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Home My WebLink About03-6433 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWEILANIL ASSESJlMEN'l'__OF_DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/21/03 to 1/20/04 Late charges per Complaint From 11/21/03 to 1/20/04 $117,174.09 1,937.97 ~Q4~2Q TOTAL $~~ 215--25 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J. UDREN & ASSOCIATES \ " DAMAGES ARE HEREBY ASSESSED AS INDICATED r j) DATE: >>~~DJ,.J ~4.1 ~ ~'1 111~-b;, 7<.. ~~ .- P~J PROTHY ~ C7 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-482-6900 Monument St. Funding LLC Plaintiff ATTORNEY FOR PLAINTIFF v. 1 COURT OF COMMON PLEAS 1 CIVIL DIVISION i Cumberland County I i NO. 03-6433 Vir$inia R. Radle Mel~ssa V. Benner Defendant(s) TO: Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 DATE of Notice: January 7, 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 REDUGED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association ~~c 2 Liberty Avenue ~/ Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED 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 SENTEN CIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED 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 /s/ Mark J. Udren, s Woodcrest Corporate Cent 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 OL ECTION PRACTICES ACT, THIS AND THIS IS AN ATTEMPT TO D WILL BE USED FOR THAT NOTICE: PURSUANT TO THE FAIR DEBT LAW FIRM IS DEEMED TO BE A DEBT COLL COLLECT A DEBT. ANY INFORMATION 0 PURPOSE. vu~A~ 4AW 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 Monument St. Funding LLC Plaintiff ATTORNEY FOR PLAINTIFF v. i COURT OF COMMON PLEAS i CIVIL DIVISION I Cumberland County !,NO. 03-6433 Vir9inia R. Radle Mel~ssa V. Benner Defendant(s) TO: Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 DATE of Notice: January 7, 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 NOTIFICACION, EL TRIBUNAL PODRALoSIN 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 US TED 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 ~CTION. PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLL AND ~HIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OB D WILL BE USED FOR THAT PURPOSE. /s/ Mark J. Udren, squi e Woodcrest Corporate Center 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 Monument St. Funding LLC Plaintiff ATTORNEY FOR PLAINTIFF v. i COURT OF COMMON PLEAS i CIVIL DIVISION IC~mberland County ___ ! NO. 03-6433 Vir$inia R. R-adfe-- Me11ssa V. Benner Defendant(s) TO: Melissa V. Benner Virginia R. Radle C/o Mark W. Allshouse 219 pine Street Harrisburg, PA 17101 DATE of Notice: January 7, 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 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 0 LECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COL OR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION NED WILL BE USED FOR THAT PURPOSE. /s/ Mark J. Udren, sq re Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 NORTH KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 1 COURT OF COMMON PLEAS 1 CIVIL DIVISION I Cumberland County I MORTGAGE FORECLOSURE I NO. OH'" AFFIDAVIT OF NON-MILITARY SERVICE Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) 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: Virginia R. Radle Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Melissa V. Benner Over 18 As captioned above Unknown Sworn to and subscribed before me this 20 day of January, 2004. (\tf\ f\ ~~9)) N~~~ciblic ~ CARA STEARS NOI'ARYPUBUC OF NEW JERSr( Comm/JsIon tV""'"' '''' ''lIVl~ Name: t ~ >t ..lq. ~ () F -- <> ......, '- f' ~ c c.:::t 0 C".J .J::. :;.0'. _1..:- -11 ~ )J -., :-1 ~ t rT1 ..1--n 10 OJ rnr::::. c" ! ~TJrn \Ii ,..0 -F U1 :oj'~J ,~) : ~ -..J ~-:..;O P= ~ ~;}~~ c"'_ .'-; (..J (5i-n :..; .--1 J> -< :;:1 CO' -< 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 NO. 03-6433 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $~~21~.2~ Interest From 1l21Lo4 L 4'Z~. 5~ to Date of Sale JJ.We~,_~O{M Per diem @$31.77 (Costs to be added) $________ ___ MARK J. UDREN & ASSOCIATES ~ D + ~~ b~f: ~ ).,J ~~t l~ OJ v ~ ~ -4:\."'J. :-- ~ D () 0 FFYJ -c.ql'] l:; li1 (".; b:-O ~ ~ ~O ~ ..0 0C 0 I I I " - - - , " ~ ~ ~ ~ ........w~ u-- Irl ~ o In () 0..00 :pr +-~ , ~~ - - (' n ~'~: < r--> ~:;::) c:.:::. "'- ~.., r;! co I Ul o " -J :'1_-n rnp; -r.,rn <Jy q(.J I=r; :R >.~ ~~~ U c.:? s! :0 0"\ -< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MONUMENT ST. FUNDING LLC, Plaintiff (s) From VIRGINIA R. RADLE AND MELISSA V. BENNER NO 03-6433 Civil CIVIL ACTION -LAW (I) You are directed to levy upon the property of the defendant (s)and to seU 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 foUows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himllier that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $119,216.26 11 $.50 Interest FROM 1/21/04 TO 6/9/04 - PER DIEM @$31.77 - $4,479.57 Atty's Comm % Due Prothy $1.00 Atty Paid $133.59 Plaintiff Paid Date: FEBRUARY 5, 2004 Other Costs (Seal) CURTIS R. LONG prothon4' ~. "'~"! .P'~"-f.lr Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court lD No. 04302 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 NO. 03-6433 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. MARK J. UDREN & ASSOCIATES ,.,.___,U \ 0 "'" 0 = C~: = " ~:;7 ...- ..,., .-1 r:I II1 m--- = r- I -['Jm :,JC) U1 (~Q u S~~; ......."" (~'-. ,r,.11 W v ;?: :.~ o.~ :.0 -< O"l -< . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY 1.0. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 NO. 03-6433 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Monument St. Funding LLC, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Virginia R. Radle 6 Greeway Drive Mechanicsburg, PA 17055 Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 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 Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Domestic Relations Section 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 6 Greenway Drive Mechanicsburg (Upper Allen Twp) PA 17055 Mark W. Allshouse, Esq. Law Offices of Stephen C.Nudel, PC 219 pine Street Harrisburg, PA 17101 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: January 20, 2004 .;.>c.. ~~ -< ("") c_ ...., ~., c::~ ..- ~ n CD I (Ji C -n ---I i~?i:,g -n~; -fJt::: t~~(:) =-c~-H ~~=2o ~_~iTj ~ :.,:.: :::s ~ '-:? CJ"'> 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 NOTLCE..QE'..SHERIl"l".'.~~F-REAlL.ERO.EERTY TO: Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NO'UC:LO.F.J)jffiER'.S_RIGHTB Y01LMA Y..B.E.. ABLE. .1'O_P.REYENT...THI.s...sHERIEE~ 8....SALE To prevent this Sheriff's Sale, you must take immadiat~.~tia~t 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: .LS5..6.L_4S~OlL.. 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.) --- YQU_ MAY~TILL__BE--->>LE_TQ___SAVE~YQURn PROPERTY AND_Y_OU . HAYE~OTHER RIGHT.ELE\TEK~_THE--.SliERIFE'-'S---.SALE_. D_OES_TAKEJ'LACE. 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 (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 l70l3 7l7-249-3l66 800-990-9l08 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l70l3 7l7-249-3l66 800-990-9l08 o C~: c) ^/- ~J -, , '-~ '" C~ = ....- Ci ., --:! -- ::1" , Cl1f~ -(".' CC! :uy ~~~ ~},~~~ -,.,. ~~ -" b:i I (J1 ~ ::L- w -.J MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 NOTICE QLSBERIFF I SJlAL.LJ)E-REAILJ>RQPERTY TO: Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 a.m. in the commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. N~CE OF O.tiNE:~JUGH1'S YOU MAY BE Jl,ALE TO PR"VElIIT THTS-.Bff"RIFF'S SJl,T.E To prevent this Sheriff's Sale, you must take imme.diat.lLact.ioD..t 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: l.a5E~82~JL. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause~ 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YO_U~Y.S.TILL_BE_ABLE_TQ..SA'llLYQUR_PROPERTY.. AND_YOlLHA'llLQTHER RI GHTS..E'IlElLI ~THE---.SHERIFF.'..S_.SALE....DQES-'l'AKE__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 (/' (") r" ::-:-1 -,' "'" c=, c::..' ~- 9 n h-l :T:....., n1F -Dm :!.JO (__ I .::;~) , " W5, ,,I'> ~~ -., .., co , U1 :;:J f.;'? --J MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Monument St. Funding LLC One Old country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) . 100 03-6433 NO'l'ICE_QF~HERIFF I S SALLQF~ROl'ER'l'Y TO: Melissa V. Benner Virginia R. Radle C/O Mark W. Allshouse, Esquire Law Offices of Stephen C. Nudel, PC 219 Pine Street Harrisburg, PA 17101 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. liQ'1'IClLQl'_QmmR'JLll.I~TS YOU .MAY_.BILABLILTQ__l2REllENT... TEI S...8HERIFE"S ..sALE To prevent this Sheriff's Sale, you must take immed~___~t~ 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: .LS5c6J-".4.ll2,,-6.9.Q.O L 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 saoner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) XOILMAY_S'1'~LL--BJLJUl~lL':t'O_SlIcY1LYOl1R. i'ROi'D'1'Y_ ANP_ YaP. H!o'lE_.O'1'HEK RI.GH'1'S.. EYEN. IF 'l'HliLJ3HE1UFJ.>'JLSAI.B. .DOElL '1'AlI'.lLP.LACE, 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 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 (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 TAlI'.B THIS PAPER '1'0 YOUR LAWYER AT ONCE. IF YOU DO NO'1' HA'ITE A LAWYER OR CANNO'1' AFFORD ONE, GO TO OR TELBPHONE THE OFFICB LISTED BELOW '1'0 FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l70l3 717-249-3l66 800-990-9l08 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l7013 717-249-3166 800-990-9108 (") (.