., then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to relating to unsworn falsification 18 Pa.C.S. Section 4904 Dated: August 16, 2005 UD BY: 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) DATE: March 25, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SA:LE OF REAL PROPERTY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County i NO. 03-6129 Civil OWNER(S): James E. Tschudy & Kim D. Tschudy, Last Record Owner, Melissa Tschudy Known Heir of Kim D. Tschud.y, Last Record Owner, Josh Tschudy, Known Heir of Kim D. Tschudy" Last Record Owner PROPERTY: 138 South Locust Street a/k/a 13!l Locust Street Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on Septembeir 7, 2005, at 10: 00 am, at the Commissioners Hearing Room, 2nd Floor Courthouse, Carlisle, Pa. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance wii:h the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A !~ -aSii o ~ 'tic: a: 'CD :I;.. "'"- ~ . "c:i $ -0 15~ 'E l/i"- !!1::2! . ;10= ~ .'2 "'_ "0 a: $ ':!::,ao <>.la:14. e-I/) .... <DB. <3 ~"O-8 1 ~ Ul ll~ ~!S1 ~c5- h ~ 5i~~ ~ 0" ii Hli i~~~>'.! ~~.l ~ h i~o. 0 ~,~~:a ~G) n6~'H !'-' ,g 15 i .~l~ ! n~J l1!-:.~ O~Ou 1 'il ~b~ Mol: '" '" ~.('\I c!'" c.i~~&l 'OJ .'7 a.._."'o.t"J .,l!!88 .~ e.~ g \l:. 0:'" 00...:"% ,..,;;U= 3l!!g:f '" <>,. r: GJ~'~" ..8- GJ "',..-'" ::t;;ll'''I''''',(J . "Otl)tu ~l.D"'O CD e. li5 e:gC/J ~<o i 0. 0 cD I as Ui a... 'EO * III U .~ ~ US 15 (.) I "@ a 11> 0. ~ :x: -0 % g € l <'l ~ ~ c 0 $ - ~ ~ U) iil ~ !!! 0 ~ l:l III f- a; "15 <D Cl: CD !!i 0<'> ~ '" m~ UJ<'l z "$6 8';;; 0::':: Oel. .#' , .s- <~ "' ~ \d.~~~ ~ ~~ !I:1Q~ ~ -.: -.... \ i "(~ .4 1;; - " d $ I ~ ~ ~ 't)V5 ~~!! ~ 1 i~.5~ ~_ ..~..~ '" Ui ~3 >;;':: ~g ~.~ ~ wi." i~ li ~~ ~ ~~ ~~;: l:: e- .= Q.. ::0 Co 8 ~5 d ~ ~ ~E ~'" 1!~ ~"' ~3: elo- ~.~ ~~ :a' el.~ $:g ;z~: "0 III 8 III "Jr ]!~ uOl; "0 81:::'~~. ,x: ~ \1'1 Ii l...J)( ....J ~~ ui~ 5 (/)~ ~S~ '~.c.>- og [llll\ en ~.. l!! .il>zSc ~~ s~ ~~~,;;:a ~.~~ ~al~ i~ l~ ~~~!l ~,~n! ~ 1l <5 ~ ~\, ~ ~ ~ ~ el. g ~ ~ .. "oe ~ ~S 5e.iE"8~ "0 Hh': Q.lll$ o"'u.~ 'R-elllsi" ~~ ~i1l ad~s !Hn~ .!!! >- '" Iii 0 "C <!i ." E -g ~ 1I> ~ J:) i5" li,i! ~ e " .S; l- u-o U ~ ::; - '" <'l .... 10 '" f"- a:> < , Ii" !.". , ~ i' ~~ . ':09.0 ",......:. :. . - .t."" L ;&"Il. ~~. \- '. ......^ ~a<IJg~ hiih 'IO:;iS". ~1!n~ . ~~li~~ ~ ~jj ~,-11 E ~~ ~ ii19: '~~i~h E~ -5 '" ." l!~.. ~gc s.us:s .. o. ' 0 ~ '~~l i- 'ih:g."'6 ~c.~ 8 >- \~f~1!l =:S!ii& i~,H! ~* '!:;~ :-.~ ~.t! ".. - iilCD,[: '" ..1!'":;:; .~ ~:::~. o~ ~i~@j~ 1i~~lh ~-e -:g~ ~~i:o;:;~ ~'it_~~~_S v ,~ . .'\ .:: :. .. .:: .15 II. -m .lD ~ .'0 "" :.= ......- ...... -:-' -.... ------=-- "'1.' :, =---. i '.~~.~..... ~! ~.'i> ~ '-' SIY.1l1 ~~~ <!!. < !' .~.._ _j. . "9- 'iY. I . li A2 ,:~-,til Q.. . C o (J .. .D 'iii ::l :E e ~ o u.. ':':.., ~ "5 ~ ;! ~ l!; el. l!;l<0 Ui III E 1;; o a. ,Iiill'l - .8... .... U '" '" ~ U - ~ '" ::> ~ :a Q) u- ii:_ ~ "\S! ttQo ... E oJ:) 0 -'il u- 0 ~ <>I <!l ... 10 ~- rn '" ~ - ~ ~ ~ - >-3 0.. EXHIBIT A ~ ~m I) :::E o Oc C)_00 ::c~~:o m""mm ;7:l<;WZ ;7:l0-lr- '<OC).~ :1:00<= -C):DO F:D-o-n t:mo-n w - -l:Do O:D~m 10 m_W >0-0 omh z. -l m :D r'-' r'- lrl lrl m m 0 0 ~ ~ JI JI ":i:'d~~z II" II" nJ nJ ~Ol"'ll:l'" nJ'rIJ . n l"'l ole ~~..~~ 010 l"'l~E:t"E: 010 t"'"''':i 0 0 ~~~~~ a- a- m', m 0: 0 ~ Q~~ lrl lrl ":i l:ll"'lZ 0 0 ;;. d..,~ 0 0 r'- r'- ~ ~~[Il ~ ~ l"'l ~ ~ ~ n Q == U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic M8I/ Only. No Insurance Coverage Provided) , ,. " OfFICIAL USE n~'" Postage $ .5 30 I is CenII1edFee -..._ Fee (Endor'8l.tm8OtAequlred) R8IdriCted Delivery Fee (EndOrSement ReqUired) TataI Postage & fees $ (j If. 7 INTEF.NAL REVENuE SERVICE t, FEDERAL ESTATE TAX ---;, SPECIAL PROCEDURE BRANCH ",POl ........ P.O. BOX 12051 City,S! PHlLADELPHlA, PA 19105 - HON EXHIBIT A ~ {1erun ,] T5chundy .~. ~li ~ ?t'.~ ~ ~ 3 ; 1 ~ II '" ~ --.l ~. Cl Cl ~ Lr1 Cl ~ w 3 ...Il '" Cl ~ Cl 11. Cl Cl n.J n.J ...Il [f" ~ Cl W Lr1 --.l ~ ~ * "'''''''''''2 ~9;ga;;j ~~~~~ t"' ;:;"Ill"l'~ ;:;:~~t:l 1:'''("1>< .r l"l..,l"l ." 1:ll"l2 :: ~..,~ ~ =~~ lh ~ ~ ("1 ("1 == l"l i ~ ~ (i rn,z.;+[ [ h[f i[3:L:: ! !!.!!. i~li i . :ll ~ 1~ ~ ~ 3: i o " . !' "'.. ii\!i: ,,, ! 18: :q i~ ~i g~ -~ ~ ~ !" >< ~ 1 Jl i [ f .!!. ~ . . . I 0-)> en ""D;:; (') ~=O~.!l!o OJl)!:ya33 :.g.!l'< ~.'2. i HHii ~ "h~ l~ 11 \13 :; i!" 1l -o.-l!J 1il:n:ti[o. "IHl -<!" " a.-'~ ff~sg,i~ CD,<,g._.n 3 g~it~ e!,.' iiI. "0 -0 < ~: J ~ If' DO ~~ p ~ DO ~ii ~ - -< "Od~ pu. 'Od." 01 p.....pp. II.W uo elq'".'.IOU '1 UOII.W.OIUr AJO'".P 01 sse... l.o,eIO. .A'Inbul o. DOI~." oeqM 1I10.oe.d p.. ,dl.'''' slq,.'.s :lNYlHOdl'll 'Iraw pUB ell8l9od lUIM ISqBI x,,,.u pUB ~:JSJ&P 'pepaeu IOU 81 JdleoeJ IlBVIl PSllllJ9:) &I.U UCI )(J8~Od '8 II '6UI>tJ8W1sod 10J 801#0 lSod e~ ~8 910 -!~B 84l JUElS9Jd eS8Elld 'pSJ!sap sl Id!808J Hew P8URJ90 aLII uo )\JewlsOd ell. ..,(;91\/16(1 P9JD!ilS91:J. IUeW8SJOpu& 9l/l L/lIM eoo!dnew 941. >\JSW JD )1.1910 9tU 8S1^PV 'iu8B9 P9Z1JQ4In&' 8,88SSaJpp&' JO eaSS8JppB 841 01 P8lOf.QS8J eq ADW N9^!l8P '99.1 IBUornPP9 us 10:1. 'pOJlnbOJ 81 JdlS09J HeW pelJl,lJao JnoA uo )jJBuqsod 8sdsn 8 'ldl809J WrQ9J 8lSOlldnp 8 JOI J8^f8M 99lB 8Al8OE1J OJ. .~~ 1d\908~ Wrq8\:iM 8Oe\d\rBw esJOpU3 '&&l 91.U JeADO cq e681.sod "Iqaolldde ppe pUB elO\lJB 9l# ~ (~~9t UUO~ Sd) u:lleoe~ wnJ9H e lp8UB PUB 9181dwoo 9S89Id '9O/AI88 u:lI908l::1 wrnel:l ul1QQO OJ. 'AlEl1^lI8P JOJoOJd ap!^OJd OJ pewenbeJ aq Aewld/908l:/ wm9l:18 'e8t18UOmppl! U8 JQ:I . .ne...., pe.lSWl6~1::t JO J)9Jnsul J8PISUOO 8S881d 'sslqanl8^ JO.:l '118V\l pa!l!1JsO 1l1!M OaOIAOWd 9/ 3D'9'l:i3^QO 3:JNV'l::tnSNI ON . >lfBW IBUOjlllW&UJI JO SSUIO AU8 101 81QBI!BA& JOU SllIew P8U1:aJ9:) . 'IiIJ!BVlI ~!JO!Jd JO GIIBW sseIO-~!::f LAl"" peU!qwoo eCl ^1NO,\aW I!8W P8!1nJEtO . :$l&PUfUUJI;I JtfBUoawl 9J8911; ~ JOI 9:llhJ9S IBlsod alii ^q ld6>1 N8AII8P '0 pJOO9J '" . 9:)9!dHBW JOeA JOl J9UlIU8PI enblun V . PS Form 3800, June 200~! (ReWlrse) J(tIElO8J 6UlllBW", . :SapIAOJd 1!8W pa!lIlJa:J EXHIBIT A SENDER COMPLETE THIS SECTION . Complete ttems 1, 2, and 3, Also complete !tem 4 if Rastrlcled Delivery is desi.red. . Print your name and add...... on the reverse so that we can return the card to you. . Attach this card to the back of the mellplec&, or an the front if space permits. t. Article __ to: INTERNAL REVENUE SERVICE FEDERAL ESTATE TAX SPECIAL PROCEDURE BRANCH P.O. BOX 12051 PHILADELPHIA, PA 19105 2. AI1laIe Number (TIansfer fmm service IobeJ) , PSForm3811, Februaty2004 ",~Ice:'YP" _Mall PExpmS1I'Ili11 o Regt$tered - ~Aetum Hecelpt for Merohandlse o Insul<ld Mall 0 C.O.D. 4. Restrlcled DeIlVery? fE>ctno Feol 0 Yes 7005 0390 0002 2964 0357 10259&<1Z-M-1540 Oomestlc Return-Receipt !EXH1err A 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff .1I.TTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE (') ......, = 0 c = ." ~..... en t:.ll~;:;:; :x -l ~~l:: ;;:.. ::r:.." -' n1p I -o'm (J) .t :oy -<:-;;- Co.) c::c C~O ~c ~ ::rJ'Ti (") ::0 '--0 -". 7(") J"-""_.- orn '-- Z );! ~ N :J:.J u:> -< TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: April 28, 2005 BY: \ (\ ~'lre Attorney for , ESQUIRE laintiff EXHIBIT B 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff i COURT OF COMMON PLEAS i CIVIL DIVISION I Cumberland County 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: April 28, 2005 BY: \ f\ ~dre Attorney for , ESQUIRE laintiff I=XHISIT B Service of Process by APS International, Ltd. 1-800-328-7171 , Mortgage Electronic Registration Systems, Inc., et. aI., Plaintiff(s) vs. James E. Tschudy, et. al., Defendant(s) APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 AFFIDAVIT OF SERVICE -- Individual Service of Procelis on: -Melissa Tschundy, known heir of Kim Tschundy Court Case No. 03-6129 UDREN LAW OFFICES. P.C. Ms. Cindy Gremmel 111 Woodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 L.. St~te of~ t:f" -;;.s'i,-- ; It-v -;,.,.