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Home My WebLink About04-0224 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION . : Cumberland County v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) . : NO. ot./- ;)1.'-1 ~ 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 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as nained in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Wood crest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Concorde Acceptance Corporation Assignments of Record to: JPMorgan Chase Bank As Trustee, c/o Residential Funding Corporation Recording Date: 12/11/03 Book: 704 Page: 3207 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: 333 West Perry Street MUNICIPALITY/TOWNSHIP/BOROUGH: Township of pennsboro COUNTY: Cumberland DATE EXECUTED: 4/29/03 DATE RECORDED: 5/20/03 BOOK: 1812 PAGE: 3462 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 1/13/04: Principal of debt due $88,913.29 Unpaid Interest at 11.47% from 8/1/03 to 1/13/04 (the per diem interest accruing on this debt is $28.33 and that sum should be added each day after 1/13/04) * Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) Late Charges (monthly late charge of $43.97 should be added in accordance with the terms of the note each month after 1/13/04) Other Fees Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 4,617.59 250.00 280.00 439.34 175.88 55.00 4,445.66 $99,176.76 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $99,176.76 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. ~r n, 'OU,,. UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, ,CqMBERLAND COUNTY, PENNSYLVANIA, HAVING THEREON ERECTED THE EASTERN HALF OF A _DOUBLE FRAME DWELLING HOUSE KNOWN AS 333 N. PERRY STREET, - ENOLA, PENNSYLVANIA, MORE FULLY BOUNDED AND DESCRIBED AS FOLLOWS: . "'...... BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE NORTHEAST CORNER OF PElUff-MID ZION s-I'REETS, AT A LINE OF =nS-NOW- OR LA:!'E oF' WALTER J. MANNING; THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, 120 FEIlT TO LOT NO. 9 ON THE HIlREINAFTIlR MENTIONED PLAN; -THIlNCE WESTWARDLY ALONG THE LINE OF LOT NO.9, 32 FilET 6 INCHES, MORE OR LIlSS, TO A POINT ON THE LINE RUNNING THROUGH THIl CENTIlR OF THE PARTITION WALL OF THE DOUBLE FRAME DWELLING HOUSIl ERIlCTED IN PART UPON THE LOT HEREIN DESCRIBED, AND IN PART UPON THE LOT ADJOINING ON THIl WEST; THENCE IN AN SOUTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE AND PARALLIlL WITH ZION STREET, 120 FIlIlT TO PERRY STREET; THIlNCE EASTWARDLY ALONG THIl NORTHERN LINE OF PERRY STREIlT, 32 FIlIlT 6 INCHES, MORIl OR LESS, TO THE POINT OR PLACIl . OF B.IlGINNING. BIlING A PORTION OF- LOT NOS: 6, 7' AND 8, BLOCK A', PLAN NO.1, HOOPY'S ADDITION TO ENOLA. . Image Print Page 1 of6 Homec~Jbumdal AG.!AAt:COmprllay Nov<mhcr05.2OO.J C<<tilicdMail. RdumR...iptRequ<olcd 0435822!ml Jamifer E Sisti 333Wc<tPmySlrllet Enolti, PA 11025 R.: Property Addn:os: 333 W.atPmy Sln:et Enol.. PA 1= A ilcfuul. .xiW11lnd<r the """'" rrf=n..<l MortpJjc",J)ccd "fTrust J""'.....Ol!lCIll. 1'11< IWli<m l<qllirnll<>..... lho default i.lhopaymelltofaU...... """und<rtheM~edofT_lOOll_....nt "" oftbcdatll of this !dk< l1u: toW _ due is S :\.114.13, That..... includes tbc OOIJawitl]j: 3 p.lj'Jl'IlD..l<llsUflg: S 3.011.19 Lat. "-: $ 87.94 Qth.. f... wor ._ S 2.MO Unapplied Fund< : NiA Loon Number. 043SlI:l2m Th.1Ot.l _. d"" shown .bov. i. ~<<ll<> furtI10r in....... fur additional monthly poym......1tM c:haIi<.. .ltOffl.y r..., Mdt", othet r... andoo.. wlti<h may_. due, _l1u: <lat. or this].,,<<. To obtail1 "" Ul'dato! of Ille _13m<lUI1t due.o ""'" this dd'3U!I, cantod lIS:rl UDlU06.1901. TO CLlm TIllS DEFAULT, SEND YOUR CASIIlER'S CIIllCK, MONEY ORDER, OR CERTIFIED CHECK IN TlIE A\fOUNT OF S 3.124.13 BY Ile<...ber lIS. 100"3 TO THE FOLLOWING ADDRB.'l.S: no........lng. FIno_I, P.O. O.x 78416 Ph_Ix, AZ _-'416 OR OVERJo.1GJI'T TO! 1445 W. Dunlop .benue, Soli. tOO P.......lx, AZ lI!01l-lflOJ, If tho dd'owItis not.....d