~ , (~. :~'J --<. ,..., C:~.:~ C:::. ..J~-. o -n --{ :T-r-' f('pi -CiiTl i3? :"j ~I} ~~? ~1 .~] -< --., ..-, 0:> I U1 U ~.& c..> -.J UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUmberland county NO. 03-6433 v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) DATE: January 20, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NO.'I'J:CE-OL.BHERIFF I S SALE OF- ll~l\.T. PROPERTY OWNER(S): Virginia R. Radle, Melissa V. Benner PROPERTY: 6 Greenway Drive Mechanicsburg (Upper Allen Twp), PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the C~~anQ County Sheriff's Sale on June~~~, at 10:00 a.m., 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. n "> ,-'.'. C''';::l 0 0 "'" ....- 01 --.-, :.yi r<j CO Nlp!] , "niTl L:": :::JO r. =? S16 f~~ ...,~- ':'"? -" -'i -' p; , ~lJ '-' ~~ 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION . : Cumberland County v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) : NO. 0.3 - ~l/JJ G(.)~L~~ 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 AV1SO Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa 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. LI.EVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owei! 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 yon, 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 '. on a preceding page. If Plaintiff is an assignee then it by virtue of the following recorded assignments: caption is such ~ssignor: Pennfirst Financial Corporation ~ssignee: First Union Home Equity Bank, N.A. Recording Date: 09/11/00 Book: 654 Page: 587 ~ssignor: First Union Home Equity Bank, N.A. ~ssignee: Monument St. Funding LLC Recording Date: LODGED FOR RECORDING 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: 6 Greenway Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Upper Allen COUNTY: Cumberland DATE EXECUTED: 06/02/00 DATE RECORDED: 06/08/00 BOOK: 1617 PAGE: 543 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. 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 bereof, 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 $117,174.09 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \\J Mark J. u~ren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for P~aintiff Attorney I.D. No. 04302 ..-.- / .-- __.~___"''-~~_.~_'_____~~__ ..._' ,"_~___m ALL THAT CERTArN TWO (2) ADJSCENT LOTS OF GROUND, TOGETHER wrTH THE rMPROVEMENTS THEREON ERECTED, SrTUATE rN THE TOWNSHrp -OF . U!!E:ER ALLEN, COUNTY OF C~ERLAND J\ND STATE OF PENNSYLVANrA, MORE PARTrCULARLY BOUNDED ANn' DESCarBED AS FOLLOWS, TO wrT: LOT NO.1: BEGrNNrNG AT A POrNT ON THE SOUTHERLY SrDE OF GREEENWAY DRrVE AT CORNER OF LOT NO. 20 ON THE HERErNAl"TER MENTrONED PLAN OF LOTS; THENCE ALONG THE LrNE OF SArD LOT NO. 20, SOUTH 35 DEGREES EAST, 155.00 FEET, MORE OR LESS, TO A POrNT ON THE LrNE OF LOT NO. lS ON SArD PLAN OF LOTS; THENCE ALONG THE LrNE OF SArD LOT NO.1S, SOUTH 59'DEGREES WEST, 103.5 FEET, MORE OR LESS TO A POrNT ON THE EASTERLY SrDE OF SArD GREENWAY DRrVE; THENCE ALONG THE SArD EASTERLY SrDE OF SArD GREENWAY DRrVE, NORTH 31 DEGREES WEST, S7.00 FEET, MORE OR LESS, TO A POrNT; THENCE FURTHER BY THE LrNE OF SArD GREENWAY DRrVE, BY A CURVE TO THE RrGHT HAVrNG A RADrUS OF 6S.00 FEET, AN ARC DrSTANCE OF 100.00 FEET TO A POrNT ON THE SOUTHERLY LrNE OF SArD GREENWAY DRrVE; THENCE FURTHER BY THE SOUTHERN LrNE OF SArD GREENWAY DRrVE, NORTH 56 DEGREES 20 MrNUTES EAST, 32.00 FEET. TO A POrNT ON THE LrNE OF THE Al"ORESArD LOT NO. 20, THE POrNT AND PLACE OF BEGrNNrNG. BErNG LOT NO. 19 ON THE PLAN OF LOTS OF JAMES K. & HARRrET R. TRrTT, KNOWN AS "WrNDrNG HrLL HErGHTS, SECTrON 1", WlUCH SArD PLAN OF LOTS rs RECORDED rN THE ,RECORDER'S OFFrCE rN AND FOR THE SArD CpMBERLAND COUNTY, rN PLAN BOOK 9, AT PAGE 8. LOT NO.2; BEGrNNrNG AT A PorNT ON THE EASTERLY srDE OF GREENWAY DRrVE AT THE SOUTHWEST CORNER OF OTHER LAND OF PAUL L. CRAMER AND HELEN B. CRAMER, WHrCH SArD PorNT rs .ALSO AT THE DrVrDrNG LrNE BETWEEN LOTS NOS. lS AND 19 ON THE PLAN OF "WrNDrNG HrLL HErGlITS, SECTrON 1, AS RECORDED rN THE RECORDER'S OFFrCE rN AND FOR .CUMBERLAND COUNTY rN PLAN BOOK 9, PAGES; THENCE ALONG THE LrNE OF SArD LOT NO. 19, NORTH 59 DEGREES EAST, 103.5 FEET TO A PorNT; THENCE THROUGH LOT NO. lS ON SArD PLAN, SOUTH 35 DEGREES EAST, 15.00 FEET TO A PorNT; THENCE FURTHER THROUGH SArD LOT NO. lS ON SArD PLAN RECORDED rN PLAN BOOK 9, PAGE S, SOUTH 59 DEGREES WEST, 104.00 FEET TO A PorNT ON THE EASTERLY LrNE OF GREENWAY DRrVE; THENCE ALONG THE EASTERLY LrNE OF SArD GREENWAY DRrVE, NORTH 31 DEGREES WEST, 15.00 FEET TO A PorNT ON THE EASTERLY LrNE OF SUD DRrVE, AT THE PorNT AND PLACE OF BEGrNNrNG. BErNG PART OF LOT NO. lS ON THE PLAN OF LOTS OF JAMES K. TRrTT AND HARRrET R. TRrTT, KNOWN AS "WrNDrNG HrLL HErGHTS, SECTrONS 1" WHrCH SArD PLAN OF LOTS rs RECORDED rN THE RECORDER'S OFFrCE rN AND FOR CUMBERLAND COUNTY rN PLAN BOOK 9, AT PAGE S AND BErNG THE SOUTHERN 15.00 FEET OF LOT NO. 19 ON THE REVrSED PLAN OF LOTS .~F JAMES K. AND HARRrET R. TRrTT, KNOWN AS "REVrSED PLAN OF wrNDrNG HrLLS HErGHTS, SECTrON 1", WHrCH SArD LATER PLAN OF LOTs.rs RECORDED rN THE RECORDER'S OFFrCE rN AND FOR SArD CtlMIlERLAND COUNTYrN PLAN BOOK_, PAGE_ THE ABOVE DESCRrBED PREMJ:SES rs rMPROVED wrTH A SrNGLE FAMrLY RESrDENTrAL DWELLrNG, PRESENTLY KNOWN AND NUMBERED AS 6 GREENWAY DRrVE, MECHANrCSBURG, PENNSYLVANrA. UNDER AND SUBJECT, NEVERTHELESS, TO CERTArN PROTECTrVE COVENANTS, RESTRrCTrONS RESERVATrONS AND CONDrTrONS OF PRrOR RECORD. DF785 VIRGINIA A RADLE 6 GREENWAY DRIVE MECHANICSBURG, PA 17055 September 9, 2003 0006651779 NBRC ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortu.e on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 nAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when YOU meet with the counselin2 aeency. The name. address. and phone number of Consumer Credit Counselin. A.encies servin. your countv are listed at the end of!!ill Notice. Ifvou haye anv Questions. you may call the Pennsylvania Housin. Finance Agencvtoll free at 1-800.342-2397 (Persons with impaired hearing can call 717-780-1869). 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 NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE 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 SAL VAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing Corporation is a debt collector; HomEq is attempting to collect a debt and any information obtained will be used for that purpose. SEE LAST PAGE FOR ADDITIONAL IMPORTANT DISCLOSURES THIS NOTICE CONTINUES ON THE NEXT PAGE EXHIBIT A HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . YOUR DEFAULT HAS BEEN CAUSED BY CmCUMSTANCES BEYOND YOUR CONTROL, . YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange for and attend a nface_to~face" meeting with one of the consumer counseling agencies listed at the end of this notice. TIDS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCJF,S If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone nmnbers of desi2IUlted consumer counseling agencies for the county in which vour prooerty is located are set forth at the end of this notice. It is necessary to schedule only one face-to-face meeting. You should advise this lender/servicer immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this notice (see the 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/servicer, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the dasignated 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face.to- face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BEDENJED. AGENCY ACTION Avallable funds for emergency mortgage assistance are very limited. Funds 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 lime requirements set forth above. You will be notified directly by the Agency of its decision on your application. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 3 NOTE: IF YOUA RE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIDS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed baukruptcy you can still apply for Emergency Mortgage Assistance. NATURE OF THE DEFAULT The MORTGAGE debt secured by your property located at: 6 GREENWAYDRIVEMECHANICSBURG,PA 17055 IS SERlOUSL Y IN DEF AUL T because: I. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number of Payments Delinquent: b) Delinquent Amount Due: c) Late Charges: d) Recoverable Corporate Advances: e) Other Charges and Advances: t) Less funds in Suspense: g) Total amount required as of (due date): 3 $3,125.91 $260.50 $130.48 $$0.00 $0.00 $$3,516.89 2. YOU HA VB FAILED TO TAKE THE FOLWWING ACTION: (Do not use ifnot applicable) HOW TO CURE THE DEFAULT - You may cure this default within TIIIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDERlSERVICER, WHICH IS $3,125.91 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) wmCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's check. certified cheek. or money order made pavable to: Regular Mail HomEq Servicing Corporation P.O. Box 96012 Charlotte, NC 28296-0012 Overnight Attn: Cash Central NC 4726 1100 Corporate Center Drive Raleigh, NC 27607-5066 You can cure any other default by taking the followiug action within THIRTY (30) DAYS of the date of this notice: (Do not use if not applicable) THIS NOTICE CONTINUES ON THE NEXT PAGE Page 4 IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within nnR TY (3D) days of this notice, the lender/servicer intends to exercise its rhilits to accelerate the morte-age debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the opportunity to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE DATE OF THIS LEITER, HomEq Servicing Corporation also intends to instruct its attorneys to start a legal action to foreclose upon vour morte:8e:ed propertY. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender/servicer refers your case to its attorneys, but you cure the delinquency before the attorney begins legal proceedings against you, you will still be required to pay the reasonable attorneys' fees actually incurred up to $50.00. However, ifJegal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred even if they are over $50.00. Any attorneys' fees will be added to the amount you owe the lender/servicer, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pav attorneys' fees. OTHER LENDEWSERVICER REMEDffiS The lender/servicer may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You may do so by oavin~ the total amount then oast due olus any late char~es, other char~es then due. reasonable attorneys' fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as soecified in writin~ by the lender/servicer and bv performin~ any other requirements under the mort~a~e. Curing your default in the manner set forth Ip this Notice will restore your mortgage to the same position 85 iCyou had never deCaulted. EARLIEST POSSIBhE SHERIFF'S SALE DATE It is estimated that the earliest date that such Sheriff's sale could be held would be approximately five (5) 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. 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/servicer. HOW TO CONTACT THE LENDEWSERVICER BY TELEPHONE OR MAIL: Name of Lender/Servicer Address HomEq Servicing Corporation Attn: Account Research, Mail Code CA3345 P.O. Box 13716 Sacramento, CA 95853 1-866-577-8834 Telephone Number: EFFECT OF SHERIFF'S SALE You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lenderlservicer at any time. ASSUMYTION OF MORTGAGE You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 5 YOU MAY ALSO HAVE THE RIGHT . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT; . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF; . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL T HAD OCCURRED, IF YOU CURE THE DEFAULT. HOWEVER, YOU DO NOT HAVE THE RIGHT TO CURE YOUR DEF AUL TS ANY MORE THAN THREE TIMES IN A CALENDAR YEAR; . TO ASSERT THE NON-EXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS; . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDERlSERVICER; OR . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED TO THIS LETTER If you received a discharge of the account through the Bankruptcy Court and if your account has not been reaffIrmed, the acceleration and sale will not result in your being held personally liable for the debt and this letter is not an attempt to collect a personal debt. However, failure to pay the delinquent balance is necessary to avoid foreclosure. You are notified that this default, and any other legal action that may occur as a result thereof, may be reported by HomEq to one or more credit reporting agencies. Please take appropriate action with respect to the important matters discussed herein. Sincerely, HomEq Servicing Corporation THIS NOTICE CONTINUES ON THE NEXT PAGE Page 6 IMPORTANT DISCLOSURES Colorado Collection agencies are licensed by the Colorado Collection Agency Board, 1525 Sherman Street, 5th Floor, Denver, Colorado 80203. Please do not send payments to the collection agency board. Minnesota This collection agency is licensed by the Minnesota Department of Commerce. Nebraska Any credit insnrance issued In connection with the loan contract may be canceled unless the borrower cures the default. NewYorkCitv Collection Agency License: #1099500 - North Highlands, CA (Main office) #1099501- Raleigh, NC (Branch) #1099512 - Boone, NC (Branch) North Carolina North Carolina Department of Insurance Permit: #3677 - North Highlands, CA (Main office) #3676 - Raleigh, NC (Branch) #3675 - Boone, NC (Branch) Tennessee This collection ageney is licensed by the Collection Service Board, State Department of Commerce and Industry, 500 James Robertson Parkway, Nashville, Tennessee 37243 DF785 MELISSA V BENNER 6 GREENWAY DRIVE MECHANICSBURG, PA 17055 September 9, 2003 0006651779 NBRC ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notjce that the mort~a~e on vour home js in default. and the lender intends to foreclose. SDecific information about the nature ofthe default is provided in the attached Dages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can helD VOti, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when YOU meet with the counseling a~encv. The name. address. and phone nuxnber of Consumer Credit Counselin~ AS!;encies servinlZ: your county are listed at the end of~ Notice. If you have any auestions, YOU may call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397 (Persons with imDaired hearing can call 717-780-1869). 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 NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCIQNIMMEDIATAMENTE LLAMANDO ESTAAGENCIA (PENNSYL VANIA 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 SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing Corporation is a debt collector. HomEq is attempting to collect a debt and any information obtained will be used for that purpose. SEE LAST PAGE FOR ADDITIONAL IMt>ORTANT DISCLOSURES THIS NOTICE CONTINUES ON THE NEXT PAGE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . YOUR DEFAULT HAS BEEN CAUSED BY cmCUMSTANCES BEYOND YOUR CONTROL, . YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARYSTAYOFFO~CLOSURE Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange for and attend a !tface_to_facen meeting with one of the consumer counseling agencies listed at the end of this notice. TIDS MEETING MUST OCCUR WITHIN mE NEXT rnmTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you attend a face-te-face meeting with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone munbers of designated consutner counselinJl. ae:encies for the county in which vour property is located are set forth at the end of this notice. It is necessary to schedule only one face.to~face meeting. You should advise this lenderlservicer immediatelv of YOlD' intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this notice (see the 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/servicer, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. 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 wlll assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OrnER TIME PKRIODS SET FORTH IN rnIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. Funds 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 he pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency ofits decision on your application. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 3 NOTE: IF YOUA RE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have fIled bankruptcy you can stilI apply for Emergency Mortgage Assistance. NATURE OF THE DEFAULT The MORTGAGE debt secured by your property located at: 6 GREENWAY DRIVE MECHANICSBURG, P A 17055 IS SERIOUSLY IN DEF AUL T because: 1. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number ofPaymenls Delinquent: b) Delinquent Amount Due: c) Late Charges: d) Recoverable Corporate Advances: e) Other Charges and Advances: t) Less funds in Suspense: g) Total amount required as of (due date): 3 $3,125.91 $260.50 $130.48 $$0.00 $0.00 $$3,516.89 2. YOU HA VB FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDERlSERVICER, WffiCH IS $3,125.91 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's check. certified check. or money order made payable to: Regular Mail HomEqS~cmgCorporation P.O. Box 96012 Charlotte, NC 28296-0012 Overnight Attn: Cash Central NC 4726 1100 Corporate Center Drive Raleigh, NC 27607-5066 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this notice: (Do not use ifnot applicable) THIS NOTICE CONTINUES ON THE NEXT PAGE Page 4 IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within TIDRTY (30) days of this notice, the lender/servicer intends to exercise its ri!'hts to accelerate the mort?a?e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the opportunity to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made within TIDRTY (30) DAYS OF THE DATE OF TIDS LETTER, HomEq Servicing Corporation also intends to instruct its attorneys to start a legal action to foreclose upon your morte:ae:ed prooem. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender/servicer refers your case to its attorneys, but you cure the delinquency before the attorney begins legal proceedings against you, you will still be required to pay the reasonable attorneys' fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred even if they are over $50.00. Any attorneys' fees will be added to the amount you owe the lender/servicer, which may also include other reasonable costs. If you cure the default withiu the THIRTY (30) DAY period, you will not be reauired to pav attorneys' fees. OTHER LENDEWSERVICER REMEDffiS The lender/servicer may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, vou stil\ have the right to cure the default and prevent the sale at anY time up to one hour before the Sheriff's Sale. You mav do so bv pavin? the total amount then Past due plus anv late char~es. other chare.es then due. reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writin~ bv the lender/servicer-and bv performin~ any other reauirements under the mort~a?e. Cnring your default in the manner set forth In this Notice will restore your mortgage to the same position as If you had never defaulted. EARLffiST POSSmLE SHERIFF'S SALE DATE It is estimated that the earliest date that such Sheriff's sale could be held would be approximately five (5) months from the date oUhl. notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. The amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. HOW TO CONTACT THE LENDEWSERVICER BY TELEPHONE OR MAIL: Name ofLender/Servicer Address HomEq Servicing Corporation Attn: Account Research, Mail Code CA3345 P.O. Box 13716 Sacramento, CA 95853 1-866-577-8834 Telephone Number: EFFECT OF SHERIFF'S SALE You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the Iender/servicer at any time. ASSUMPTION OF MORTGAGE You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 6 IMPORTANT DISCLOSURES Colorado Collection agencies are licensed by the Colorado Collection Agency Board, 1525 Sherman Street, 5th Floor, Denver, Colorado 80203. Please do not send payments to the collection agency board. Minnesota This collection agency is licensed by the Minnesota Department of Commerce. Nebraska Any credit insurance issued in connection with the loan contract may be canceled unless the borrower cures the default. New York Citv Collection Agency License: #1099500 - North Highlands, CA (Main office) #1099501- Raleigh, NC (Branch) #1099512 - Boone, NC (Branch) North Carolina North Carolina Department of Insurance Permit: #3677 - North Highlands, CA (Main office) #3676 - Raleigh, NC (Branch) #3675 - Boone, NC (Branch) Tennessee Tbis collection agency is licensed by the Collection Service Board, State Department of Commerce and Industry, 500 James Robertson Parkway, Nashville, Tennessee 37243 V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. MARK J. Ud~\L~ UDREN & ASSOCIATES N it- ~ ~ -t::: 6' (:) i9.. ~~ ~ ~ -~i? -L-- '--< Cl - c """;J" nl ~ ('_-' h ~~:'. ' ):':;. ,-- -. ~: , -~ .... -. :? .',.) 1 ~ (:; -, SHERIFF'S RETURN - REGULAR CASE NO: 2003-06433 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MONUMENT ST FUNDING LLC VS RADLE VIRGINIA R ET AL J MICHAEL ICKES Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RADLE VIRGINIA R the DEFENDANT , at 1240:00 HOURS, on the 15th day of December, 2003 at 6 GREENWAY DRIVE MECHANICSBURG, PA 17055 by handing to VIRGINIA R RADLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.59 .00 10.00 .00 35.59 .r'%-::' -.,<:~..:.u R. Thomas Kline 12/16/2003 MARK UDREN Sworn and Subscribed to before By: I ~~fs~ day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2003-06433 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MONUMENT ST FUNDING LLC VS RADLE VIRGINIA R ET AL J MICHAEL ICKES , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BENNER MELISSA V the DEFENDANT at 1240:00 HOURS, on the 15th day of December, 2003 at 6 GREENWAY DRIVE MECHANICSBURG, PA 17055 by handing to MELISSA BENNER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her 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 12/16/2003 MARK UDREN Sworn and before By: } ~ 0 Jr,jJ)(/ Depu~ Sheriff 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 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Monument St. Funding LLC v. Virginia R. Radle Melissa V. Benner : NO. 03-6433 Defendant(s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of Notice of Sale upon the following person (s) named herein at their last known address or their attorney of record. Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: May 3, 2004 TO: Virginia R. Radle C/O Mark W. Allshore, Esquire Law Offices of Stephen C. Nudel, PC 219 Pine Street Harrisburg, PA 17101 xxxxxx xxxxxx Melissa V. Benner C/O Mark W. Allshore, Esquire Law Offices of Stephen C. Nude I , PC 219 Pine Street Harrisburg, PA 17101 UDREN OF~O'''' P.O'. j \ dr:tl, Esquire for Plaintiff By: Mark J. 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NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) : NO. 03-6433 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 kno''-'n 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 tim 1 m 3129. This Affidavit is made subject to the e 4904 relating to unsworn falsification to au Dated: May 3, 2004 BY: Mark J. Udren, Esqu~re Attorney for Plaintiff () r; -,~.... '......(y, ~;,~:_:~i G~" -?":.., .r::;-<':':, ::..--....t. .s::,'j S{"} .C 3; -< "" = = .co g: ""'"" 1'" co -" :::?i: ~ o "J '-1 :r:-.,., rn_ r-' """t7rn ;PO \__) i ::::!E:,l ..., " c5 :YJ :..::::() C)fTj 3W 1',) N 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 856-669-5400 ATTORNEY FOR PLAINTIFF Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 NO. 03-6'133 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Monument St. Funding LLC, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PI, 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address Same as #1 above 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a 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 Real Estate Tax Dept. Address Domestic Relations Section 1 Courthouse Sq. Carlisle, PA 17013 13 North HanovEor 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 6 Greenway Drive Mechanicsburg (L~per Allen Twp) PA 17055 Mark W. Allshouse, Esq. Law Offices of Stephen C.Nudel, PC 219 Pine Street Harrisburg, PA 17101 I verify that the statements made in this aff'davit are true and correct to the best of my personal knowledg r information and belief. I understand that false st te ts h rl'n are made subject to the penalties of 18 Pa.c.s. ec. 4904 r lating to unsworn falsification to authorities. DATED: May 3, 2004 (") ...., 0 = c:. = -n ~ ...- '"T""'l ::lC =2 ~"lj ':'.. :r~ fn::.1J --< ,.- _..~ !', "TJm (j) :06 -, CI:J n ~, :5;.1-t. ,~ -- -0 ~..- :JJ ~~~ (:,;("~ L.) (~)rn ~~'I ",:.:. '> -.-1 1'-> :':',1 -< N --< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6B3 v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) DATE: May 3, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF I S S1~LE OF REAL PROPERTY OWNER(S): Virginia R. Radle & Melissa V. Benner PROPERTY: 6 Greenway Drive Mechanicsburg (Upper Allen Twp), PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 9, 2004, at 10:00 a.m., 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 w <tI ....._ "0.0 m- w ~S:E .!a Ol= :=.50 ~'ffi :g Q) E"i5.. "'_0 0.00 ~f6~ ii).!::!.Q .~:e :g ~B-g ~~ ~ ~(ij Q) r::: c:> om S ~ ~ " ,,, m "_ ro.:..:.E.l!! 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'~~~$'ffi~ Q).- ffitfJ::E UJ ~g~~~~ E ~.(ij ffi.g~ .~~~~E.e ~.- :1l.!: 2-g E 6 ~5-= <Il 1?'gw ~ $~ t-.... c: a.tfJ=:; =]1oiii=.9 E8~.~E~ ijl~ g!,g.g ~ lii:ii R=:;ua. ]! g..g~-g ~ ~gEf5<1l:1l iii"O~ UJ-g ~ 6:iP:=-5~ ~::igts~ ~~.~]6~ ~~~~a] "Ow E.i5>~..c: a 4i~ ~ ~iii ,g -g .o8.iji UJ:::> <>>-_ a. ~.l!!g08~tfJ o g ~ . c: = ~ga~:iE IIIg8....~iii 6"0.... .22.5: 6 ] ~ ~~ -;: ~ .....00 <Il.E c: .g.,g~t~N!! l!! ~8 >>m.s .22 2~:g"O 6 ~g'O~~& ~'o.~~~ ~ ~,g~g~8 g 2.9.5:8'0 ~~i~~~ 08-g~iiig {? l!! UJE ~.~ - 8'--- III E ~1?<Ilg:!;= <Il-;:.i3.IO'ffi ~.9 "':;:a " l ~ llJ Co .~ 'm o .!! ~ o ! " ~" ~ ~ V o "- wm~ ~s .910 "-- _ w 00 >-"- m_ .0", E" , m z> m'~ om 1-'" ~ - w m o L~ >- c m m .0 en E>o '.0 c" 2,* 0._ 1-",", '" ~ C Gl Q. - c: '0 Q. 0; CD ~ o -'" .E ~ Gl - ';: ~ Gl C. ... ~ ... ... "'Cl " - Gl C. E o () Gl ... - Ul " :E E ~ o u. /7 Cf, 0"> ~ Monument St. Funding LLC "IS Virginia R. Radle and Melissa V. Benner In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-6433 Civil Term Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on March 04, 2004 at 6:46 o'clock PM, he servf:d a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Virginia R. Radle and Melissa V. Benner, by making known unto Virginia Radle and Melissa Benner, personally, at 6 Greenway Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to them personally the said true and correct copy (lfthe same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2004 at 4:58 o'clock P.M., he posted a tTUle copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Virginia R. Radle and Melissa V. Benner located at 6 Greenway Drive, Mechanicsburg, 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 thf: action to the within named defendants, to wit: Virginia R. Radle and Melissa V. Benn<er, by regular mail to their last known address of 6 Greenway Drive, Mechanicsburg, P A 17055. These letters were mailed under the date of April 06, 2004 and never returned to the Sheriff's Office. Sworn and subscribed to before me This _ day of So~~s~s: /~ ~~,7'''''''IoC,f~ , R. Thomas Kline:Sheriff ~\ BY lo/llfh Real Esta / eputy 2004, A.D. Prothonotary r::;~) 7 ~_M A ~ ~1i"' ~, " . L:..,~I.r~UL::.;:;LI u ~ 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 Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County Monument St. Funding LLC v. Virginia R. Radle Melissa V. Benner : NO. 03-6433 Defendant(s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire, hereby certify that I have served true and correct copies of Notice of Sale upon the following person(s) named herein at their last known address or their attorney of record. Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: May 3, 2004 xxxxxx xxxxxx TO: Virginia R. Radle C/O Mark W. Allshore, Esquire Law Offices of Stephen C. Nudel, PC 219 pine Street Harrisburg, PA 17101 Melissa V. Benner C/O Mark W. Allshore, Esquire Law Offices of Stephen C. Nudel, PC 219 pine Street Harrisburg, PA 17101 UDREN OF1~'CES' P.C. 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Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Postpone Sale Surcharge Law Journal Patriot News Share of Bills 30.00 24.34 30.00 30.00 .50 1.00 30.00 13.80 20.00 40.00 549.05 463.27 29.26 $ 1261.22 Sworn and subscribed to before me So Answers' This/Sf!: daYOf~. rg,.~~~ C) . R. Thomas Kline, Sheriff 2004, A.D. 7'L_()~'_,~ ~. - A BY, . h Prothonotary Real E Deputy 0{ b{) \, ~Y71')) 12u--- 16G 331 MARX 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 NO. 03 -6433 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Monument St. Funding LLC, Plaintiff in the above action, by its attorney, Mark J. Udren, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Virginia R. Radle 6 Greeway Drive Mechanicsburg, PA 17055 Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 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 of record: Name address of the last recorded holder of every mortgage Address Plaintiff herein. See Caption above. 5. Name and address on the property: Name of every other person who has any record lien Address None 6. Name and address of every other pen""'''' ..'- interest in the propertv ",.,A -., sale: 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 Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Domestic Relations Section 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 6 Greenway Drive Mechanicsburg (Upper Allen Twp) PA 17055 Mark W. Allshouse, Esq. Law Offices of Stephen C. Nude 1 , PC 219 Pine Street Harrisburg, PA 17101 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: January 20, 2004 03/03/04 WED 05:31 FAX 2154050180 FEDERIIAN&PHELAN 1aI00 The Law omc.. FEDERMAN & PHELAN, LLP Olle Penn Center Plaza Sulte1400 Philadelphia, PA 19103 (215) 563-7000 Fu (215) 563-8656 Rachel Allmond Ex!. 1562 March 3, 2004 Fax i: '17-240-6397 Office of the Sheriff Cumberland County 1 Courthouse Square Carlisle, P A 117013 RE: COUNTRYWIDE HOME LOANS, INC. v. KELLEY S. BETTON CUMBERLAND County # 01-6190 CT Property Address: 1332 PENNSYLVANIA A VENm PITTSBURGH, PA 15233 Sherifrs Sale: MARCH 3, 2004 Dear sir/madam, Please mark the "terms of sale not complied" on the a: I ve captioned property. Chapter 13 Bankruptcy was rued on 6110/03 at 03. 11460 and we were incorrectly advised of reUer. Please return the writ of execut ':. to the Prothonotary. Thank you. ~ Rachel Allmond Federman & Phelan Cc: File MARK J. ODREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 855-482-6900 ATTORNEY FOR PLAINTIF. v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) ~ COURT OF COMMON PLEAS 1 CIVIL DIVISION i Cumberland County I MORTGAGE FORECLOSURE I NO. OH'" Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff NOUClLOLSHER~SALlLOLRDL PROPERTY TO: Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, carlisle, PA, to enforce the court judgment of $119,216.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTI.CE OF OWNER' S RIGHTS YillLMAY-~13LE TO PRF.VF.N'r TEIl'l l'lHERIFF'S SALE To prevent this Sheriff's sale, you must take imroediAt~_actiQn: 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: 3~6~-,,-6~O~Il. 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.) _. '._'_."-'_'''~~ _..._..._..__._._h..,'......_.__.. .. ~<'_...m,.~m~~..'_._'__ . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-.6433 NQ'rICE..J:l:LSHERIFF f S SALE-O:LB.EAL PROmn: TO: Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NQTJ:CL.OL_O~:tGH'l'.S. LQQ...MA"LBE_J>J3LE.-TO.-.P-REYENT THIS SHERIFF' 8-SALE To prevent this Sheriff's Sale, you must take immediate_a~~ 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges 6 costs and reasonable attorney's fees. To find out how much you must pay, you may call: ia~5L-4B2-69Q.~ 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_YQUR_PROPER'l'Y_ AND_YOILHAYE_OTHER RIG1iT.s_EYENJE.-'!HE-.-SHERIF~SJALLD.OES-'I'AKE_P.LACEJ_ 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. 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 ALL THAT CERTAIN TWO (2) ADJSCENT'LOTS OF GROUND, TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP ~F U?~ER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND' DESCRIBED AS FOLLOWS, TO WIT: LOT NO.1: BEGINNING AT A POINT ON THE SOUTHERLY SIDE OF GREEENWAY DRIVE AT CORNER OF LOT NO. 20 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE LINE OF SAID LOT NO. 20, SOUTH 35 DEGREES EAST, 155.00 FEET, MORE OR LESS, TO A POINT ON THE LINE OF LOT NO. 18 ON SAID PLAN OF LOTS; THENCE ALONG THE LINE OF SAID LOT NO.18, SOUTH 59 DEGREES WEST, 103.5 FEET, MORE OR LESS TO A POINT ON THE EASTERLY SIDE OF SAID GREENWAY DRIVE; THENCE ALONG THE SAID EASTERLY SIDE OF SAID GREENWAY DRIVE, NORTH 31 DEGREES WEST, 87.00 FEET, MORE OR LESS, TO A POINT; THENCE FURTHER BY THE LINE OF SAID GREENWAY DRIVE, BY A CURVE TO THE RIGHT HAVING A RADIUS OF 68.00 FEET, AN ARC DISTANCE OF 100.00 FEET TO A POINT 'ON THE SOUTHERLY LINE OF SAIDi GREENWAY DRIVE; THENCE FURTHER BY THE SOUTHERN LINE OF. SAID GREENWAY DRIVE, NORTH 56 DEGREES 20 MINUTES EAST, 32.00 FEET TO A POINT ON THE LINE OF THE AFORESAID LOT NO. 20, THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 19 ON THE PLAN OF LOTS OF JAMES K. & HARRIET R. TRITT, KNOWN AS "WINDING HILL HEIGHTS, SECTION 1", WHICH SAID PLAN OF LOTS IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR THE SAID C,UMBERLAND COUNTY, IN PLAN BOOK 9, AT PAGE 8. LOT NO.2; BEGINNING AT A POINT ON THE EASTERLY SIDE OF GREENWAY DRIVE AT THE SOUTHWEST CORNER OF OTHER LAND OF PAUL L. CRAMER AND HELEN B. CRAMER, WHICH SAID POINT IS ,ALSO AT THE DIVIDING LINE BETWEEN LOTS NOS. 18 AND 19 ON THE PLAN OF "WINDING HILL HEIGHTS, SECTION 1, AS RECORDED IN THE RECORDER'S OFFICE IN AND FOR .CUMBERLAND COUNTY IN PLAN BOOK 9, PAGE 8 ; THENCE ALONG THE LINE OF SAID LOT NO. 19, NORTH 59 DEGREES EAST, 103.5 FEET TO A POINT; THENCE THROUGH LOT NO. 18 ON SAID , I PLAN, SOUTH 35 DEGREES EAST, 15.00 FEET TO A POINT; THENCE FURTHER THROUGH SAID LOT' '. I NO. 18 ON SAID PLAN RECORDED IN PLAN BOOK 9, PAGE 8, SOUTH 59 DEGREES WEST, 104.00 FEET TO A POINT ON THE EASTERLY LINE OF GREENWAY DRIVE; THENCE ALONG THE EASTERLY LINE OF SAID GREENWAY DRIVE, NORTH 31 DEGREES WEST, 15.00 FEET TO A POINT ON THE EASTERLY LINE OF SAID DRIVE, AT THE POINT AND PLACE OF BEGINNING. BEING PART OF LOT NO. 18 ON THE PLAN OF LOTS OF JAMES K. TRITT AND HARRIET R. TRITT, KNOWN AS "WINDING HILL HEIGHTS, SECTIONS 1" WHICH SAID PLAN ,OF LOTS IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 9, AT PAGE 8 AND BEING THE SOUTHERN 15.00 FEET OF Lo.T NO. 19 ON THE REVISED PLAN OF LOTS ''OF JAMES, K. AND HARRIET R. TRITT, KNOWN AS "REVISED PLAN OF WINDING HILLS HEIGHTS, SECTION 1", WHICH SAID LATER PLAN OF LOTS'IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR .SAID CUMBERLAND COUNTY IN PLAN BOOK_, PAGE_ THE ,ABOVE DESCRIBED PREMISES IS IMPROVED WITH A SINGLE FAMILY RESIDENTIAL DWELLING, PRESENTLY KNOWN AND NUMBERED AS 6 GREENWAY DRIVE, MECHANICSBURG, PENNSYLVANIA. UNDER AND SUBJECT, NEVERTHELESS, TO CERTAIN PROTECTIVE COVENANTS, RESTRICTIONS RESERVATIONS AND, CONDITIONS OF PRIOR RECORD. ----- BEING KNOWN AS: 6 GREENWAY DRIVE, MECHANICSBURG, (UPPER ALLEN TWP.) PA 17055 42-27-1890-028 PROPERTY ID NO. : TITLE TO SAID PREMISES IS VESTED IN VIRGINIA R. RADLE AND MELISSA V. BENNER, AS JOINT TENANTS WITH THE RIGHTS OF SURVIVORSHIP AND NOT AS TENANTS IN COMMON BY DEED FROM PAUL L. CRAMER, WIDOWER DATED 01/03/00 RECORDED 01/04/00 BOOK 214 PAGE 431. WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-6433 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MONUMENT ST. FUNDING LLC, Plaintiff (s) From VIRGINIA R. RADLE AND MELISSA V. BENNER (I) You are directed to levy upon the property of the defendant (s)and to seIl 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 foIlows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himllier that he/she has heen added as a garnishee and is enjoined as above stated. Amount Due $119,216.26 11 $.50 Interest FROM 1/21/04 TO 6/9/04 - PER DIEM @$31.77 - $4,479.57 Atty's Comm % Due Prothy $1.00 Atty Paid $133.59 Other Costs Plaintiff Paid Date: FEBRUARY 5, 2004 CURTIS R. LONG (Seal) Prothonot51 '--lU: ~~_/1. P '7po~~.c.r--:-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale #42 On March 04, 2004 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 6 Greenway Drive, Mechanicsburg, more fully described on Exhibit "An filed with this writ and by this reference incorporated herein. Date: March 04, 2004 By: ,} tj(4r~~u.f1n Real Est<1te Deputy ~..