- - ) ss. County of: S'III 'i I) € rL ) Name of Server: GAVLL 7). (;uJ{Cu, tAlSTIt6i..f. ,undersigned, being duly sworn, deposes and says that at the time of service, s/he was over the age of !twenty-one, was not a party to this action; Date/TimeofService: thatonthe ~dayof /1M 1(. _,ZOOS-,at l?:oO o'clock PM Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: , m__-------I at 450 Buckwalter Road ,in Newpor!.PA 17~H__......_..... the undersigned served the documents described as: Notice of Sherifrs Sale of Real A true and correct copy of the aforesaid document(s) was served on: Melissa Tschundy, known heir of Kim Tschundy .._-_._~--,--_._.~_._-""_. D By personally delivering them into the hands of the person to be served. ~ By delivering them into the hands of Va /11'" td III n , a person of suitable age and discretion residing at the Place of Service, _ whose relationship to the person to be served is _ ~ -I iIJ - L-RUJ The person receiving documents is described as follows: ,. //. Sex 1!L.; Skin Color IUttl1'6 ; Hair Color _ "t/J.('f{.. ; Facial Hair rv'!!t Approx. Age $"'1 ; Approx. Height ~r'lo" Approx. Weight ;)1JcJ 9?J To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that the foregoing is true and correct. _4 ~LJ &1-- . Signa~f Server Subscribed and sworn to before me this Cf-O+aaYr~. _,ZODS:- C1ip,U' ~!'\J1\i ~~ZJ~iC~,-. ' (Date) APS International, Ltd. APS File #: 071339~OOI MYCOMMISSION FXPIRES FIRST MON Jh~! ?Q08 EXHIBITB . . Mortgage Electronic Registration The Court of Common Pleas of Systems, Inc. Cumberland County, Pennsylvania VS Writ No. 2003-6129 Civil Term James E. Tschudy; Kim D. Tschudy, Last Record Owner; Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 12,2005 at 8:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendants, to wit: James E. Tschudy Kim D. Tschudy, Last Record Owner and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, by making known unto James Tschudy, personally and adult in charge for Kim D. Tschudy and Josh Tschudy, at 138 South Locust Street aJkJa 138 Locust Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 13,2005 at 7:13 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James E. Tschudy, Kim D. Tschudy, Last Record Owner, Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, located at 138 South Locust Street a/kJa 138 Locust Street, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: James E. Tschudy Kim D. Tschudy, Last Record Owner and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, by regular mail to their last known address of 138 South Locust Street aJkJa 138 Locust Street, Camp Hill, PA 17011. These letters were mailed under the date of July 01, 2005 and never returned to the Sheriff's Office. Sworn and subscribed to before me This _ day of So Answers r~;. :-c/2-~' R. Thomas Kline: Sheriff By.Jm.... Real Estate 2005, A.D. Prothonotary ).'10 ' EXHIBIT 8 o .....' c:;::::t -=-A ? c:: W,1 [', ti) ~}: ~ -I ::l-3:l P'c.::.:. -rJ',~ i,~?,~~) ,;~~e~q .,")rn ~::'-4 'y "'"r:J '-4 L~:';j o Mortgage Electronic Registration The Court of Common Pleas of Systems, Inc. Cumberland County, Pennsylvania VS Writ No. 2003-6129 Civil Term James E. Tschudy; Kim D. Tschudy, Last Record Owner; Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 12,2005 at 8:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: James E. Tschudy Kim D. Tschudy, Last Record Owner and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, by making known unto James Tschudy, personally and adult in charge for Kim D. Tschudy and Josh Tschudy, at 138 South Locust Street a/k!a 138 Locust Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2005 at 7:13 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James E. Tschudy, Kim D. Tschudy, Last Record Owner, Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, located at 138 South Locust Street a/k!a 138 Locust Street, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: James E. Tschudy Kim D. Tschudy, Last Record Owner and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, by regular mail to their last known address of 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, P A 17011. These letters were mailed under the date of July 01, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Mileage 30.00 20.28 15.00 15.00 15.00 20.80 Prothonotary Certified Mail Postage Surcharge Postpone Sale Share of Bills Law Journal Patriot News 1.00 6.13 1.11 50.00 20.00 18.20 455.00 366.65 $1,034.17 This & ~ day of ~ ,005,A,D, ~7 Proth a ;~~~~ Sworn and subscribed to before me R. Thomas Kline, Sheriff BY ,)oritj..s~ Real Estate Sergeant I,',-<) )1)3 ClI... 'f /" ~ INt."1) I , 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address James E. Tschudy 138 South Locust Street Camphill, PA 17011 Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 :' Josh' Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federal Estate Tax Special Procedures Branch Department of Public Welfare TPL Casualty Unit Estate Recovery Building Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue Bureau of Individual Tax, Inheritance Strawberry Square, Dept. 280601, 6th Floor Harrisburg, PA 17128 P.O. Box 12051 Philadelphia, PA 19105 P.O. Box 8486, willow Oak Building Harrisburg, PA 17105-8486 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 , 7. Name and address of every 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 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 Any and All Unknown Heirs of Kim D. Tschudy, Last Record Owner 138 South Locust, a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: March 24, 2005 , 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE TO: Josh Tschudy, Known Heir of Kim D. 138 South Locust Street Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 civil OF REAL PROPERTY Tschudy, Last Record Owner Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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 Co the charges, costs and reasonable attorney1s 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. 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 ~EGA~ 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 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last' Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 03-6129 Civil Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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 attorneyls 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 wi thin 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE TO: Melissa Tschudy, Known Heir of Kim 40 Buckwalter Road Newport, PA 17074 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 civil OF REAL PROPERTY D. Tschudy, Last Record Owner Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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 , r UDRE8 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 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 $118,421.80, 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. 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 !ILL THAT CERTAIN piece or parcel of' land situata with the building a.nd improvemeMts thereon erected beinq known as Lot' No. 90 on Plan of Lots laid out for. Allen PDr.k Development corp., called cumberland Park, as recorded in Plan Book 4, Page 86, cumberland Co. Records, on the southwestarly side of Locust Street, Cumberland Park, Lower !lllen Township, Cumberl~nd County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point on the Southwestarly side of Locust street 60 feet wide, said point being at a distanca of 275 feet measured North 40 degrees 33 minutes we5t from the inte.rsection of tho. said side of Locust straet with the Northwesterly side of Locust str""t 60 faat wida, both linas produced; thenca axtending along Lot No. 89 South 49 dagrees 27 minutes West a distanca of 127.50 faat to a point; thence extending along I,ot Nos. 94 and 95 North 51 degraes 21 minutes 30 seoonds west a distance of 130.94 feet to a point; thence extending along property now or late of Robert stoner, 'North 71 degrees 57 minutes JO seconds E~st, a distance of 164.59 feet to a point in the Southwesterly side of Locust street; thence extending along the said side of Locust Street South 40 degrees 33 minutes East a distance of 65.61 feet to the place of BEGINNING. HAVING TllEREON erected a single dwelling known and numbered as 138 Locust Street. BEING KNOWN AS: 138 SOUTH LOCUST STREET A/K/A 138 LOCUST STREET CAMP HILL, (Lower Allen Township) PA 17011 PROPERTY ID NO. : 13-23-0555-057 TITLE TO SAID PREMISES IS VESTED IN JAMES E. TSCHUDY AND KIM D. TSCHUDY, HUSBAND AND WIFE BY DEED FROM ANNA GESFORD, SINGLE WOMAN DATED OS/21/93 RECORDED 06/03/93 IN DEED BOOK 136 PAGE 13. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-6129 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORPORATION, ITS SUCCESSORS AND ASSIGNS Plaintiff (s) From JAMES E. TSCHUDY, KIM D. TSCHUDY, LAST RECORD OWNER, MELISSA TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER, JOSH TSCHUDY, KNOWN HEIR OF KIM D. TSCHUDY, LAST RECORD OWNER (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 ofthe 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due $118,421.80 L.L. Interest FROM 4/17/04 TO DATE OF SALE 9/7/05 PER DIEM@25.38-$12,918.42 Atty's Comm % Due Prothy $1.00 Atty Paid $1120.80 Other Costs Plaintiff Paid Date: MARCH 30, 2005 CURTIS R. LONG (Seal) pr~tho:0 [? 77zc ~ 0 0 2::..:. r-.12 /k L~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #24 On May 05, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 138 South Locust St. alk!a 138 Locust St., Camp Hill, more fully described on Exhibit "A" , filed with this writ and by this reference incorporated herein. Date: May 05, 2005 By: ... JdJ-( j~(-t~ Real Estate Deputy @~ ~@><t gO :E 'i! g - UdV ~DDl '-J] " oJ(j /,l..-;i iV... """ ~;J.. ::.1 .:l.:l1l:l3HS Jill :~o 3~11.:H(] . 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 on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscella s Book "M", Volume 14, Page 317. COPY SALE #24 ":~=~='~~,,""'O'AO /1 PUBLICATION NOTAR UBLlC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 . Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 366.65 REAL ESTATE SALE No. 24 WrR No. 2003-6129 CMITenn Mortgage EIeclronIc Reglstretlon Systems, Inc. Vs Jsmes E. T,chUdy; Kim D. Tschduy, Last Record Owner; Mell_tschudy, Known Heir of KIm D. Tschudy, Last Record oWner; and Josh Tschudy, Known Heir of KIm D. Tschudy, Lesl Record Owner Ally: Mark Udren DESCRIPTlON ALL '!HAT CElO'AIN piece or parcel of land situate with the building and improvements there- on erected being known as Lot No. ~ on Plan of Lots laid out for Allen Park Development Corp., caJJed Cumbcrlaod M,/1S ~ in Plan Book 4. Page 86. Cumberland Co. Records, on the Southwesterly side of Locust SlRet, Cumberland PllIk, Lower Allen Township, Cumberland County, Pennsylvania,~ and describedas follows to wit BEGINNING at a Point on the Southwesterly side ofLoootStre<l oof"" wido,said poinlb<:ing at a distance of 215 feet measured North 40 degrees 33 minutes west from the inlmection of the said side of Locust Street with the Northwesterly side of Locust Street 60 feet wide, both IiDes produced; thence extending along Lot No. 89 South 49 degrees 27 minutes West a distance of 12750 feet to a point; thence extending along Lot Nos. 94 and 95 North 51 degrees 21 minutes3<Jseoonds West a distance 0( 130.94 feet to a point; thence extending along property now or late of Robert Stoner, North 71 degrees 57 minutes 30 seconds East, a distance of 164.59 feet to a point in the Southwesterly $ide of Locust Street; thence extending along the said side of Locust Street South 40 degrees 33 minutes East a distance of6SfJJ feet to !be place of BEGINNING. HAVING t:hereoo: erected a single dwelling known and numbered lIS 138 LoclJSt Street. BEING KNOWN AS: 138 Sooth Locust Stre<l o/kI. 138 Locust Street.C;omp Hill (\.ower Allen TownBhip),PA 17011. PROPllRfYID.NO; 13-23-{)555-1l57. TI1LE to said premises is vested in James E. Tschody aod lGm D. TscIJldy. husband aod ..., by lJooj _Anna Gcsfmj. single .......,daod 05121/93 -.Jed 0Ml3/93 io lJooj Boot 136 _13. 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 15, 22, 29, 2005 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. , ~~C1 ~~ / , Lis I, SWO 0 AND SUBSCRIBED before me this 29 day of Julv. 2005 NOTARIAL SEAL lOIS E. SNYDER, Nolaf'/ Public CarHsle Bora, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 24 Writ No. 2003-6129 Civil Mortgage Electronic Registration Systems Inc. vs. James E. Tschudy; Kim D. Tschduy, Last Record Owner; Melissa Tschudy. Known Heir of Kim D. Tschudy. Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Atty.: Mark Udren ALL THAT CERTAIN piece or par- cel of land situate with the building and improvements thereon erected being known as Lot No. 90 on Plan of Lots laid out for Allen Park De- velopment Corp.. called Cumberland Park, as recorded in Plan Book 4. Page 86, Cumberland Co. Records, on the Southwesterly side of Locust Street, Cumberland Park, Lower Allen Township. Cumberland County, Pennsylvania. bounded and described as follows to wit: BEGINNING at a point on the Southwesterly side of Locust Street 60 feet wide, said point being at a dis1ance of 275 feet measured North 40 degrees 33 minutes west from the intersection of tile said side of Locust Street with the Northwest- erly side of Locust Street 60 feet wide, both lines produced; thence extending along Lot No. 89 South 49 degrees 27 minutes West a diS- tance of 127.50 feet to a point; thence extending along Lot Nos. 94 and 95 North 51 degrees 21 min- utes 30 seconds West a distance of 130.94 feet 10 a point; thence ex- tending along property now or late of Robert Stoner, North 71 degrees 57 minutes 30 seconds East, a dis- tance of 164.59 feet to a point in the Southwesterly side of Locust Street; thence extending along the said side of Locust Street South 40 degrees 33 minutes East a distance of 65.61 feet to the place of BE- GINNING. HAVING THEREON erected a Single dwelling known and num- bered as 138 Locust Street. BEING KNOWN AS: 138 SOUTH LOCUST STREET. AIKIA 138 LO- CUST STREET CAMP HlLL.(Lower Allen Township) PA 17011. PROPER1Y lD NO.: 13-23-0555- 057. TITLE TO SAID PREMISES IS VESTED IN James E. Tschudy and Kim D. Tschudy, husband and wife by Deed from Arma Gesford, single woman dated OS/21/93 recorded 06/03/93 in Deed Book 136 Page 13. .. , . 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy & Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, JAMES E. TSCHUDY has filed Chapter 13 Bankruptcy in the MIDDLE District of Pennsylvania (HARRISBURG) on SEPTEMBER 6, 2005, Bankruptcy Case No. 05-05927. Mark J. U UDREN LAW OFFICES, P.C. Attorney for Plaintiff -F~ pJ4 (~, t-.') ,---r c. 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Interest From 4/17/04 to Date of Sale September 6, 2006 Ongoing Per Diem of $25.38 to actual date of sale including if sale is held at a later date / $118.421.80 V 22.156.74 Amount due (Costs to be added) $ UDREN LAW OFFICES, P.C. -p ~ ~\ \; N \1~ r -l -::; tv ~ t:~C> "p. =+- lJ VI ~ r- ~ <..)..:l v.\ -:-- v>, -- 0<:1 ~ -- ~ I$' <Jo>\ Yi- C> ..S:I -- ~ ""' ~ -:- ..s,. 0-. f) ~ -. ..s:.. 0'1' . "" 'i; -...\ C ~ 0'\. .... c- ~ <> ':) _.. <:> ~ <> -. ~ c\ ",0 --l r- :p ..I.-. f - ~ \.) - ---4 ~ .~ \~ r-.> 0 g ""n cr -l ::=: :>:'-n ~ ~~ _ :ux Q i;;~:~; ? ;cj.C) ::z: 3 rn q ~ (.rI 3: co .---- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N003-6129 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORP, ITS SUCCESSORS AND ASSIGNS Plaintiff (s) From JAMES E TSCHUDY, KIM D. TSCHUDY, LAST RECORD OWNER, MELISSA TSCHUDY AND JOSH TSCHUDY KNOWN HEIRS OF KIM D TSCHUDY LAST RECORD OWNER, 138 S. LOCUST ST., CAMP HILL P A 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 138 S. LOCUST ST., CAMP HILL PA 17011 (SEE LEGAL DESCRIPTIOM) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $118,421.80 L.L. Interest FROM 4/17/04 TO 9/6/06 @ $25.38 PER DIEM - $22,156.74 Atty's Comm % Due Prothy $1.00 Atty Paid $2,178.97 Plaintiff Paid Date: MAY 10, 2006 Other Costs Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, STE 200 CHERRY HILL NJ 08003-3620 Attorney for: PLAINNTIFF Telephone: (856) 669-5400 Supreme Court ID No. 04352 -~ \.")J\.k;..."