within thirty (30) days of tho m<ili"l! cfthislotttr, the _. without further ncticc or demond, wiU ....tom. tho mtUurity dolo "f tho N... en<! doclilr. aU """'. """-,,,"oj by lbo ~ of T_ to 00 imrnediarely due and pllj'8ble. The lendet !hen intends to haY. l1u: .JllOpety sold o.t . public fcn:closure sol.. Afl<r ....I.ration, . curins of tho dc&ult and ",instakmcnt of the I""" will b. p"""ittcd up '" the tlm. orlho 0llI. by ~1na tho poot due molllbJy ~ IIIld otbor ......lhon duo under the },~/JJoed cfT""" I_ "lI""""cct and by """'I'I~ wiIh oll tcnc. .r tcimtat=- You ba""lhe ri2ht '" btiJ1~. eoort oeti... w ..."" the.- <>r. defaul' '" ""II Olhor defelliJel1u:t m." o;ist to prC\'ellt aocdcration aOO:S.'lIc: of the property. TIllS NOTICE IS SENT TO YOU IN AN ATIEMPT TO COLLECT THE INDEBTEDNESS = TO HllRIlIN "'''1) M'Y INFORMATIoN OBT AINflD FROM YOU WI)'L 13.1i USED FOR 1lIAT PL'RPOSll sin=cly, Loom Counsellng Dcpar1mcn' lILH HornecOtlllngs Flnmdol 2111 Not1" t!(ukel, ^~e -StJife ~O(lJl('!'io. fe;<<l;s 1.;2(lt4 3.>>.20I$.290t tjomtX'Ornifl(ls.oom r~ ,..------- ..._~-----~ ~~\{HIBIT A https://imaging.homecomings.comlimageview/PrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print Page 20f6 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE TIIIll NOTICE fS SENT TO YOU IN AN AT1EMP'T TO COllJlCT TIlE lNDEBTEIlNESS RllFERRED TO HEREIN A."lD M"'Y INFORMATION OBTAINED FROM YOU '\\IlL!. BE USED FOR THAT PlJ"RPCSIl. This :is 1m official not:ice that the ~ on vcur hmue L1\ in dcfauJt. and the Jendtt intends to for.c.clost:. Spt:cific: lnfOfllllLlion Obout the nature of the demol' i'l'rovido<! in the al1ocl>o<I pll\lO'l- The ROMEOWNF.R'S MORTGAGE A~SlST,'lNCE I'ROORAM (lrnMAJ'l may I>< able", help '" ''''''')'OUt" 1>00'0. This Notice _Iains how IIle IlI'OIll'8m """". To... jf HF.f\ItAP ~ 1><11' y"" I1tIl!lt lIWRT WlTIf A CONSUMFR CRlID\T ('AJtJNSFI.1NG AGENCY WlTHW 30 DAYS OF TIIDATIl OF TIllS NOTICE. Take 1his noti.. with you whet! you lI1eel \Vim the CoonseJ.,. Aj>.en<v. Tho ftIIlIle. addte..1Wl....... """,her .f COIl$Utller Ctodil ~ Aoenci.. .miM""..,. Coontv "'" Ii>IeoJ llIthe end oCthis Notioo. If you him: om. qu<sti..... you...y ..tIthe Pmn.yl>...... Ilm~ Fin""". Al"'ncy totl &CC", 1- ~[lO.342-'2397. (J'"""""with inlpni...dh<arini """...11 n!7) 180-1ll<i!l\ This Noti<< oontoim ~ kpl infOfllllLlion. [f you ha.. 3IlY qoostiOlll!.l"qlr<llCl>IllIiVOSllllhe C."""""" Cr.<lit c"""""ling Agetl<y ~ b, .bl, to help 0Jql1airt it. You lllilY 01"" want III ccntaot on atIOOley in your "'"". Tho 1",,01 bor OI!illOciati... may be .ble to Iu:lp you fmd alswJ=. LA NOTlFICACION EN ADJUNTO liS DE SllMA IMPORTM'CIA. PUES AFEeTA SU DEROCHO A CONTlNllAR '\/IVIENDO EN SU CASA. SI NO COMPRENDE BL CONT.llNIDO DB ESTA NQI'lFICACloN OBTENGA UNA TRADUCCKlN lMMEDIATAMENTE LLAMA.'IDA ESTA AOENCIA. (PENNSYLVANIA HOUSING FINANCE AGENCY) SlM CARGOS AL NlIMERO MENCIONADO ARRlBA PLlEDES SER ELEGIBLE PARA tIN PRESTAMO POll EL PROORAllrlA UA'I>fAOO "HOMllOWNER:'S BMERGENCY MORTGAGE ASSlSTANCE PROGRAM" EL Ct1AL PUEDE S,"LVAll. SU CASA DE LA PERDlDA DEl.. DERECHO AREDIMIR SU"lllPOTECA Date: N"""llh<rOS, 2003 TO: Imfer B sisti 3JJ Wffi p""" S_I En.I", PA 1*"..5 Premises: 333 West Porry Street Enol", PA 17025 lk Loan N\JII\b<r: ()43$S-2..'?19 FROM: Hom"""",""", F inano;"l https://imaging.homecomings.com/imageviewlPrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print Page 3 of6 HOMEOW'NERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM \'OU MAY BE EUCWLI: .FOR FlNANClAL.ASSlSTANCE WHICH. CAN SAVE yom HOME FRO.\{ FORECI,()SURE AND HET,PYOU MAKF. JlUTURE MORTGAGE PAV.\fF.NTS IF YOU COMPLY WITIi lEE PROVlSIDNS OF lEE HOMEOWNER:'S EMERGENCY MORTOAOE ASSITANCE ACT OF 1983 (l1IB "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY ll.fORTGAGE ASSISTANCE; IF YOURDEFAIJLT HAS BEEN CAUSED BY CIRCUMSTAll/CBS BEYOND YlXi"R. CONTROL. IF YCltTl!A VB A R:Ei\SONABLB PROSPECT OF BEING ABLE TO PAY YOC'RMORTGAGB PAYMENTS, A.'lD IF YOUMIl!lT OIHER ELIGIBILITY REQUlRllMBNTS ESTABUSHEO BYTIIE PENNSYLVANTAHOUSlNG FINANCE AGENCY. TEMPOlURV STAY OF l'ORECLOSllRE - Undor !be Act, )"<lU "'" entitled l<I a tomponuy slay of foreclosun: on your 1ll~fur- tlrirty (30) dOJlll rrom tho dat. of thiJ Notiu. I::luringlhal1im..)"