-) ~ @ .1)ViI 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 of the Cwnberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cwnberland 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 Cwnberland Law Journal on the following dates, viz: APRIL 16,23,30,2004 Affiant further deposes that he is authorized to veritY this statement by the Cwnberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 42 sa MA~ditor SWO TO AND SUBSCRIBED before me this 30 day of APRIL 2004_ Writ No, 2003-6433 Civil Monument St. Funding LLC VS. Virginia R Radle and Melissa V. Benner Atty.: Mark J. Udren ALL THAT CERTAIN two [2) adjscentlots of ground, together with the improvements thereon erected, situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, more part1cu~ larly bounded and described as fol- lows, to wlt: LOT NO.1: BEGINNING at a point on the southerly side of Greeenway Dnve at comeT of Lot No. 20 on the hereinafter mentioned plan of lots; thence along the line of said Lot No. 20, South 35 degrees East, 155.00 feet. more or less. to a point on the line of Lot No. 18 on said plan of lots: thence along the line of said Lot No. 18. South 59 degrees West, 103.5 feet_ mnrp nr 1.",<> t.... <> ....~....~ 0t~)~. JAlJ-dt'A/ NdMtrAt SEAL If lOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2005 ~ nUt: u~ ...._. lots; thence along the line C! S~lU Lot No. 18, South 59 degrees West, 103.5 feet, more or less to a point on the easterly side of said Green~ way Drive; thence along the said easterly side of said Greenway Dlive, North 31 degrees West. 87- .00 feet, more or less, to a point: thence further by the line of said Greenway Drive, by a curve to the right having a radius of 68.00 feet, an arc distance of 100.00 feet to a point on the southerly l1ne of said Greenway Drive; thence further by the southern line of sa1d Greenway Drive, North 56 degrees 20 minutes East, 32.00 feet to a point on the line of the aforesaid Lot No. 20, the point and place of beginning. BEING Lot No. 19 on the plan of lots of James K. & Harriet R. Tritt, known as "Winding HlU Heights, Section 1", which said plan of lots is recorded tn the Recorder's Office ~ in and for the said Cumberland County. in Plan Book 9. at Page 8. LCYl"NO. 2: BEGINNING ata point on the easterly side of Greenway Drive at the southwest corner of other land of Paul L. Cramer and Helen B. Cramer, which said point is also at the dividing line between Lots Nos. 18 and 19 on the plan of "Winding Hill Heights. Section I, as recorded in the Recorder's Office in and for Cumberland County in Plan Book 9. Page 8; thence along the line of said Lot No. 19 North 59 degrees East, 103.5 feet to a point: thence through Lot No. 18 on said plan. South 35 degrees East. 15.00 feet to a point; thence further through sa1d Lot No. 18 on said plan recorded in Plan Book 9, Page 8. South 59 degrees West, 104.00 feet to a point on the easterly line of Greenway Drive; thence along the easterly line of said Greenway Drive, North 31 degrees West, 15.00 feet to a point on the easterly line of said drive. at the point and place of beginning. BEING part of Lot No. 18 on the plan of lots of James K. Tritt and Harriet R Tritt. known as "WInding HIll Heights, Sections I' which said plan of lots is recorded in the Re- corder's Office in and for Cumber- land County In Pian Book 9. at Page 8 and betng the southern 15.00 feet of Lot No. 19 on the revised plan of lots of James K. and Harriet R Tritt, known as "Revised Plan of Winding Hills Heights. Section I". which said later plan of lots 1s recorded in the Recorder's Office in and for said Cumberland County in Plan Book _, Page _' THE ABOVE DESCRIBED PREM- ISES IS IMPROVED WITH a single family residential dwelling. presently known and numbered as 6 Green- way Drive, Mechamcsburg, Pennsyl. vania. UNDeR AND SUBJeCT, never. theless. to certain protective cove~ nants, restrictions reservations and conditions of prior record. BEING KNOWN AS: 6 Greenway Drive, Mechanlcsburg. (Upper Allen Twp.) PA 17055. PROPER1Y ID NO.: 42-27.1890- 028. TITLE TO SAID PREMISES IS VESTED IN Virginia R. Radle and Melissa V, Benner, as joint tenants with the rights of survivorship and not as tenants in common by deed from Paul L. Cramer, widower dated 01/03/00 recorded 01/04/00 Book 214 Page 431. , r _...~ ..... LI'-'6UUJJug. BEING Lot No. 19 on the plan of lots of James K. & Harnet R. Tlitt, known as "Winding Hill Heights, Section }", which said plan of lots is recorded in the Recorder's Office in and for the said Cumberland County, in Plan Book 9. at Page 8. LCYrNO. 2: BEGINNING at a~t on the easterly side of Greenway Drive at the southwest corner of other land of Paul L. Cramer and Helen B. Cramer, which said point is also at the dividing line between Lots Nos. 18 and 19 on the plan of "Winding Hill Heights. Section 1, as recorded in the Recorder's Office in and for Cumberland County in Plan Book g, Page 8: thence along the line of said Lot No. 19 North 59 degrees East, 103.5 feet to a point; thence through Lot No. 18 on said plan, South 35 degrees East. 15.00 feet to a point: thence further through said Lot No. 18 on said plan recorded in Plan Book g. Page 8, South 59 degrees West. 104.00 feet to a pOint on the easterly line of Greenway Drive; thence along the easterly line of said Greenway Drive, North 31 degrees West. 15.00 feet to a point on the easterly line of said drive, at the point and place of beginning. BEING part of Lot No. 18 on the plan of lots of James K. Tritt and Harriet R Tritt, known as uWinding Hill Heights, Sections I" which said plan of lots is recorded in the Re- corder's Office in and for Cumber- land County in Plan Book 9, at Page 8 and being the southern 15.00 feet of Lot No. 19 on the revised plan of lots of James K. and Harnet R. Tritt, known as uRevised Plan of Winding Hills Heights, Section 1", which said later plan of lots Is recorded in the Recorder's Office in and for said Cumberland County in Plan Book _, Page _' THE ABOVE DESCRIBED PREM- ISES IS IMPROVED WITH a single family residential dwelling, presently known and numbered as 6 Green- way DI1ve. Mechanlcaburg. Pennsyl- vania. UNDER AND SUBJECT, never. theless, to certain protective cove- nants, restrictions reservations and conditions of prior record. BEING KNOWN AS: 6 Greenway Drtve, Mechanicsburg, (Upper Allen Twp.) PA 17055. PROPERTY ID NO.: 42-27.1890- 028. TITLE TO SAID PREMISES IS VESTED IN Virginla R. Radle and Melissa V. Benner, as Joint tenants with the lights of survivorship and not as tenants in common by deed from Paul L. Cramer, widower dated 01/03/00 recorded 01/04/00 Book 214 Page 431. 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and..Ihll 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 April and the 4th and 11th day(s) of May 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 aid Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of a hin in Mi ellaneous Book "M", Volume 14. Page 317. ~;. . r .'.". II ~itl:l' "':rfi~ ^i,:.>>:;i:?\.,:i:1:' """:jti~+i,;"1!:?_,:\:;: ....................... ..........~... ..................................................... Sworn to and subscribed 'efore/~ 28th day o~. Terry L~:IFNotary Pu'!~~ ~~ QlyofHarrisburg, DouphlnCaunly NOTA Y PUBLIC My Commission Expires June 6, 2tll9. mmisslon expires June 6, 2006 Member I PlnnlylvlnlaAJacclahonol Notarl.. PUBLICATION COPY SALE #42 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 "';,l}' /",)1".,,';" .... ..~~.,::J~~~i>. af~~~~ .f~I~:~ : Statem:On~HEo:AT~~~~~~~n~o., ~~sts ~ In' ~.\~.w.."..~ F bl h th t bl' t' tt h d _~~\~~ or Ph~r~~ol~~ th: :~~~: ~;aie~ ~:~~~n a ac e r "IO~~*x5 Publisher's Rece~::al for Advertising Cost $ 463.27 =liIt,tJ:l~~,.r16:~ ' publisher of The Patriot-News and The Sunday Patriot-News. newspapers of general ...,r...OI.!\"l,Y, \1l!\<flly Qt",'I\;).~".; receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By,......,......,...........,......................................... r m__ 0f gr<JlfTId, ro~IlJl,,1 ..,..' __ . thereonerectec, sl'l.1atein '.1eTOWl1Snilloft'prer Allen, Count) of Cumber-land and ~tale of Pennsylvania, more particularly bounded and describedasfoUows,towit LOT NO. 1: BEG~1NG at a point on the southerly side of Greenway Drive at comer of Lot No. 20 on the hereinafter mentioned Plan of Lots; thence along the line of s,1id Lot No. 20, south 35 degrees east, 155.00 fect, more I)T less, to a point on the line of Lot No. 18 on said Plan of Lots; thence along the line of said Lot No. 18, soulb 59 degrees west, J03-5 feel, more or less to a point on the easterly side of said Greenway Drive; thence along the said easterly ~ide of said Greenway Drive, north 31 degrees west, 87.00 feet, more or le1,5, to a point thence further by the line of said Greenway Drive, by a curve to the right having a radius of 68.00 feet, an arc distance of 100.00 feet to a point on the southerly line of said Greenway Driv~ thence further by the southern line of said G,~nway Drive, north 56 degrees 20 minutes east, 32.00 feet to a point on the line of the aforesaid Lot No. 20, the point and place of BEGINNING. BEING Lot No. 19 on the Plan l)f Lots of James K. & Harriet R. Tritt, known as 1Winding Hill Heights, Section 11, which said Plan of Lob isrecoroed in the Retorderis Offic.e in and for the said Cumberland County, in Plan Book 9, at Page 8. LOT NO.2: BEGINNING at a point on lhe !;'merly side of Greenway Drive at the southw~ comer of other land of Paul L. Cramer and Helen B. Cramer, which said point is also at the dividin& line between Lot!; Nos. 18 and 19 on the Plan of lWinrling Hill Heights, Section U, as recorded in the Recorderfs Office in and for Cumberland County in Plan Book 9, Page 8; thence along the line of said Lot No. 19, north 59 degrees ea.