..:~-LJU IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRiCT OF PEl'.'NSYL V ANIA INRE: JAMES E. TSCHUDY TAMMY 1. TSCHUDY, Debtor( s) : CHAPTER 13 CASE NO. 1-05-bk-05927 Household Mortgage Funding Corp. III, Movant, vs. Jamcs E. Tschudy and Tammy J. Tschudy. Debtor(s) / Respondent(s), and Charlcs J. DcHart, III, Trustee / Respondent. ORDER Upon consideration of the motion of Houschold Mortgage Funding Corp. II! to Amend Dismissal Ordcr to Includc a 180 Day Bar and In Rem Relief, and any opposition thereto, it is hercby ORDERED THAT: the February 28, 2006, Order of this Court dismissing the instant Chapter 13 Bankruptcy Case is hcreby amcndcd and thc Debtors are hereby prohibitcd from filing or re-filing a bankruptcy petition in the Middle District of Pennsylvania for a period of one hundred eighty (180) days from the datc of this Order: and it is further ORDERED THAT: the filing of any bankruptcy petition after the expiration ofthc aforesaid 180 day time period by or on behalf of Dcbtors shall not stay or prohibit Movant, or its successors and/or assigns, from proceeding with their State Court foreclosure proceedings, and/or ejcctment/possessory action proceedings, without further Order of this Court; and it is further ORDERED THAT: any automatic stay which may arise as a result of any bankruptcy casc filed by the Dcbtors in violation of the ] 80 day bar as sct forth hcrein, shall not apply to Movant or Movant's assignec(s) and shall not act as a stay of any proceedings by Movant or Movant's assignee(s). BJ' tile Cowt.. 771 ,j~ .~ I ~ JVd /lO.11t9- Banlirop~Jullge (EW) Dated: March 20. 2006 This electronic order is SIgned and filed on the same date. (, ,1 MARK J. UDREN & ASSOCIATES BY: M~rk J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration: Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County : NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Defendant(s) AND NOW, this 3("d Da~ :fD ~bru..o..rl/ ,2DO~ ,upon consideration of Plaintiff's Motion For servJJe Pursuant To Special Order Of Court, and any response thereto, it is hereby ORDERED AND TRU::: Cr)py fROM p.r:C:~RD In 1:si',mo~'I Vlnereo:, i he,,' lI:no,d my hand ilnd scal of said Court :LCaes1e, Pa. W H".o..~... clf.J;:~.u...... . L J~. Piot\lonotary DECREED that Service of the Complaint In Mortgage Foreclosure on Kim D. Tschudy, Last Record Owner, and upon any and all Unknown Heirs of Kim D. Tschudy, Last Record Owner shall be complete when Plaintiff or its counselor agent has published in accordance with Pa.R.C.P. 43D (b) (1) a Notice of the action once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service of all subsequent pleadings that require personal service, including, inter alia, the Notice of Sheriff's Sale, . shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, PA 17011, which is the subject matter of this action in mortgage foreclosure. BY THE COURT: 16/ ~ 8 !3pJf 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 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. ark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF (') ...., 0 "" (: c=> 11 CT' -":.'\1..', - ~ ~ j"";"'lr; :rr rn::!J ;? -< r- 2: -Om U,', c:> :Xl,? .. (.:J -\ ~-::: '., :::;j~:;::\ '\';> =-"'!'" ;S"(' ;"..-< ::ro: "C") .,. is (Srn -\ ". U1 ~ CP --~----- 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, (Lower Allen Township), Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s) Name Address James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camphill, PA 17011 138 South Locust Street a/k/a 138 Locust Street Camphill, PA 17011 450 Buckwalter Road Newport, PA 17074 Josh Tschudy, Known Heir of Kim D. Tschudy, Laqt Record Owner 138 South Locust Street Camphill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name a record Name and address of every judgment creditor lien on the real property to be sold: Address whose judgment is none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Commonwealth of PA Inheritance Bureau of Individual Tax, Tax Division, 6th Floor, Strawberry Square, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax, Special Procedures Branch, PO BOX 12051 Phila., PA 19105 Dept. Of Public Welfare TPL Casulty Unit, Estate Recovery Program, PO BOX 8486, willow Oak Bldg., Harrisburg, PA 17105-8486 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 has knowledge who has any interest affected by the sale: Name person of whom the plaintiff in the property which may be Address Tenants/Occupants 138 South Locust Street a/k/a 138 Locust Street (Lower Allen Township) Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relatin to unsworn falsification to authorities. DATED: April 18, 2006 Ma J. Udren, ESQ. Attorney for Plaintiff 0 ...., = 0 '0: ,-", -n 0"' ;:.':~ 2: -t I ;i;:.'''' :r:" rl1-- -< -Om <=> :0'1' ~~1~_.J ~ \]#1 C3 C) III > {fl :." CD .< ... UDREN LAW OFFICES, P.C.ATTORNEY FOR PLAINTIFF 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 Mortgage Electronic Registration Systems, Inc., its successors and ass~gns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff j COURT OF COMMON PLEAS 1 CIVIL DIVISION I Cumberland County , FORECLOSURE v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 03-6129 Civil Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 Sheriffrs 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. l. 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 full amount due in the sale. 856.482-6900. through only if the buyer pays the Sheriff the To find out if this has happened, you may call 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 FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 0 ...., = 0 c = '1' .' C" i";' == ::;j :1;;.. fn~ -< vm 0 :pc;:' ':'7?(~ L_ "'" ~.~~~ - ~ 6 ~, ~, .;0' (J1 :xl C) .< ,. ..... 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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: l. 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. ~U MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE vi. 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. 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. the full amount due is At that time, the 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 o c: ::''''' ,-.:;:,= ...., = (:;;:J "'" ..... ;;; -< o --r1 :r_ n1~l..! -oFn :rJCfi (~C) (~=n ;70 cjm "'.'i :?- ,D .< o ~ :J:: '? U1 0:> 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 Mortgage Electronic Registration Systems, Inc., its successors and ass~gns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: All and Any Unknown Heirs of Kim D. Schudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, ( Lower Allen Township) PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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) 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 SH~RIFF'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 FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 r-.> = c.:;:) ,,~ (:.. (::. ::::r -< Q, ~..,., rn-- -vEt - r-~ 0..,..- :-'::';'j.. ~~'f)] ~C ..,1 ~~)~ 0.-. ::.:\ 'J=E :-< ::<: po ...-< - c:> ~ U1 c::> James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF TO: Melissa Tschudy, Known Heir of Kim Owner 40 Buckwalter Road Newport, PA 17074 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. ~-~4302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Sys~ems, Inc., its successors and ass~gns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6129 Civil REAL PROPERTY D. Tschudy, Last Record 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 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 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- YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IP 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. 