<lU rIlUSl """'II< 0Il<11lttonJ a "fuco-to..fBcc" m..,uns with om: of !be l>OIlOlUII1<I" co:clit """"""!ins ~ listod at tho &:11d of this Notice. ~ "IKIITIl'<G MI1!1T OCellR WITHIN THF !'<F.XT )0 DAYS !F ymf DO NOT ".PPL Y FflR !l\.ERGENC'!' ~.1i)':~ :'; :..\~!I ;_,~~,i.~5:.'::':;~~.:r..... rc ,1 '. .':';';'~~:!lJj~~~:~_-'"lii..l~. rt..G..~ '.::.::l:1:!i.r:2...!:1..1.M.J~i. _"I": IE ~,:r.gI_rJ::. TI! :~ \:f'JTI,':r.: C.-\~.! ::I~ ';:(~U:. '7:' :""1 RE."'(,l:R. ~.k)k'I'.~AOF. mF:\~ 1.1'". f'XP"...\NS HO\"" ~.(, 'l:,I~,,(: ,=,'.'n.:~. MORJGAOR IJP TO f)A IE. CONS!JMF.R CRmIT COIJNSF.I ,!NO AGF.NCIF.!I- l1yw m.et with on. of tho _or crNit """",,,ling ~ allied at tho end orllli._ce, tht! I_my NOT ts1re llCfion lltlIlwt}'Ou ror 1I1lrty (30) da).. allot tho date cfthis :meeting The: :MIt1cs. addre~ and te1~ numbus of designated CDl1~ <<edit counael~ ap:cncic:s foe tht! eoonty if! which tho ~ i.loeoted ... oet forth., tho wi of Ibis Noli... It i. only lXC""""l' to schNul. one r_to-lhcc meetios !\doriac your IcncIcr immodialCrv of your intcnIicns. APPUCATION .FOR MORTGAGE ASSISTANCE - y"", ~ is in default for the "'""""" .etforthlAlllr in this Notice (.ee fuUowin.e; Jll'SCS for specific inlOtmation about tbc -= of your dofault.) If)"" have tri<d :nul ... """.1. to roooI.. tbi.. problem "ith tht! l<n<Iot, )"<lU ha,.. tbc right t\} 'P1'1y for lirtanci.1 .,..j_ fiml tho llmnCOWl:l<<'s Em_ ~ .~isbJncel'!q;mm. To do so, Jl"U mustl'ilJ out; sisn wi .file 3 complct<d llmn.owner's Em<'IJ!"ncy .....""""'" ~ API'lication with """ of tho ~-d __ mdit "".....ling llll""Cios Ii",". 0' tlw ond of Ibis Noli,..,. o"ly """"""'" _I _ing __'os have oppIi<>lti_ ror tho PfCtlI"'lltl wI.they will .,..jst you in submitting. complc:tc "I'P1ieation l<Ilhc Penn.yivonia H""'""s Finance ~. Your "I'PlicationMUST bofiled orp~<d wilhintlrirty(30)doy<ofyourf_to-fioc. mooting ~f,NDm CONT ACT IN RF.r~-\'"ROS TO PENNSYLVA1\"l'\ HOIlSING Jo1NAi',ClAl. ASSISTANCE HomeComings Financial 2711 Notth ~Il A... Suit< 900 I.:l:1n"" J"""" 75104 Ann: 1.<\$. ~lM Dopw:tmOltt, Stephanie Crouch Phone: 1-800'206-2001. .."'II. 2506 https:llimaging.homecomings.comJimageview/PrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print Page 4 of 6 ALL OORRJ!SP()NDENCE R.EGARDIl'I'G PRFA ASSISTANCE SHOUlD BE FORWARJ)ED TO THE ABOVE REFERENCED ADDRESS. YOU Ml!fI FILE YOIIRAPPI.JCATIONPROMPTLY. IF YOU FAIL rooo SO OR IF YOU 00 NOT FOLLOW THE OTHER TIME PElUODS SET FORm IN THIS Lll'lTEll, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. i\CENCY ACTION - A...ilahlc fund. lOr cm_ mot1;osc ...i&tancc an: very limil<d. They will he di.bursed by Illo Agonc.y oruIor tM oJigillility critoria eslatllisbod lly the Act. The P<Ml}'ivania Housi11g Fin&n<e ~ J... sil<ly (60) day> to _ a dooition .!tor it ...,.,... your oppIication. DutUlg that lime, no fur<clas"'" pt<l<<edittgs ",ill he pwsucd ogoinJityou if}"" Imvemct lh.li1llO rcqui,...ent..cl forth""""', You ..ill be nctificddircctlylly llto ","""yJ\'llnia Housing Finom:e Agoney or.. dooition on yoor application. NOTE: IF YOlT ARE CURllENTL Y PROTECTED BY THE m.ING OF AI'ETITJON IN 1L~'..mUPTCY, THE FOLLOWING PART OF TIllS NOTICE IS FOR lNFOR"VATIONP1JIlPOSES ONLY ANI) SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT THEDERI'. (II" you "".'. m.d b<mkrupky you .... .WI.ppIy .... E'.....D<l' MorlJIllIe A.tdmlnce.) HOW TO CURE YOL'R MORTGAGE DEFAlTLT (Brio!! it liD ... date). J'I). TVRE OF THE I)KF AliT.T - The MORTGAGIl d<bI held lly the above lcn<kr an your property l"",",=d at: 333 W..-t PClTj" Strcd. Enol.. PA 17D2S IS SERJOUSlYJNDEFAUlTb<<J""",,: YOU HAVE NOT MADE MONTHLY MDRroAOIl PAYMENTS lar tMfollowing months and tho follMIll! amaunls or. """ JlIDl due: Mottdllypoynl""tl; I'rom 09101/03 to 11101/03 tOlllli11g: Lot< Ch:lrges: 0Wr f... and/or..,... (inclllding NSF dlar$e' and J>I'Ol'<<lY impo<ti"",)' lESS: UIlHpplicd Funds: TOTAl S 3,OIl.