\, 103.5 feet to a point; thence through Lot No. 18 on said plan, south 35 degrees east, 15.00 feet to. point; thence further through said Lot No. 18 011 said Plan recorded in Plan Book 9, Page 8, aoutb 59 degrees wes~ 104.00 feet to a point on the easterly line of Greenway Drive; thence along the easterty line of said Greenway Drive, north 31 degrees west, 15.00 feet to a point on the easWty line of said Drive, at the point and place of BEGINNING. . BEING part of Lot No. 18 on the P\en of Lots of James K. Tritt and Harriet R. Tritt, known as i'Mnding Hilt Heights, Sections li which said Plan of Lots is recorded in the Recorderls 0ft1ce in and for Cumberland County in Plan Book 9\ 11 Page 8 and being the southern 15.00 feet of Lot No. 19 on the revised Plan of Lots of James K. and Harriet R. Tritt, known as tRevised Pbn of Winding Hills Heights, Section 11, wbicl1 uid later Plan of Lots is recorded in the RectflScJfI Office in and for said Cumberland Countyia. Plail. BooK._,Page_. The above described premises is improved with a single family ,residential dwelliJJJ, presently known and numbered as 6 G<<etlW&y Drive, Mechanicsburg, Pennsylvania. UNDER AND Subject, neverfue1r:at.', to certain protective covenants, resttjctioDl. reservations and conditions of prior rwmL BEING KNOWN AS: c GreenW!l Drivo.. M"hanicsburg (Upper Allen 1Ivp.), PA 119S5. . TITLE to said premises is vested in VqiDia R. Radle and Melissa V. Benner, as joint ,...... with the rights of survivorship and not ~ ~ in conunon by deed from Paul 1. ~ widower, dated 01103/00 recorded OJJJWl BookIl4 Page 431. " PROPEKIY ill No.42-27-1890-028. For publishing the notice or PUUII....O'lIV.. hereto on the above stated dates Total publisher's Receipt for Advertising Cost Co_, publisher of The Patriot-News and The Sunday Patriot-Ne 9dge receipt of the aforesaid notice and publication costs and 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6433 v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Virginia Radle has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on June 8, 2004, Bankruptcy Case No. 04-bk-03501. Mark J. Udren, Es ire UDREN LAW OFFICES, P.C. Attorney for Plaintiff 03110512 (') f~; -u6i j'-i":_f: ~~:--:. ~r-" '~'l~ ).>{;;; ::.-1 -< "" = = or:- (/) Pi -0 o -n -1 'r ?"'ii(' ,:-;STl -n.....:' I~~J~;-' '__~:" -Ii ':.;(,,:: ,;'_',c< fn --.I -", '.- N N --.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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(sl ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6433 TO THE SHERIFF: PRAECIPE TO ISSUE WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 06/09/04 to Date of Sale 12/07/05 Per diem @$31.77 $119,216.26 17,378.19 (Costs to be added) $ 1: UD~N LAW OFF I CES, P. C j \ . r\ /"--./ ! J "--../ ~rk ~. Udren, ESQUIRE TTORNEY FOR PLAINTIFF p ~r - () ~~ w ?-~ '"" Vl ~ \)' o.v \D ~ ~ ~. + \J t ..J4. ):: \) ~ ~ - UJ \) C> t? {g.. )..J-W- lr] '" '" 11\ \r1 ~ -?~:-- 0'\1"\ '0 .\;) C> ~ ,... C ...0 0 DC\J~ \ \_\ ) 1 t r:::. -V \ ,C' r -1- ~ ' , ' C '~ - ,i/E ------ t-~ 0 ;-:.:) 4'1 ~ .-\ "'C.",'. """ i'n'~ ~:::;::; \.''i'. 'I ':i~\::,~) c:; <:?~ ~~~; ~ ~~:;~~ -.:;. . ~ ?r:~ {,..fi ~4. <P - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-6433 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MOMUMENT ST. FUNDING LLC Plaintiff (s) From VIRGINIA R. RADLE AND MELISSA V. BENNER (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 ofthe 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 uamed garnishee, you are directed to notify himllier that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $119,216.26 11 Interest FROM 6/9/04 TO DATE OF SALE 1217105 - PER DIEM @$31.77 - $17,378.19 Atty's o,mm % Due Prothy $1.00 Atty Paid $1407.31 Plaintiff Paid Date: JULY 13, 2005 Other Costs CURTIS R. LONG (Seal) prothOlZ P ~y: 0.....(_ Deputy 71ZOl/J/YJ 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 lD No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~~~ WOODCREST ROAD, SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 03-6433 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. certification is made subject to the penalties of relating to unsworIli..",...I.fals.. ifica~' on to authorit.ies. '.'\. ' ;1,.UDR:i!;N LAW FF E'S"d' c. ' q. \ ! \. \.' _/ j, il~ark J. Udren, ESQUIRE ~TTORNEY FOR PLAINTIFF , This Sec. 4904 18 Pa. C.S. (") ~,; ~-7" r-> = c:? <J' <- C::. ,.....-~ ...;'-, :2 UJ o ~n -' --':.-<f'\ f:~:t., -,-'" -I") ::;;r.: r0 .- T.:;c.") /::~;"n ~':"'::', <.n CP ~'rJ. .<. ~. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 1~1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 AFFIDAVIT PURSUANT TO RULE 3129.1 Monument St. Funding LLC, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 6 Greenway Drive, Mechanicsburg (Upper Allen Twp) , PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 6 Greenway Drive Mechanicsburg (Upper Allen Twp), PA 17055 Mark W. Allshore, Esquire Law Offices of Stephen C. Nudel, PC 219 Pine Street Harrisburg, PA 17101 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 a horities. t'\\UDREN'~W OF.~S, P.C. I \ ; ~/ I M~ J. Udren, ESQ. l Attorney for Plaintiff DATED: July 7, 2005 . (") r-> 0 \~ C "'"" 'n <.>~ " <.-. .-, r c: ::r:"1'1 ,-- n.1r;;::'~ 3, en '0 u.:> c':) '_ ~:l -y', 4J .-\', ::c: .: ) (') .~~: <; , f'n ~ :~:_~~ .c.:" ,> -j <.n ~'>::) ~ CO :.-<. 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Virginia R. Radle 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 a.m. in the Commissioners Hearing Rooom, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, 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 ~ediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late chargest 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 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 OPFICE 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 c:~ ~.:~ = '11 W'l <- :::I c= _,,_ -n " rl1e~ W i~~:~ -,., .> -q ( (' c ~- r\1 :--^~ 1') '.::~I Z ",~-,. -" en ~ ,< 00 UDREN LAW OFFICES, P.C. BY, Mark J. Udren, Esqnire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~~~ WOODCREST ROAD SUITE 200 CHERRY HILL, NJ 0$003-3620 856-669-5400 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTI COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(sl NO, 03-6433 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Virginia R. Radle c/o Mark W. Allshore, Esquire Law Offices of Stephen C. Nudel, PC 219 Pine Street Harrisburg, PA 17101 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper AI: Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on Decem 7, 2005, at 10:00 a,m. in the Commissioners Hearing Rooom, 2nd Flo Courthouse, Carlisle, PA, to enforce the court judgment of $119,216. obtained by Plaintiff above (the mortgagee) against you. If the saIl postponed, the property will be relisted for the Next Available Sal 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 charges, costs and reasonable attorneyls fees. you may call: (856) 669-5400. mortgagee the back paymen To find out how much you ml. 2. You may be able to stop the sale by filing a petition asking the Court t or open the judgment, if the judgment was improperly entered. You may 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 contac (See notice on page 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 lID) 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- c, ....,-" ~...... ~, r-> c:~ c;::.) <-J' (... c:-;: ,-- Q. .... :r, -n n1?' _nl):' ~) >--) ;~1.,(:~.'. "r:'-'..i ~"~rA , - u> -t:l :>: r;-? ~f\ v:> ". -" ~1 -- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Monument St, Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 a.m. in the Commissioners Hearing Rooom, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, 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 <;:." r-> = Co> ~ <- c:::: ,-,.# ~; =< u.:> o -n -I :1:~ rnf;":O 4.) '~"'.J, :',"}~'/ '~:?~ S!,~ ;'~.'). (:") _;;:~(n ~~ -a :..:;. N .. tfl u:> ".." UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire A~TY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3~20 856-669-5400 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Melissa V. Benner c/o Mark W. Allshore, Esquire Law Offices of Stephen C, Nude 1 , PC 219 pine Street Harrisburg, PA 17101 Your house (real estate) at 6 Greenway Drive, Mechanicsburg (Upper Allen Twp), PA 17055 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 a.m, in the Commissioners Hearing Rooom, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $119,216.26, 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 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. 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 o c ,.., = ~~:::::> 0'> '- c::: C'- C' :::1 -<. UJ o -n ,.... ::c --..-) \~<<~ .