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. the full amount due is At that time, the 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 0 ,..., 0 = C~ C.::::l " ,.,-. " ;:J1.: ::;l ;r- m:J:) -< -oM ;;)0 c:> :":),.1., ~.)~r', = ~~J 25 ::>: '2 orn ---I <.n 55 co -< ------------- UDREN LAW OFFICES, P.C. ~Y: 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 Mortgage Electronic Registration Systems, Inc., its successors and ass~gns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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- ./ ?aU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. l. 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. amount due 6900. The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-482- 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 .- 0 ....., 0 "'" ~. c;;:;, 11 '-'" - -t "(J rr' -""" ff\FJ IT', r1"1 ;p> ,._/ -< -UE;3 (~' C> :r) ~;2_(:) , --c."'r, . """ {.~~S :J!: )..:" ( C5 Om ..-\ ~;'2 <.n c;5 (Xl :< \ 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE TO THE PROTHONOTARY: PROOF OF SERVICE Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: August 31, 2006 BY, ~ Mark . Ud , Esquire Attorney for Plaintiff ... I Mortgage Electronic Registration Systems, Inc., et. al., Plaintiff(s) ... \'s. James E. Tschudy, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 078426-0001 AFFIDA VIT OF SERVICE -- Individual Iu ,DREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Suite 200 . ..1 Cbury U;~ NJ ~.~362~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . State of: h If/A/J';'L- V/JVltt ) ss. County of: 5.(} If'/l.tL_--.J Name of Server: 'I'i~'-i D. CnAlF~/L.. IAJ,f1IHJ{..f., , undersigned, being duly sworn, deposes and says , that at the time of service, slhe was of legal age and was not a party to this action; U.A ---./o--A Date/Time of Service: that on the ......z...:day of NV vl/Jr , 20o...k..., at j 'T~ o'clock LM Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: Service of Process on: --Melissa Tschudy, known heir of Kim D. Tschudy Court Case No. 03-6129-Civil at 40 Buckwalter Road , In Newport, PA 17074 the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Melissa Tschudy, known heir of Kim D. Tschudy mEL. IS JI1 ISC 1ft/Dr "'#Ilt D By personally delivering them into the hands of the person to be served. , Ifi By delivering them into the hands of "'JPLs Will n , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Melissa Tschudy, known heir of Kim D. Tschudy at the place of service, and whose relationship to the person is: flus lJA.c/e) The person receiving documents is described as follows: Sex /!:L; Skin Color ilJ#I Tt ; Hair Color f}~J ~ ; Facial Hair Approx. Age 3,;L ; Approx. Height SII4' ; Approx. Weight 11S- ~ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that the regoing is true and correct. to before me this , 20<Xo APS International, Ltd. Jla.. &......., MrVlfl_....~ DtItItot l J~ ~ Countf* ~Ie Commllllon .',.. "'nIMfY ,: i8i ~ .. "" f' - . Mortgage Electronic Registration Systems, Inc., et. al., Plaintiff(s) " '" . 'vs. James E. Tschudy, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 078541-0001 AFFIDA VIT OF SERVICE -- Individual r-- --.------.--------.--- ---.--------~-------'-~~-~--~-~ I Service of Process on: UDREN LAW OFFICES -Josh Tschudy Court Case No. 03-6129-Civil Ms. Henni Crommarty 111 W oodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 I L..___ ----- ~~:~r~~~~~ ('1\. (Y)',c..Y'\e..\ ~-@ r~u.y ton...., undersigned, being duly sworn, deposes and says that at the time of service, slbe was of legal age and was not a party to this action; Daterrime of Service: that on the 1 'a.t~daY ofP~u.S\- , 20~, at ~: ~~o'c1ock P M Name of Server: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Recching Documents: Signature of Server: J - - - - -- - - - at 446 Bi2 Sprin2 Road , In New Cumberland, PA 17070 the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Josh Tschudy ~ By personally delivering them into the hands of the person to be served. o By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Josh Tschudy at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sexffi....; SkinColorwh'\-\-e.. ; HairCoiord\t\.i ~M.c\; FacialHair Approx. Age d Lo ; Approx. Height ~ \ ~ " ; Approx. Weight \ 7:J) o To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. APS International, Ltd. ubIic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Tammie L. Peters, Notary Public South Middleton Twp., Cumberland County My Commission Expires Sept 9. 2007 ['\"",(h?r. Pennsylvania Association Of Notaries f'..> (J', r'''',j C:"::) L.;:,:;) <:::1'0 C.') '. ~_.j . , -~-V I C-j Co.) o "f} :::::J ;-1';21 c:: , " r::.: L c.) , " '~:::f b: :::0 -< 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. James E. Tschudy Kim D. Tschudy, Last Record NO. 03-6129 Civil Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff'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 liB". 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". This Affidavit is made subject to relating to unsworn falsification 4904 All Notices were served within 3129. Dated: September 29, 2006 BY: Mark J. Udren, Esqulre 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/ a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address James E. Tschudy 138 South Locust Street Camphill, PA 17011 Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Twp) PA 17011 450 Buckwalter Road Newport, PA 17074 446 Big Spring Road New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Commonweal th of PA Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federal Estate Tax Special Procedures Branch Department of Public Welfare TPL Casualty Unit Estate Recovery Building Address Bureau of Individual Tax, Inheritance Strawberry Square, Dept. 280601, 6th Floor, Harrisburg, PA 17128 P.O. Box 12051 Philadelphia, PA 19105 P.O. Box 8486, Willow Oak Building Harrisburg, FA 17105-8486 Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 PA Department of Revenue Bureau of Compliance, P.O. 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 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Twp) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal know edge or information and belief. I understand that false stateme t her in are made subject to the penalties of 18 Pa.C.S. s c. 49 4 lating to unsworn falsification to authorities. DATED: September 29, 2006 Mark J. Udren, Esquire Attorney for plaintiff 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 PLAIN'l'LJ.<'J.<' Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D.Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) DATE: April 18, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record OWner PROPERTY: 138 South Locust Street a/k/a 138 Locust Street (Lower Allen Township) Camp Hill, PA 17011 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 Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A (IJ . CD = i.e:iS ::I ~.!! 1:5 it; go -'ill I E'- ~'5t E.CDCi t~! lSt:"O ~!i ...d* .i cD u. r! . CD <;)' 0:; CD ~ 0::: u.. 1 ~o l~~ ~ ::1- Q;,O ~~ .e g ~~ is !l!!- o C::l :is l!!l!~. t~ ~ i ~i e:E is. ~ =- ila.l 1l!!!r~ .c ~DD ~ CD 00::: .,.c J:O .e "is _0 .9- i= 1_'Ei i ~ ~ ~i u. ::I cO:::... li~! D~ 00 CD CD -! o Q. ~ -i i. i.58~ o:::~oo tIl DODD e "0 ~ ! ~ 1ii o Q. "0 C CD a: ~ S z i w 0 o > ~iQI ftiOc(~ ~~i~ H:gtiz O...lt!!::i ~mS~ Zsii !j8-~ ~~::o & 'g=~ i!~ ~'C~ GII~_ Z 0 I (IJ u.~ - ., ~i ~o::: 0:: :Ii .12 fll!!t ihlll !ifl!: 11I11~ i .. .,~g 11. .I~.t.~.t.. r,a j-i IJj'i..l.i Ill.!) h~41 111111 it~ ~til.. J! 11'215 ! 15. ~ ~15iif Hilli i~I.:lj , ~~ -I : : :r* uju. 'C' . .\ <Jt. "- c; \'. '~'.:i~~< . iT.~~';J4 'lj'jj It:U;.~,.r...'.;:~~,./;' ftlr z...~.. t~~'~ "';'-i,b~t,90\-,9~' \1 Z4r- .~.-. ~~';~;~~1n~~:/.t.~>:~~, f;~-;".-, "ry,",-""'>" .., : f Q:: l5 ~ ~ I Q. ~ - .<<>>< 0 li: 0::: q ~CL >< ci w ~ CL ~..i ~ en 9 e~o w<= W .~ m ~o ~ oo....z 0 ::> w~ ~ ~ i: ~ ~ ..(1) D..~ ~ .,.: .0 ~.'~ ~ g: z ~ ',;j;t;. . !;; Ii wg 8 1;).