\!< S ~7.!l4 :$ 25JJO NJA S 3,1:14.13 HOW TO CORE TfTR DEFAULT.. You may "'"" the default within IHlRIY (.J(lJ DAYS of !he dolo of th1s Not;'" BY PAYlNG THE TOTAL A..VOUNT DUE TO THE LENDER, \\'IIlCH IS S 3.l.U.U. PLUS M:-."Y MORTGAGB PAYMENTS AND Ll\.IE CllARGiiS WIl1CH EBCOMIl DUB DURING TIlB IHlRIT (30) DAY PERIOD. Pal"''''''' "'U'1 "" tll1lI1e .i1Ilot bv '"""- ._', cheek. certified _ or "''''''''' on:lermade oo..l>l. and sent to: UOOle""mh.p Flnllnelal. P.O. Bm; 78426 PIIoenh, AZ 85062-8426 OR OVER"'llGHT TO: 2445 W. Dunlap Avenue, Suite 100 l'boetdx, AZ 85021-2803. IF YOU 00 NOT ClJRE TIlE DEF AIlLT -If you do no' cur. tho default within IHlRTY (3<)) DAYS of tho date (jf. this 1'1'00<<, the Itnd" 1"lC'ndii; tn e-'(trciM ibi riaht to aetderate the m~t'1Iz:llft ddlL This .means th.'lt the l;loti.rc ou1slandirtil bill"""" or !hi, _ will b. """"idered due immediately ,,"d you may I"". thd <hIlnce to pay lb< ~. in monthly ;",tsllmon... If full payment or the tolBlllDlO!.ll1t pa'" due is ruJt made ",.dUn IHlRIY (30) DA ,{S, tho I.""", also int<nds to instro<t its lID<.-.:ney to '"'" lq;al.otion IV f.,oo1o.. upoo. your m<<lt!ilg<lll Pfap.:rty. https://imaging.homecomings.comlimageview/PrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print Page 5 of6 IF TIfF MORTGAGE IS FORJ1.cI.osm l!POl'i - Th. m~ propert}' will be sold ll\' lho Sheriff to pny off lhc lI1OI1peodcbl lftho lcudern:f<nyour.....to its lIll<xm:y, buLyou<Un: tho tIolinqt=cybef"",thcl<n<kr bo,sjrul losul prooooclinp qainst y""" you will still b. noquired to J'OIY tho _OOIblo 1Illornoy'. f...lhol WON sctuolly itJcUtted, U1> 10 $5Q_OO. _. if logaI proeeodinQ:< ore Itartl!d agaillSt you, ycu will hove to (lIlY all_I. lIlt<lmoy'. r... """,,,"y incurro<lll\' tho lender, ..... if~ <1<<<<4 S5MO. Any lIttome:Y'. fees will be oddoclto !he ,""ollnl you owe the lender. which may 01", inc1ude other _hie oo<<u. Ihou e..... lite <Icfoult wllllIn lite nnRTY (30) llA V ..ricJd,.... ...'1 nnt be mmind Iu .- .ltamev'. r.... 0TfI11.1{ I,F:NJ}F.J<: RJ'l'dE1JI1lS - Th. londormoy 01"" ,.,. you peoormlIy for lho l;lllpOid prin<:ipal bnhwwe om! all Othetoum <lue1.ltUlor the__. lUGHT TO CURE TIfF. DKF Am,T PRIOR TO SImRIFF'S SAI,J( - If you mle not """,4 the dcfuulI wilhm th. THIRTY (30) DAY poriod ODd fO<OCkl..... pt'OC<O<\jllll' !lave hoeurt. you still hAve 1"- rif!u: to cure the d.r...!t and pre\'eIl1 the sale: at anv time up tnane hourbefl:la: the Sheriff's. Sak. You may do so bv pavin~the ~obtlamount Ih.m I'!I"t <lue 1'1.., ll11Y IRto or other <harp. then <lue ,,,,,,onohl. .ttmne;.., r- and Cl1<lts <an....tad with tho fcnclooure "'lIe ond any other ._ ~ will>. the SherifI'. Sale.. ",ooified ill 'IlIt'iIiIlu by the lender and bv p.;rfomJinv OIlY od1arreauiromctrto undc.-!he ~ Curi....l'Our dofaultln tho _or lot forth in this Noll.. willl't.ltortyour ~1lIl. ..lb. .... ,_ ...lfyoo had _r defaulled. Ei\RI.IEST POSSlDLE SIlERIFF'S SALE DATE -It i. cstimllled 1lmt tho earliest dote lIlsl """'. Sherin'. SoJ. of the m,,"-d property "".ld be belli "",,14 bo approlll..atel). .11 (6) ..onth. fro.. tho da.. or thl, NoCkt. Anolieo ofll>..-.J _oflhc Sllerilr.Salewil! be _to you befate lholl8le. Ofoo.....lholllMunt_W ""'" thodef""ll win .........lh.l_)'lJUwait. Ywmay 5ndOlltotOl1)'tim. .xactlyl1lhotthoroqllirod l'")1IlI<Iltor action will be ll\' oontaoliJlg lite 1...00. JjOWTO COl'!TM:T TIJE LVIDER, Ham""""'iJISlFinaneiol 211 t N. IWk.n. Suilo 9()O) Doll... 1"X 15204 Attn: Lallll CotmsdineDcp.- l'IIDno; 1. SlJO.:105.2901 EF FRCT 011 THE SRERWF'S SAI.E - Y".nhoulll real"", that. Shorilf, SoI< will end yow """,.oiliip of !he ~L'll'OJlOlIY ond your righ!1ll OCOU/lY iL If you 00lllinue 10 liv. iIllho property ofIer lbe SheritT's Sill.. . lawsuit to ,,",,0'" you and your fumishineo and othe< be\onsinss oooId be started by the londa: at any time. ASSUlI-lPTION OF MORTGAGE - YOI! may be abl. III ..11 or ~ your ham< to . buyer <lt1l3ns.f"",. "'!to ..,1] ."