~':; (~) -_1'\' ~r 55 -< -Q ~ -- r:-? (..,., ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County CIVIL TERM NO. 03-6433 v. Virginia R, Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) DATE: July 7, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): VIRGINIA R. RADLE MELISSA V. BENNER PROPERTY: 6 Greenway Drive Mechanicsburg (Upper Allen Twp), PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 7, 2005, at 10:00 a.m., at the Commmissioners 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. ALL THAT CERTAIN TWO (2) ADJSCENT LOTS OF GROUND, TOGETHER w:rTH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP -OF UE~ER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND' DESCRIBED AS FOLLOWS, TO WIT: LOT NO.1, BEGINNING AT A POINT ON THE SOUTHERLY SIDE OF GREEENWAYDRIVE AT CORNER OF LOT NO, 20 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE LINE OF SAID LOT NO. 20, SOUTH 35 DEGREES EAST, 155.00 FEET, MORE OR LESS, TO A POINT ON THE LINE OF LOT NO, 18 ON SAID PLAN OF LOTS; THENCE ALONG THE LINE OF SAID LOT NO,18, SOUTH 59 DEGREES WEST, 103.5 FEET, MORE OR LESS TO A POINT ON THE EASTERLY SIDE OF SAID GREENWAY DRIVE; THENCE ALONG THE SAID EASTERLY SIDE OF SAID' GREENWAY DRIVE, NORTH 31 DEGREES WEST, 87,00 FEET, MORE OR LESS, TO A POINT; THENCE FURTHER BY THE LINE OF SAID GREENWAY DRIVE, BY A CtlllVE TO THE RIGHT HAVING A RllDIUS OF 68.00 FEET, AN ARC DISTANCE OF 100.00 FEET TO A POINT ON THE SOUTHERLY LINE OF SAID GREENWAY DRIVE; THENCE FURTHER BY THE SOUTHERN LINE OF SAID GREENWAY DRIVE, NORTH 56 DEGREES 20 MINUTES EAST, 32,00 FEET TO A POINT ON THE LINE OF THE AFORESAID LOT NO. 20, THE POINT AND PLACE OF BEGINNING. BErNG LOT NO. 19 ON THE PLAN OF LOTS OF JAMES K. & HARRIET R. TRITT, KNOWN AS "w:rNDING HILL HEIGHTS, 'SECTION 1", WHICH SArD PLAN OF LOTS IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR THE SAID CUMBERLAND COUNTY, IN PLAN BOOK 9, A'I: PAGE 8. LOT NO.2; BEGINN:I:NG AT A POINT ON THE EASTERLY SIDE OF GREENwAY DRIVE AT THE SOl7T1lWEST CORNER OF OTHER l.AND OF PAUL L. CRAMER AND HELEN B, CRAMER, WHICH SAID POrNT IS ALSO AT THE DIV:J:DING LINE BETWEEN LOTS NOS. 18 AND 19 ON THE PLAN OF "WINDING HILL HEIGHTS, SECTION 1, AS RECORDED IN THE RECORDER'S OFFICE IN AND FOR .CUMBERLAND COUNTY IN PLAN BOOK 9, PAGE8; THENCE ALONG THE LINE OF SAID LOT NO. 19, NORTH 59 DEGREES EAST, 103. 5 FEET TO A POINT; THENCE THROUGH LOT NO, 18 ON SAID PLAN, SOUTH 35 DEGREES EAST, 15.00 FEET TO A POINT; THENCE FURTHER THROUGH SAID LOT NO, 18 ON SAID PLAN RECORDED IN PLAN BOOK 9, PAGE 8, SOUTH 59 DEGREES WEST, 104,00 FEET TO A POINT ON THE EASTERLY LINE OF GREENWAY DRIVE; THENCE ALONG THE EASTERLY LINE OF SAID GREENWAY DRIVE, NORTH 31 DEGREES WEST, 15. 00 FEET TO A POINT ON THE EASTERLY LINE OF SAID DRIVE, AT THE POINT AND PLACE OF BEGINNING. BEING PART OF LOT NO, 18 ON THE PLAN OF LOTS OF JAMES K, TR:!;TT AND HARRIET R. TRITT, KNOWN AS "WINDING HILL HEIGHTS, SECTIONS 1" WHICH SAID PLAN OF LOTS IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 9, AT PAGE 8 AND BEING THE SOUTHERN 15.00 FEET OF LOT NO. 19 ON THE REVISED PLAN OF LOTS UP' JAMES K. AND HARRIET 11., TRITT, KNOWN AS "REVISED PLAN OF WINDING HILLS HErGHTS, SECTION 1", WHICH SAID LATER PLAN OF LOTS IS RECORDED IN THE RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK_, PAGE_ THE ABOVE DESCRIBED PREMISES IS IMPROVED WITH A SINGLE FAMILY RESIDENTIAL DWELLING, PRESENTLY KNOWN AND NUMBERED AS 6 GREENWAY DRIVE, MECHANICSBURG, FENNSYLVANIA. UNDER AND SUBJECT, NEVERTHELESS, TO CERTAIN PROTECTIVE COVENANTS, RESTRICTIONS RESERVATIONS AND CONDITIONS OF PRIOR RECORD. BEING KNOWN AS: 6 GREENWAY DRIVE, MECHANICSBURG (UPPER ALLEN TWP) , PA 17055 PROPERTY ID NO. : 42-27-1890-028 TITLE TO SAID PREMISES IS VESTED IN VIRGINIA R. RADLE AND MELISSA V. BENNER, AS JOINT TENANTS WITH RIGHTS OF SURVIVORSHIP AND NOT AS TENANTS IN COMMON BY DEED FROM PAUL L. CRAMER, WIDOWER DATED 01/03/00 RECORDED 01/04/00 IN DEED BOOK 214 PAGE 431. .......- ....-----. B18W (12103) United States Bankruptcy Court Middle District of Pennsylvania Case No. 1:04-bk-03501-MDF In re: Debtor(s) (name(s) used by the debtor(s) in the last 6 years, including married, maiden, trade, and address): Virginia Radle aka Virginia Gutshall 6 Greenway Drive Mechanicsburg, P A 17055 Social Security No.: xxx-xx-3023 Employer's Tax LD. No.: DISCHARGE OF DEBTOR AFTER COMPLETION OF CHAPTER 13 PLAN It appearing that the debtor is entitled to a discharge, IT IS ORDERED: The debtor is granted a discharge under section 1328(a) of title II, United States Code, (the Bankruptcy Code). BY TIlE COURT Dated: 3/17/01 -ry~ d/}c3f ~ United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. 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 Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF' COMMON PLEAS CIVIL DIVISION Cumberland County NO. 03-6433 v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO WITHDRAW WRIT OF EXECUTION TO THE SHERIFF: Kindly withdraw the Writ of Execution with regard to the referenced matter. DATED: August 31, 2005 Mark J. dren, ESQUIRE ATTORNEY FOR P AINTIFF o ~;~ "'" C"::J cO> en (/) rrl -0 I -.J -n N U1 f 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 Monument St. Funding LLC One old Country Road Suite 200 Carle Place, NY 11514 Plaintiff A~rTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION cumberland County NO. 03-6433 v. Virginia R, Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO MARK SETTLED. DISCO!ITINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED, upon payment of your costs only, (~ Mark ~Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff DATED: Auqust 22. 2005 n '" c;::, 0 C = -n ,J' C/o --/ n :r " ~,) f11 p;. I ~.Cl fT1 ~. ; } 0 -J , C:J -V -~", -) -, ,~ ~':5rn ._, N :;'> -~ :".IJ .., a. -< MARKJ, VDREN' STlJART WINNEQ"" QAYL SPIVAK ORLOFF"" HEIDI R. SPIVAK'" MARISAJOY MYERS'." LORRAINE DOYLE'" ALAN M, MlNATO..'. 'ADMITTliD NJ, J)A, FL ",ADMITTEO PA ...ADMlTTED NJ, E'A TINA MARIE RlCll OFFICii ADMlN'ISTRA7'OR VDRENLA W OFFICES, P .C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856 . 669 ' 5400 FAX: 856.669.5399 PENNSYLVANIA OFFICE 215.568.95011 215.568.1141 FAX FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE August 11, 2005 Sent via telefax #1-717-240-6397 1/ Cumberland County Sheriff's Office Cumberland County Courthouse One Courthouse Square Carlisle, PA 17019-3387 ATTN: Sgt Jody Smith Re: Monument St, Funding LLC vs. Virginia R, Radle & Melissa V, Benner Cumberland County C.C.P, No, 03-6433 premises:6 Greenway Drive, Mechanicsburg (Upper Allen Twp) , PA 17055 55 Date: December 7, 2005 Dear Sgt. Smith: Please Stay the Sheriff's Sale scheduled for December 7, 2005. Sale is stayed for the following reason: The subject loan has been Paid Off. Amount collected in consideration of the Stay Sl17.172.23.................. Thank you for your attE,ntion to this matter. SinCf\ef\ yours, MarV J~ u~en UDREN LAW OFFICES, P. C ,. /hac 8/31/05 - Original writ returned to the Prothonotary' Off' 8/31/05 _ Co . s ~ce. . Py of wr~t and $1500.00 returned to Attorney Mark Udren. 10/10 'd L0088cv9S8 'ON X~j '0 'd 'sao!HO MOl uaJpo Wd Ic:cl OHl SOOc-IH)n~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03,6433 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MOMUMENT ST. FUNDING LLC Plaintiff (s) From VIRGINIA R. RADLE AND MELISSA V. BENNER (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) 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 himfher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $119,216.26 L.L. Interest FROM 6/9/04 TO DATE OF SALE 12/7/05 - PER DIEM @$31.77 - $17,378.19 Atty's Comm % Due Prothy $1.00 Atty Paid $1407.31 Other Costs Plaintiff Paid Date: JULY 13, 2005 (Seal) CURTIS R. LONG Prothod; P 7g ~ a~ e. 'Y(/?"I. r-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856,669-5400 Supreme Court ID No. 04302 U-c,'",: ~. a:: :,.. uJ. :x:;. U"J;" c: N 0. ;::r Lt_ tl_<....' r""': -~ ::~ -, ..r> = = ...... - ------ 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 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Monument St. Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff MORTGAGE FORECLOSURE v, Virginia R. Radle NO. 03-6433 Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I, The judgment entered in the above matter is based on an Action: ____A. In Assumpsit (Contract) ____B. In Trespass (Accident) --X-C. In Mortgage Foreclosure ____D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property, II. The Defendant(s) own the property being exposed to sale as: ____A. ____B. --X-C, ____D. ____E. ____F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): --X-A. ____B. _C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonweal th of Penn' ':yl vanAf. . ' Resident: i'v/ V'~/ ark J. Udren, ESQUIRE ddress & I.D. # as above I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER ~~~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Monument St, Funding LLC One Old Country Road Suite 200 Carle Place, NY 11514 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Virginia R. Radle Melissa V. Benner 6 Greenway Drive Mechanicsburg, PA 17055 Defendant(s) NO. 03-6433 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 Sec. 4904 certification is made subject to the penalties of relating to unswor\\ifa~sific~~on :: authori~ies. i'UDREN LAW ~FFVCES\ P. C. /' I \j'. V .~ ',t' ilMark J. Udren, ESQUIRE ~TTORNEY FOR PLAINTIFF 18 Pa, C.S.