~ < ~ Cf)::E N::::l ....;0.... W ~ ~ - 0 t: 0 -~ W.N o:::.~..... .... ffi!!2 ~ 0- 9 2l:L CLlC( z~ ::J.... - I.L<. -w ~CL :):>1 w~ t)S OCL~ (l)z ~o 0 -: ~Ii I 0:::0 wt: ::::l.e) ~.~ ....0 .~.~:;;i:; ~ ~.~ ii ii .~..~ i~~~~ii~~ I :)::::l 0 ~ ID- ;cWI.La:: - <1(.... o D..... ~ 8.fA. ~"!2 Gf.'~ ~... "~ .~...tH. ~ ~~ n......~~ J ~.~.~ ..~ ~ z~ 8 ~a1!i ~~~CL i '0 ~5 00 o~ ~ti~....:)I3CL fi:~:) ~ ffi ~ti""-li: ~....ti I.L eD~m Q ~~ ~m ~ i~ ~ .~!~ i:) E ~ ii~ ~~ t;:8 ~ 50 e t; g: ~ ~ 9 ~ 070 ~ g;; m ~ ~ :J: i"' J Q~ ~ /C'~ I.!~ ._~ i! \- :t ::I"i C$ =.~ 'C"" ~~ ~ I-tt: ~ ,Q CD U. (IJ - Ql I ~ CIO 8 ~ 0::: 0:... 0 CJ) w 0 ".a ;:) I o~ ~E:J: i N IDe Z - Ii \' ::10 0 ~ :Ez Z zeD Cf) 55 W .aCfJ .... 0 0 :J: E;>. ::1.0 CD ~'i c 0 .... N ~ ~ ." o:!! ::J ...... N ~ ~ ." co ,.... co en .... .... .... .... .... .... 1--' EXHIBIT A c t) A. 1: "0 A. i .. o M: .5 . i 0- ~ ~ .a " ! a 8 (.) .! 1 :IE E ti. ~ ~ 8 u. en a. ~ \J\ ~ ~ o Oc o~oc ::I:~~ift gJ~mz :xJ8~~ :t:Oo~ ;=0::00 ,:IJ"" . mo" t:~:no O::D~m coo--.cn c,:;) m - 0>0"'0 wOmb z- nI :D "tI"tI(I).,..... ~o'alDa Qlo IDAID Q,OJ!lID... lDOIII;= 'O"x--cu ~ " - _.........::~ .!1' ~ 0 ... ID ~~ii= ..... c ~c \0 ;CUID ..... .><(1) o lID ID 01 '-r ~ III _ :I n n ID =- I I I , I I I Ii: w' g~, " ~~'-~ ~WI-== O~'r9' I- c , _...... ~!;tl~ -lCI~ W..J >o,~ Zu. Wen-.I; ~~I~ D..a:I~ Sgl~ ~i'~ a: a: , ..... ~~I~ ga:'... en wi..... ~~,r ... :"i ~ , ....., n. , I I I , I I I ~, ~.~ / ~.'j ;:;<,i , ~::- ~J :n ! ~ i '- '/;~ ~.'^//;, . ,7~~f:J.S:'2~;~' , ' ~--~ ;::-~}~ ';I ;[i";:~, i "-~,, '."- ~',;~~~?i:l'l:J 1" ~ ift.:':' "I : m '. !., lH ,-<~',2 ;';'*If-~'fJt~It".ltlf.;i 0 0 cO I:Q ..D ..D m m rn m LJ1 LJ1 IT' IT' M M ru ru 0 0 0 0 0 0 010 M1M MM m m LJ1 Lt'J o! 0 0 0 ('- ("- U.S. Postal Service CERTIFIED MAIL RECEIPT (DomestIc Mall Only; No Insurance Coverage ProvIded) OFFICIAL USE Postage $ Postmark Here Certified Fee Retum Receipt Fee (Endoraement Required) Restricted Delivery Fee (Endoraement Required) Total Postage & Fees $ o INTERNAL REVENUE SERVICE ==::; =l ==J..~S BRAMCH .-------------- Chy,Biai.;;ZiP+P .o.1IOX 12851 PHILADELPHIA, PA 19105 PS Form ~)8lJl ~Junl )1 )1' flf )( I (I ! H 1'-L'r:tIOTl~ EXHIBIT A ~97/ --r -x)wndy "tI en ~ =- . . . " ~~ ~ ~)>~~S=O 0 g~g:a3~ 3 0 CIl CD CD U) ~z ,,"ID"I1% ~ g: ::T a '< .r::.. "2. .....~o::;;!!. (X) ~l :t' "am.... Q. CD~ ~::DCD ..... -Pmcm I gcnCD~I::a: ..... !; ad:! m ;0 - ! "' a[~~~~ " co:.,.~ CD ::;; CDaUJ g- fl m><........ ~ ~ 5~~!.~ c: .... ..... .'11 m .... III f ~~;oen:D 1llg:3a.o,l') -< ~~8;;!~ gCDg:~I:~ I\) 't:lflCDa.;ia. 0 0 " m-lz ~oo;-<Co) ~ ,. emc "Illf: . ..... c-lm s:s.aoCE~ CD ~ten " .....a-~ 0.8 ..... ::T .....1 C) en m CD '< ::T-. 8 "\J c.n III :D i ~ ~ ~-5 CJ :a < 0 . (; -0 < - 0 CJ f CD !!. 3 In Z m i CD CD 0 !!. ::E: o' UJ J:l I:..J !t I:..J E; CJ ::I ~ P PJ >< ~ :D .,{ CJ J:l oori =:fij :D (J) i -(Q. ~ US" CJ ~l n mil. ::l 'S CJ ! a a 1:_ CD - < I: ru ! !I~i !!j~ iiI I:..J 0 ~~ ~ t Q.Q. -.. ..D @l, ~ ~m ~ In ::J UJ CD Q. ~ i Dip if UJ P~tp ~ D"'" l Pl:j I a' .!!. [):I P3 CJ ~ If i3 ~f P ~ ~ ~ g- o 0 DO a 00 lB 3: CD (JI 'ii ~ ~t So i!r~ 6 N CIl :T ~ Q.!!j * ~ i - ~ Q. < f CD -< . . f' . 'IOd:l pue IOdV 01 pesseJpp. lIew uo elqlUIAe IOU II UOIIIWJOIUI ueAllep 01 III:>>:>>e lewelUI 01l10lluI ue DUIJleW ueqMlIlUeleJIl PUlldlUeJ Ilql 8AIS :J.NVlHOdlMl "lfSW pue e68Isod lAIM 18q81 xme pue lP8I8P 'pepeeu IOU SI JdI808J '18W P8YAJ80 9:\D uo)U9W18()d 11 II "6upt.l9W18Od JOJ 8OYJO lsod 8\D ~ ep -AJ8 8LIJ lUeseJd 8S88ld 'pe.;'S8P S! IdleoeJ 'I8W p81JAJ90 9LIJ UO )!J'8w1SOd 11 II . ".N9AJl8ClJJ9PfJlS9lJ. JU8wesJopue 81U lQIM El:)8td&rew 8lIlIJ8W JO )!J91O 8\D 88\^PV "~ peZlJOlUlle s,88898JPP'8 JO eesseJppe 9LIJ OJ peJ:)J.qSeJ eq MtW AMMtI8P '881 19Uomppe U8 JO~. 'peJlnbeJ S! JdIe:l8J uew peygJeO JnM uo ~ 8Sdsn e '\d\909.l WI1J8J ~llCinp e JOJJ9^f8M 9818 8AI908.l o~ "~Jd!8081::1 WrtI81::1 ~ esJOpU3 "981 8\D JeAOO OJ e6eJsOd ~ pp9 pue 8PIPll~ la.a.9& uuo~ Sd) ~l::l ~~:=:r: ::JenbeJ ~e::::l:I Wrn9l:1~"t8~J=~ U81~ . "118W p818IS!6eH JO pelR8U1 J8PISUOO en8\d 'S8ICI8nJ'811 JO~ ".fSW P9ImlBO 11IM 0301^Otld SI 3E)W3J\OO 30NVl::lnSNI ON · "1!8W I'8UOII8W8IUI ,0 SS8IO ~U8 JOJ 91Q81!8A81OU 81118W P8YRJr.> . "8i\8W AwoIJd JO 4lltJ11W SS810"J9.11:1 tmM p8U!QWC)O eq ^1NO A8w 1\8W pe~ . :..",,'UItII:IIU-wUII SJ8eJ; OMI.IOJ 80fAIes I'8JSOd etn,tq _ NMllep JO pJooeJ V . 808Iduew.JfIOA JOI J8fJDU9PI enblun V . PS Form 3800 J 2002 'RtMne' JdleoeJ 6ulIJ11W V · . une t' 1 :sePIAOJd IIIIM '8Ylpe:) EXHIBIT 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 mailpiece, or on the front If space permits. 1. Article Addressed to: INTERNAL REVENUE SERVICE FEDERAL ESTATE TAX SPE~ PROCEDURES BRANCH P.O. BOX 12051 PHI~ELPHIA, PA 19105 "- , ~ce Type ~ertified Mail 0 Express Mail o Registered ~tum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes '-42. Article Number (fransfer from service label) PS Form 3811, February 2004 7005 3110 0002 1953 3680 Domestic Return Receipt 10259S-02.M-1540, EXHIBIT A Mortgage Electronic Registration The Court of Common Pleas of Systems, Inc. Cumberland County, Pennsylvania VS Writ No. 2003-6129 Civil Term James E. Tschudy; Kim D. Tschudy, Last Record Owner; Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2006 at 8:53 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: James E. Tschudy, known heir of Kim D. Tschudy, Last Record Owner, by making known unto James Tschudy, personally and adult in charge for Kim D. Tschudy, at 138 South Locust Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Josh Tschudy, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale, and Description as NOT FOUND, as to the defendant, Josh Tschudy. Josh Tschudy no longer lives at 138 South Locust Street, Camp Hill, Pennsylvania, 17011. His current known address is located at 446 Big Spring Road, New Cumberland, York County. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 5:50 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Kim D. Tschudy, Last Record Owner, by making known by posting the premises pursuant to order of the court at 138 South Locust Street, Camp Hill, Cumberland County, Pennsylvania. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 5:50 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James E. Tschudy, Kim D. Tschudy, Last Record Owner, Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, located at 138 South Locust Street, Camp Hill, Pennsylvania, 17011 according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: James E. Tschudy, Known heir of Kim D. Tschudy, Last Record Owner and Kim D. Tschudy, Last Record Owner by regular mail to their last known EXHIBIT B address of 138 South Locust Street, Camp Hill, P A 17011. These letters were 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 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: Josh Tschudy, Known Heir of Kim D. by regular mail to his last mown address of 446 Big Spring Road, New Cumberland, P A. This letter was mailed under the date of July 14, 2006 and never returned to the Sheriffs Office. SO~A~ ~., r-~~~~~.