..me lhol'OC>rle>il" ckbt, provided Ih9l.Ulho out!llandinepnym<nt., ~ and atlomoy'. f... and 00!Its "'" paid prier IU or at tho sale and that the odu!r roq~ of tho mortgage ....lIOti.fiod YOHMAY AISnHAVF.Tfft RIGJo1T: TO SELL TIlE PROPBR"TY TO OBTAIN MmlEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW l...I01'i1JY FROM ANOTHER. LENDING INSTI11JTlON TO PAY OFF THIS DEllT. TOHA VE THIS DEFAI~.T CURED BY ANY THIRD PARTY AC"IlNG ON YOiJ1l.llEHALF https:/ /imaging.homecomings.com/imageview/PrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print TO H!\VE TIlE MORTGMlIl RESTORED TO TIlE SAME rosmoN All IF NO DIlFAlJLT flAIl OCCtJRRED.1F YOU CURllHlJ! DEl' AUL T. (flOWEVER. YOU DG NOT HAVE TlllS RIGHT 10 CURE YOUR DIlFAlJLT MORll1lIAN THREIl TlMliS IN ANY CALENDAR YEAR.) TO lISSBR! 11lE NONE.X1STBNCB OF A DBFAULT IN ANY FORllCLOSI..IRE PROCEEDING OR M~ OTHER LAWSUIT 1Nll"lITUTlID UNDER TIlE MORTGAGE J)O('.L1MENTS TO ASSERT A.'lY OTHER DEFENSE YOUBELlEVE YOU MAY HAVE roSUCHACTION BY TIlE LENDER. TO SEEK PROTECTION millER THE FEDER.AL BANl<R.UPTCY LAW. S"""",1y. Loon coon:oeling D"Jlll11llk'nt Enclo...-e(.) Li<t ofCmm..lillg ~.. Page 6of6 https://imaging.homecomings.comlimageview/PrintImages.asp?DocumentID=41161828&... 12/17/2003 . Image Print Page 1 of6 Homec~ Jbaa.ndaJ. A.GlUL.COnlppRjI' N.".""bcrllS. 2003 Certifi<<l Mail Rdom Rc""iptR<qIl<1Ikd 043S822!l29 LirJdsoy M siotj 333 WonPer!y_ Boola. PA 1102Soooo Reo Property Addroos: 333 WcstPmy Stme! EnoIa. PA 17025 Loon NumbcF: 04358':l~ A t1cfault exi!tl",,<krtho .oo..r<f"""..o M~iDc<<I1lfT_loan...cmmt. Thcootion r<q\lu.o '" """ lito Moult ..lb. _t of all..... due und<r tile M~Deed onrustIcon llIll'IlOlllOnt. "'" .rlho.we or this Ictm!he kMa! amoonl due i. 5 3.124.13. That llUl1l include. the foIlawi"!!: 3 l"lymmts to4llling; S 3.011.19 Lat.~, $ 87.94 Other fa:ulldlor cost> S 25,00 Unapplied Funds, N'A Th."".1 _ <h>o shown .1xm is subjoct: to furth<r in_ tOr odditi...u monthly poymm", IaI<! dlargo", """"'ey f<<s, ot>dIOI' otbet C....lId oolli whi<h m.y1>eeom. dot, IIllet tho dote oClhi.lett... To obtain lilt 1ll'dalc of lb. tot.! amount <h>.to cun:lhi. cIcf""l~ _usotl.800.:z06;1!Hll. TO CURE TIl1S DEFAULT, SEND YOUR CASHIER'S CllECK, MONEY ORDER, OR CERTIFIED CHECK IN 1HB A.\1OUNT OF:II 3 lUU BY Ile<........ ll!I. 101)3 TO I"HIl FOLLOWING ADDRESS: :no........I... F1n.ndal, P.O. Sa.. 7lW26 Ph.....l.. AZ 8S062-41426 OR OVERNIGJIT TO; U45 W. Dunlop A,'mu., Sulfo 100 Ph.....Ix,AZ lIS0:ll.28O.l. If the deIlmIt is not...,.d within tIUrty (:l<J) days of the ...ilin@ofthi.lctler, the _, withaul furthc.. noIice OJ: o:IeIniJDd, wiU "",.lonte the IlIlUurity date of tho Noo. md doclnr. oil """'. ........d by tho ~1JJeed of T_ to be imrnedialAoly duo md payable. The hondet then inlellds to have the JlI'OPOl'lY sold at . public COI"Ccl.csur. ..k. Aller 0c<c1Cllltion, . ourins of tho default and reinstDI"""", of tho loan will b. p..",itted "l' '" the time of lho oal.1:>y pll}1n& tho pool dl.. IIlOnlbly paynttfnls IIItd other .....,.lhon due \lllder tho Mo11gQ8f!Doed ofTIUlilIOllll ~ and by complying willi all !cml. of rcimtatcmcnL You haw lbo rilllrt 10 bring . coort _ 10 ...ott lho""""~_ uf . delllult or any 0Ihet def..,.. tMt mal' exist to pre\'ent accdcraticn and sale ofthr:: property. TIIIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT TIlE Ir>i'DEBTEDNESS REFERRED TO HEREIN A.'ll) ANY Ir>il'ORMATIONOBTAINllD FROM YOUWll,LBE USED FOR. TIiATl'l.lRPOSE Sincerely, l..oon C"""""lmg Doparlmcnt mJJ: Homecomings Fi"ICIf1dal 2111 Hof1:h Hmke" ^~f'lue SUItt) 9(.QOQ~lOs. Te;<<l:!: l.~ OO).2lJo$.290l HomQt:Qmif1(Jl'.CQrf!l https://imaging,homecomings.comlimageviewlPrintlmages.asp?DocumentID=4116181 0&." 12/17/2003 . Image Print Page 2 of6 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Tmll NOTICE IS SENT TO YOU IN AN" ATIEMl"I TO COllECT TIlE lNDEBTEDNBSS REFERRED TO HllRElN A'm A/:<"Y INFORMATIONOBTAlNED.FROM YOU WILL BfiUSED FOR THAT Pl'RPOSE. Th'is is sn official notice that the ~ on your home is in default. and ,tht: )Lmdu intenm 'to foreclose. Sptcific jnfomalioo nOOut the nature of the def:mJ, i. provided in the .tt""b"d ~ Th. HQI.>TROWNR...S MORTGAGE ASSISTANCE PROGRAM iHIll'AAPl mov bo ahlo to holp '" '''''' },,,,r 1\001,. This Notice """Iains howllle_ __ To ,.. if !m!\1AP "'" help. ,'OU m..t MFFT WITH A CONSUMER <::RRmT C'.ollNSRT .!NG AGENCY WlTIIlN 30 DAYS OF TH DATB OF TIllS NOTICE. Toke this notice Ifoith you when va" meet wilh the Counsef"'l'~' The name. oddre.. !lfld tlhooe """,her orCOIl$lIlIler Ct1l<lit eoon...Jinlt ~.. ,.mn.: ""'" C<l<mlv ....Ii.r<d at the end of this Notioc. If},," """" lll1yqucotillT1!l. "'" IJ1Ilv<:oll the Pmn.~I;m..Holl5in~Finl1ru:.~toll m,.,.tl- ~OO.342-23n Cl'_ wiIh it11peinx! hmi11ll"",<:ol1 nJ1) 7l11).l3@). Thi. Noli.. eontaim important IqjoI infllllUOlioo. If}'OU have llDY """oti_, r<pIllscutali... al the Conmuor Credit c~ Age~ may b. .bl. to help ""Plain it. Y""ny 01"" want to ""'tllCt1lll1lttOtlley in your ""'" Thelocal bar ."ocistion ""'Y b. able to help "'" 1IrnI.1swJ=. LA NOTlFICACION EN ADJlINTO ES DE SUMA IMPORTk'JClA, PUES NEGrA SU DERECHO A CONTlNUAR VlVlENDO EN SU CAllA SI NO COMPIlBNDIl BL CONI1lNIDO DB ESTA NOfIFlCACION OBTENOA UNA TRADUCCION IMMEDIATMIENTE 1.l.AMf\:NDA ESTA AOENClA. (PENNS YL V ANL-\ HDTJSlNG FINANCE AGENCY) SlN CARGOS AL N1.lMI1RO MENCKlNADO ARRIBA PUEDES SER ELEGIBJ.E PARA UN PRESTAMO FOR EL PROORAMA LlAl\,fAOO "HOMEOWNER'S llMEKGHNc:Y lI<lORTGAGll ASSJSTANCE PROGRAM" EL CUAL PUEDE S.<\!. V AR SU CAS.4. DE LA PERD1IlA DEL DIlRECHO A.REDlMIR SUlIIl'OTECA. J:lat<:; No\'l:lllhcr05,2oo3 TO: Llndso;' M Sisti 333 West p""" S1l'<<t Enol.. FA I msoooo Premises.: 333 West Pmy Slrort Enol", PA 17<lZ5 Rc; Lmm Nlmlbcr: (14351l22929 FROM; Il<>m<<<."".... Financial https://imaging.homecomings.com/imageview/PrintImages.asp?DocumentID=4116181 0&... 12/I 7/2003 . Image Print Page 30f6 HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM \'OU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME .moM FORF.C[,OSURF. AND RF.LPVOU MATO; FUTURF. MORTGAGE PA VMF.NTS IF YOU COMPLY wmr 1HE PROVllllONS OF TIIB HOMEOWNER'S EMERGENCY MORTGAGE ASSITANCE ACl' OF 19&3 (l1lE "ACT'), YOU MAY BE EUGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DE.F AUL T HAS BEEN CAUSED BY ClRCUMSTA1'1CES BEYOND YOliR CONTROL. IF YOUHA VB A RRASONABlS PROSPECT OF BIiING ABLE TO PAY YOUR MORTGAGE PAYMENTS. A1'lD IF YOUMEBT OTIIBR ELI0IBlLflY REQUIREMENTS ESTABUSflED BY TIIB PENNllYL VANIA HOUSING F1N"'iNCE AGtiNCY. TEMPOJU.RV ST.\. V OF FORECLOSURE _ Under the Aci, >"" om: enlitlod to . tcmponuy slliy ofib",clor= <lI1yOUr nlortJlOlle fur thll1y (30) doys from tho dol1I of this NOli.... n..rJns 1IllIl tint..}'l<l- _ aml attend . "E=-ta-fs",,' mooting with """ of tho C<lIISU11ICI" credit """"",tifl; aamci<s listed .. Ihc ond of this Notice. 'fll1S ~$TII'IGM\JSTOCCUR WITHlNTHli: m:U JODAYS. IF vmrOO'NQT APPLY FOR BMllRGIlNCY MOR.TGAGE ASSISTANCE. YOU MUST BRlNG YOUR MORTGAGE UP TO DATE. TIIll PART OF nns NOTICE CALLllD "JIl:)W TO CURB YOUR MORTGAGE DEFAL'L1"', EXPLAINS HOW TO llRllifG YOUR MORTG,\GE ~jp TO PI\, Tn. CONS\J'MER CRlmIT COliNSF.T.ING AGF.NCJE~ - If you m.\lt with on. of tho _.r orodit """"",11ng .genc;..liited at the ondoClhislllllioe, tht ."""""",yNOT IaIre IICIiMagainstyoU Illrthirty(3O)days: an.tlhlldat. IOfthismccting. The name!., addrcgc:a :md tclepbanc numbcn. of delriF'3lQd ~OOSQmCl' a:cdit c:ounsel~ ap.cncic:s b the count_ in which IIlo pro~ i.IO<lIted ore set forth at the end oflhi. Notice. It i. onlY"""""'Y to.m..lul. """ f_1<>-...c ""'<l~ Ad....:fOUl" kndcr immcdialclv .t your intcnlicm. APPLICATION FOR MORTGAGE AllSISTANCE - y"", ~ i< in ""-fault for Ibo .re"- sot Illrth 1lIler in this Noli"" (.ee fuUowinjP"i'" fur specific inibrn""ion about the -." ofyourdefauk) If,,,,,h,,,,, tri<d IlIld .... _bI. to mol... tbi.o problem with lbe !.lnder, y"" 1>""0 tho right to "!'Ply f<1t financial ...._ from the I!cm<:owr.e,'s Em"'ll"""Y ~ .""'istsn", Pr"l1""". T" de Il<1, }"'U ......fill out, sioln ..,a fil. . <:ompIckd HooI.owner.. EmoQJon"Y Assi._ i'ro;!roro Applicotion with Me of the ~ """"""'" crodil oo""""lq egenci.. H>ted lit tht end cUrio Noti"". Only """"""'" _I_ling egern:i.. ha.. "!'Plwoo... fOt'the__ sndlbey will assist >"" in submitting. complete 'l'Pli<ation to thcl'<nmyw.m.Ifoosi.s FinaneeAgrncy. Your opplli:etj"" MtJST h.lll<d or pcotmotl:<d wiJbln thirty (30) days: of your f....