< R. Thomas Kline, Sheriff Bys)~~L Real Esta Sergeant EXHIBIT 8 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s} PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: o r- ':0.., r-..:J C.) CT"\ o -'1 ::;! I ; 71 :I"! (/) r-;c; v I en -0 ~~~\~ c.) f0 (i-~ Kindly file the attached Proofs of Service with regard to the captioned matter. Date: August 31, 2006 UDREN LAW OFFICES, P.C. BY: ~ Mark . Ud n, Esquire Attorney for Plaintiff EXHIBIT B 'P 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6129 Civil v. James E. Tschudy Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) PRAECIPE TO FILE TO THE PROTHONOTARY: PROOF OF SERVICE Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: August 31, 2006 BY: ~ Mark . Ud n, Esquire Attorney for Plaintiff EXHIBIT B Service of Process by APS International, Ltd. 1-800-328-7171 Mortgage E~ectronic Registration Systems, Inc., et. al., Plaintiff{s) \s. James E. Tschudy, et. al., Defendant{s) APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 078426-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Melissa Tschudy, known heir of Kim D. Tschudy Court Case No. 03-6129-Civil UDREN LAW OFFICES Ms. Henni Crommarty 111 W oodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 State of: AA/A.l5vt."IIJ~/it ) SSe County of: 5I(Jy"t~_~ Name of Server: 'ItYt.i lJ. CaAlFe R-. ~JfT"'i1LL , undersigned, being duly sworn, deposes and says / that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the ~daY of J4v~~Jr , 200 ~ , at :;;~~'clock r'M Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: at 40 Buckwalter Road , m Newport, PA 17074 the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Melissa Tschudy, known heir of Kim D. Tschudy mE L j SJIt IS (1--1" j) Y kith 1z o By personally delivering them into the hands of the person to be served. I ~ By delivering them into the hands of /1~( j' tuff; n , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Melissa Tschudy, known heir of Kim D. Tschudy at the place of service, and whose relationship to the person is: Hu5/JI1,vP The person receiving documents is described as follows: Sex J1:L; Skin Color klll/Tt ; Hair Color 1?~) ~ ; Facial Hair Approx. Age :?.:L ; Approx.Height fl/~ ; Approx. Weight /1S- ~ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that the regoing is true and correct. to before me this , 20<'Xo APS International, Ltd. Jl.~.~ L t_., -. Jl~ *I......~ DtIMot 'N:41I ~ Coufttv, ~Ate Conmlalon bpi,.. JI'UMIY I: ~l, EXHIBIT B . Service of Process by APS International, Ltd. 1-800-328-7171 Mortgage Electronic Registration Systems, Inc., et. at, Plalntiff(s) vs. James E. Tschudy, et. aI., Defendant(s) ,--'-.--'--- ----. I UDREN LAW OFFICES I I I i ~~:::~~~l~~ - .. - - - - - - - - - - - - - - - ... - - - .. - - - - - - ff\. ('f\\c.Y'\~\te r~U.'1 ~, undersigned, being duly sworn, deposes and says that at the time of service, slhe was of legal age and was not a party to this action; Date/Time of Service: that on the 1 ~ ~daY ofp, GlAS\- ,20 DJQ.., at ~ ~ 3tSo'clock P M APS International Plaza 7800 GIenroy Rd. Minneapolis, MN 55439-3122 APS File #: 078541-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Josh Tschudy Court Case No. 03-6129-Civil Ms. Henni Crommarty 111 Woodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 Name of Server: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Recei\ing DoeuIDcnt5: Signature of Server: at 446 Bi2 Sprin2 Road ,in New Cumberland, PA 17070 the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property A true and correct copy of the aforesaid document( s) was served on: Josh Tschudy ~ By personally delivering them into the hands of the person to be served. o By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Josh Tschudy at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex m....; Skin Color 1J.'")h'\ -\e.. ; Hair Color{\, C-\.i ~Oi\c\; Facial Hair Approx. Age rilo ; Approx. Height 5\ <"6 ,. ; Approx. Weight \ ~) o To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. APS International, Ltd. ry Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Tammie L. Peters, Notal)' Public South Middleton Twp., Cumberland County My Commission Expires Sept 9, 2007 i\!\,,"\t1t~r. Pennsylvania Association Of Notaries EXHIBIT B r-) ~~~ ,,^, c.::;:: ;:;~ C'J () -.. () "n ---t I-n Iflp -o~_l.~ ~~~ ',.c;' () ~:'i"Tl _:.~, .~ r- .... ~l~ co r'""t~,' -..l 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 Household Fin Corp Nominee is the grantee the same having been sold to said grantee on the 4th day of Oct A.D., 2006, under and by virtue of a writ Execution issued on the 10th day of Mav, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 6129, at the suit of Household Fin Corp Nominee against James E Tschudy. Kim D.Melissa.Josh is duly recorded in Deed Book No. 278, Page 775. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,,1/ ~'- ,A.D. ;20-0(;. day of ~l~ Recorder of Deeds ~oIDetGa. ~ My~e..,"'FiIt~'~PA .....af__ Mortgage Electronic Registration The Court of Common Pleas of Systems, Inc. Cumberland County, Pennsylvania VS Writ No. 2003-6129 Civil Term James E. Tschudy; Kim D. Tschudy, Last Record Owner; Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner; and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2006 at 8:53 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: James E. Tschudy, known heir of Kim D. Tschudy, Last Record Owner, by making known unto James Tschudy, personally and adult in charge for Kim D. Tschudy, at 138 South Locust Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Josh Tschudy, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale, and Description as NOT FOUND, as to the defendant, Josh Tschudy. Josh Tschudy no longer lives at 138 South Locust Street, Camp Hill, Pennsylvania, 17011. His current known address is located at 446 Big Spring Road, New Cumberland, York County. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 5:50 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Kim D. Tschudy, Last Record Owner, by making known by posting the premises pursuant to order of the court at 138 South Locust Street, Camp Hill, Cumberland County, Pennsylvania. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 5:50 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James E. Tschudy, Kim D. Tschudy, Last Record Owner, Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, and Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner, located at 138 South Locust Street, Camp Hill, Pennsylvania, 17011 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 defendants, to wit: James E. Tschudy, Known heir of Kim D. Tschudy, Last Record Owner and Kim D. Tschudy, Last Record Owner by regular mail to their last known address of 138 South Locust Street, Camp Hill, P A 17011. These letters were 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 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: Josh Tschudy, Known Heir of Kim D. by regular mail to his last known address of 446 Big Spring Road, New Cumberland, P A. 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 ec:rohe.r C'lJ2006 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to attorney Mark J. Udren on behalf of Household Mortgage Funding Corporation III. It being the highest bid and best price received for the same, Household Mortgage Funding Corporation III of636 Grand Regency Blvd, Brandon, FL 33510, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$1,118.71. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Prothonotary Mileage Levy Surcharge Posting Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed So Answers: 30.00 21.92 15.00 15.00 30.00 10.00 1.00 23.78 15.00 40.00 6.00 20.00 437.00 369.20 19.31 25.00 '" 40.50 /0 $1,118.71./ \/\V ~ .~~,~~ R. Thomas Kline, Sheriff" BY "J~~^Arl-l) Real Estate rgeant L __ JeJ ().cP q 00 ., 3~' 00 10\6 \. 6lP1 t{ott C.~tff 1&1 ~ ~ ,'UDREN LAW OFFICES, P.C. ~Y: Mark J. Udren, Esquire ~ r' ATTY I.D. NO. 04302 ~ WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns, 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: 138 South Locust Street a/k/a 138 Locust Street, (Lower Allen Township), Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address James E. Tschudy 138 South Locust Street Camphill, PA 17011 Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camphill, PA 17011 Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 450 Buckwalter Road Newport, PA 17074 Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Ca~hill, PA 17011 ./ 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Commonwealth of PA Inheritance Bureau of Individual Tax, Tax Division, 6th Floor, Strawberry Square, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax, Special Procedures Branch, PO BOX 12051 Phila., PA 19105 Dept. Of Public Welfare TPL Casulty Unit, Estate Recovery Program, PO BOX 8486, willow Oak Bldg., Harrisburg, PA 17105-8486 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 OS :l d L I ^ VW qOOZ 'Jd ')'lrHiu..J ,j;\~'HjjdWn:J .:.UIl:l3HS 3Hl .:10 3JL-i.:W , .UDREN ~W OF!ICES, 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION. Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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- ~ . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S S~LE 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 OS :(: d L I A VH qOOZ \/d f;~lt,~f tU..j t; H.'J: t ::J J8Wf 'j ~J .::idIH3HS 3H1 JO 3:JU.:lO I I , UD~EN LAW OFFICES, P.C.ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc., its successors and ass1gns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Tschudy 138 South Locust Street Camp Hill, PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlislel PAl to enforce the court judgment of $118,421.801 obtained by Plaintiff above (the mortgagee) against you. If the sale is postponedl 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 payme 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 Cou to strike or open the judgment, if the judgment was improperly ente! 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 proceedir You may need an attorney to assert your rights. The sooner you co' one, the more chance you will have of stopping the sale. (See not 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 S~LE 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 DOT 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 OS :2 d L I A VH qOOl '\I'd 'AHillC-.i U,:, ,!,J::J8HnJ j.:J!H3HS 3Hl .::10 381.:UO j. j. ,.UDREN LAW OPFICES, 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 Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. James E. Tschudy NO. 03-6129 Civil Kim D. Tschudy, Last Record Owner Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner 138 South Locust Street Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim D. Tschudy, Last Record Owner 138 South Locust Street a/k/a 138 Locust Street Camp Hill, (Lower Allen Township) PA 17011 Your house (real estate) at 138 South Locust Street a/k/a 138 Locust Street, Camp Hill, (Lower Allen Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 9, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,421.80, 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. ~ r YOU KAY 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 FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 OS :Z d L I AVW qOOZ \!d 'All-Ii PJ" 'r\J]8WitJ .::l.:lIB3HS 3Hl .:10 3JI.:I.:I0 .. . 1\LL TH1\T CERT1}IN piece or parcel of" land situate. with the buildIng and improV'ements thereon erected being known as Lot' No. 90 on Plan of Lots laid out for Allen Park Development corp., called Cumb~rland Park, as recorded in Plan Book ~, puge 86, Cumberland Co. Records, on the Southwesterly side of Locust street, Cumberland Park, Lower i\llen Township, Cumber.1.;:,md County, Pennsylvania, bounded and described as fo~lows to wit: BEGINNING at a point on the Sout11\olesterly side of Locust street 60 feet wide, said point being at a distance of 275 feet measured North ~o degrees JJ minutes west from the intersection of the said side of Locust strget with the. Northwesterly side of Locust street 60 feet wide, both lines produced; thence. extending ~long Lot No. 89 South 49 degree~ 27 minutes West a distance of ::'27.50 feet to 01 point; t.henc~ <;!xt':mding along Lot Nos. 94 and 95 North Sl d~areeG 21 minutes 30 ~econds West a distance of 130.94 feet to a p;int; thence extending along property now or late of Robert stoner, North 71 degrees 57 minutes 30 seconds E~st, a distance of 164.59 feet to a point in the Southwesterly side or Locust street; thence extending along the said side of Locust street South ~o degrees 33 minutes East a distance of 65.61 feet to the place of BEGINNING. HAVING THEREON erected a single dwelling known and numbered as 138 Locust Street. BEING KNOWN AS: 138 SOUTH LOCUST STREET A/K/A 138 LOCUST STREET (Lower Allen Township) CAMP HILL, PA 17011 PROPERTY ID NO.: 13-23-0555-057 TITLE TO SAID PREMISES IS VESTED IN JAMES E. TSCHUDY AND KIM D. TSCHUDY (DECEASED), HUSBAND AND WIFE BY DEED FROM ANNA GESFORD, SINGLE WOMAN,' DATED 5/21/931 RECORDED 6/3/931 IN DEED BOOK 136, PAGE 13. . . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) N003-6129 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR HOUSEHOLD FINANCE CORP, ITS SUCCESSORS AND ASSIGNS Plaintiff (s) From JAMES E TSCHUDY, KIM D. TSCHUDY, LAST RECORD OWNER, MELISSA TSCHUDY AND JOSH TSCHUDY KNOWN HEIRS OF KIM D TSCHUDY LAST RECORD OWNER, 138 S. LOCUST ST., CAMP HILL PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 138 S. LOCUST ST., CAMP HILL PA 17011 (SEE LEGAL DESCRIPTIOM) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $118,421.80 L.L. Interest FROM 4/17/04 TO 9/6/06 @ $25.38 PER DIEM - $22,156.74 Atty's Comm % Due Prothy $1.00 Atty Paid $2,178.97 Plaintiff Paid Date: MAY 10, 2006 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, STE 200 CHERRY HILL NJ 08003-3620 Attorney for: PLAINNTIFF Telephone: (856) 669-5400 Supreme Court ill No. 04352 Real Estate Sale # 33 On May 30, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A M!J ~ a:::::'I ~ ~ (~~ Known and numbered as 138 South Locust St. a/k/a 138 Locust St., Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 30, 2006 By: Jo ckr ~I:t, Real Estate Sergeant b t1 :l d L I ~ VW qOOl Vd 'AH~\lO~: ur, -,UJ8~inJ :.L:lltl3HS 3Hl ..:10 3JU.:lO 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. TO AND SUBSCRIBED before me this 4 day of August. 2006 r NOTARIAL EAL I LOIS E. SNYDER, Notary Public I Carlisle 8oro, Cumberland County ~ My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 33 Writ No. 2003-6129 Civil Mortgage Electronic Registration Systems, Inc., its successors and assigns, as Nominee for Household Finance Corporation, its successors and assigns vs. James E. Tschudy. Kim D. Tschudy, Last Record Owner; Melissa Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner; Josh Tschudy, Known Heir of Kim D. Tschudy, Last Record Owner Atty.: Mark Udren ALL THAT CERTAIN piece or parcel of land situate with the build- ing and improvements thereon erected being known as Lot No. 90 on Plan of Lots laid out for Allen Park Development Corp., called Cumberland Park, as recorded in Plan Book 4, Page 86, Cumberland Co. Records, on the Southwesterly side of Locust Street, Cumberland Park, Lower Allen Township, Cumberland County, PennsylvarUa. bounded and described as follows to wit: BEGINNING at a point on the Southwesterly side of Locust Street 60 feet wide, said point being at a distance of 275 feet measured North 40 degrees 33 minutes west from the intersection of the said side of Locust Street with the Northwest- erly side of Locust Street 60 feet wide, both lines produced; thence extending along lot No. 89 South 49 degrees 27 minutes West a distance of 127.50 feet to a point; thence extending along Lot Nos. 94 and 95 North 51 degrees 21 minutes 30 seconds West a distance of 130.94 feet to a point: thence extending along property now or late of Rob- ert Stoner. North 71 degrees 57 min- utes 30 seconds East, a distance of 164.59 feet to a point in the South- westerly side of Locust Street; thence extending along the said side of Locust Street South 40 degrees 33 minutes East a distance of 65.61 feet to the place of BEGINNING. HAVING THEREON erected a single dwelling known and num- bered as 138 Locust Street. BEING KNOWN AS: 138 South Locust Street alkla 138 Locust Street (Lower Allen Township), Camp Hill, PA 17011. PROPER1Y ID NO.: 13-23-0555- 057. TITLE TO SAID PREMISES IS VESTED IN James E. Tschudy and Kim D. Tschudy (deceased), hus- band and wife by deed from Anna Gesford, single woman, dated 51 21/93, recorded 613/93, in Deed Book 136, page 13. . . .. 1 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 smce; 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 duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #33 . CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ,ll':w,t ," oJ