-lO-fac. mootq f,~l''Dm CONTACT INR~C#\~ TO pF:NNSn,VAI'IlA ROUSING JTlNA<'!f:IAL ASSlSTANL1!; Home<:\wningsFinanclal :m 1 NorthHlllIkoll Aw.. Suite 900 Dall~ Texas 15104 Ann: Loo. ~M !)opoJtm.nt, S'ophnlli. Crouch "Phone; 1~8iXl-.206-2001, e:,,:t. 2506 https://imaging.homecomings.comlimageview/PrintImages.asp?DocumentID=4116181 0&... 12/17/2003 . Image Print Page 4 of6 ALL CORRl!SPONDENCE REGAlIDI."fG PHFA ASSISl'A1"1CE SHOUlD BE FOJlWARDED TO TIlE ABOVE RIlFERENCED ADDRESS. YOlfM!m FILE YOURAPPIJCATION .PROMPTLy, IF YOU FAIL TO 00 SO OR IF YOUOO NQT FOLLOW THE 00IIER'I'lME PERIODS SET FORm IN THIS LEtTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOMllIMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSLSTA.NCE WILL BE DENIED, AGF..NCV ACTION - A",iJohlc fund. for emergency Dlortpsc ...islanoe Ole V<rf'limited. They will be disbursed by the Agency under the di@jbilily <<iteria .slohIiWd by tho Act. Th. P...-..ylvani. Hollsin$ .Finance .'lgency has si.'<ly (oo) da).. '" _ . decision _ it toeci... yoot appliCllti""- Duri.rlg thai lime, "" fur<<I"",,,, P"'~ will be puI"<lICd agaiJ1Ill }'tlU if y<lU luM: met the Ii.., requi_ ..:t forth above. Y O\l ..ill be notified direotly by the P.......yl\'llllia Hollllinl! Fintmco Agency of il:! <loeU,on on l"'" appJi...ti..... NOTE: IF YOU ARE CURRENTLY I'ROTECTF.D BY THEm;ING OF APETmON IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR D.'FOR.'IL-I:TION PURPOSES ONLY AND SHOULDN<Yl BE CONSTRUED AS AN ATTEMPT TO COLLECT THE DEBT. (If you Ila... Oled .....kruployyou ....IllUl.ppIy ror E_1IIl>rtpae A..Iot.......) HOW TO ClJRE YOUR MORTGAGE DEFAULT (B.rlnl! it UP W date). NATURE OF TIlE DRFAULT - The MORTGAGE dab! hold by the aboic lrnder on yourpl1Jj>Cfty loo:atcd at: 131W""PcnyStr<et,Enola,PA 17005 IS SERIOUS!. Y IN DEF AOLT be'Jlm"" YOU HAVE NOT MADE MONTHLY MORTClAGE PAYMENTS for lb. fullowing Il1Qfllhs and the fo1Iowins 1ImDUl1ls... now JllI'l due: MlnIhJy l"'ym.... _ 09iOli03 to IllOllll3lCtll.liJlg: laic Chqes: 0Ih0r f.... ondlOT ~ (mcludin@NSF <Ilari#' and l""P"'lY inopecti_)' I.E:lS: UO"PPlicd Fumh: TOTAL S 3,011.19 $ 81.94 $ ~S.OO NIA $ 3,124.13 JlOW TO CtJRl1. -rm: DEI1AUL T - You m.y ouro tho dafauJt within TI:IlRT'I (0) DA'iS of Ih< dal.l of this No'ioc BY PAYING TIlE T<YlAL AMOVNT DUE TO THE LENDER, WIllCH IS S 3.124.13. PLUS tu"-Y MORTGAGE P AYMBNTS A1IID LATE CHARGES VilllCH BECOME DUB DUR.INV TIlJ:l THIRTY (30) DAY PERIOD. I'll'''''_ "'"'" re I!'Illda ._ bv ctWt. c..me.-'. ",",ck, certified check Of money order made oo,..b1t Iltld ~to; H<>mecombtll" Flnlmclal, P.O. &" 78426 Phoonh, AZ85062-8426 OR OVER1"lIGHT TO: 2445 W. Dwdap A veuue, Sulre 100 Pbcl<!nl., AZ 85021 c1803. IF YOU DO NOT CIJ'RE THE DEF A1.1LT -II' you do not cure the dafnlIt within THIRTY (.l{i) DAYS of the date of this NooiX'.the If:ndt'rin:tend5 to ,f'lfrciSlt ip rb!ht to act:dtrate:the nlQfizl~ debt Thi$ :mcans that. the l,.'11ti:ro out'<ton,tiog balance of lIli. deb, will b. c"",,idared due imlnedi0t<l)' and yoo mo)' lose the <honee to.pay the tooftJlllgll in month!)' ;",'allments. If full paymca:t at' the lCtll.l _unt ('IS! due is no' made within THIRTY (30) DAYS, the I.oo.r 01:;0 iot.."""", to inmu.:t its euomey '" 0llil11<1]ll1"ouon to for,""o.. "1>00 rourmO<tJlllgedproportj\ https:/ /imaging.homecomings.comlimageview/PrintImages.asp?DocumentID=4 I 16181 0&... 12/17/2003 . Image Print Page 5 of6 IF TIfF MORTGAGE IS F01l1'~l,osm liJ'ON -lbe m<lf1l!alled pr<>perty....ill be sold b).'lhe Sberiff to poy off fhe ~ oIcbt. lflbo Icodcr..r.n your ""'" to .. aIlorncy, but you cure Ibo lI:linqucnoy befcn: lhe Imder b'l!ins IqpU proceocIinp IIlllIm y{lU. you will still b. roquirod to poy tbo ...._bllllllornoy'. f_ thai '""'" aclualIy incumd, Ill' 10 S50.00. IIcwev<t. if lellllll.'tt"'edlIlgs .... .llIrled agaiDst you, you will !lave to pey all _I. altmn.y'. fees aotulI1ly ioo.uoclby tIlO lender. ..... iflhoy _d SSO.UO. Mj llltoI:r>oy's fees will be II<Idod II> tho amount you .... tht knder. wl>i<:h may also irn:lude other _blo <<J6I>. If vou .un the default wlltlla tb. TUIRTY (.Jill DAY JM!t'Iod._ wIIlallt 1>0 <<Qlljrod In pO" fttlun1ev'~ t.... 0TIfF.1l. ',1!ND~ RJ1I.IJmIF.S -lbolender may ill", .... youpelJlODlllly for lhe ""P'Iid principal boloIl..lllld aU _ """" due under the mor!llIlllO. RlGffr TO CURl'. mF. DEFAlJI,T PRIOR TO liHERIFF'S SAI.E -If}'<>u mv. not """,d the defIIulI within fhe THIR. IT (0) DAY period and foreolo..... proceedings haw begun. you still he... !he rifT< '" cure tl1. <I"llUlt ROd rrevenl the sale at IIIlV time un to anc: how- befoce tlu! Sheriffs. Sale. You YmV do so b\'pa.vine; the total RITlotmt then 1"-'<1 due. plus lI11Y I... or other <harp. then duo. r..">n.ml. altorne;--_ f_ and """'" "on_tOO with the f~ OllIe Illld any o!h<r ...... '"'''''''''''''' with the Sheti:ff. S.I. as ",ocifi.d in WI"itinIt by lho Ier<ler and by Porfurminll "'C' od1ot reaui_ ondortho.-\iVv. Curing your d....ult In tbo _or sot torth In this Noll.'" w1Il...roro)'<lllr mortg... to m. ... 1'- as lfyoohad........ defaulted. EARl.IEllT POS8IDLE S1lERlFF'S SALE DATE -It is .."mated lImt tho emliost date that.....n. Shcrill'. S"lo of tht martjjopd property """lid bo 1>>1d would be .pp"'Il.....). .Is (6) .ooth. front Ibe dote .fthis Nollot. ~.t>lltio< oflhe_ _ oflh< SllerilI's Salo will be _t to you bef....thellllkc Of oourse,fhe_ ml<ded '" ""'" tho dof>JUJt will inoroooc 1h.1""8l't you waiL y"" maytind 0llI 6l3l1l' tim. """",ly wbattho requit\o~ 1"\l1llmlor action. will bo by oontaW.ng tho lender. JIDW1:0 CONTACT 1'IlE LENDER, HilmeoomillllS Financial 2711 No Hask<ll Suite 90(1 NI... "IX 7:5204 Altn: Lo",,~nq,_""t Pli"",,; 1.SOQ.2IJl5.2901 F.lIF'ECT 011 THR llHF.RWF'S SAI.R - Y"" should "",Ii", thai a Sh"riff. Sale will one! your """.l3hip oflh. m~ J'lOP"llY IlI'ld }'Out right '" ""''''P:>' iL If you <ontin.. t"liI.. in lb. property aft<< tho Sheriff. Sale. . lawsuit to remove you Illld l""" furnishiOSS Illld othor bol~ oouId be -..:d by the 1_ at any time. ASSUMPTION OF MORTGAGF. - Y 00 ....y be 1IbI. '" ..u or tllWf.". yoor Itome ro . bl.\)\<t '" mwf.... who wllJ os...". the mc<lll"i" debt. provided thot allllw: ouU!mdi"l!jl<l}"'.''''; ch"'1P and afulmoy's f<<s snd """I. or. paid prior '" arSlIlw: OIlIelll'l<llhat lh< olher""lw_ of!hemOl1ll"Il""'" sati.!iod. \'OlJMAY AI.80RAVETflf. RIr.HT: TO SELL nm PROPERTY TO OIJTAlN MONEY TO PAY OFF TllB MORTGAGE DmT OR TO BORROW lvf0NRY FROM ANOTfffiR LENnING I."J:>'1'ITtmON TO PAY OFF THIS DEBT. TO.HA VB nlls DEFAI.lLT CURED BY ANY THIRD PARTY ACTING ON YOUR BRHALF. https://imaging.homecomings.comlimageview/PrintImages.asp?DocumentID==4116181 0&... 12/17/2003 Image Print Page 60f6 TO HAVE TIlE MORTGAGE RESTORJID TO TIm SAME rosmoN AS IF NO DEFAULT l!AD{)CCL1RRED. -IF''YotLCIlRli TIlE DEF AUL T, -(IIDWEVER, YOU DO NOT HA VB TIllS RIGHT TO CURE YOUR DEFAULT MORIl TIlAN TIlREIi mms IN ANY CALENDAR 1'I!AR:) TO ASSERT TIlB NONH'(ISTENC6 OF A D6FAULT IN !\NY FORllCLOSURB PROCEEJ:llNG OR. ANY OTHER LAWSUIT 1NS'ITTIJI'IlD UI'<'DER TIm MOR.TGAGE DOctiMENTS. TO ASSERT A.'IY OTlJERDllFENSE YOUBELlEVB YOlJMAY HAVE ro SUCH ACTION BY TIlE LEND~ TO SEEK PROTECTION UNDER TIm FEDERAL BANlOUJPTCY LAW. S"","",ly, I..-.C~D~ EDclo...-.{o) Lisl of Co~Iir@ Agenci.. https://imaging.homecomings.comlimageviewlPrintImages.asp?DocumentID=4 1 161810&.., 12/1 7/2003 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. ~dre ESQUIRE UDREN LAW OFFICES, P.C. ~ ~ ---- -i'::::.. E;'- <J\ ;-.1 o f-) -.& 1...1 -';1 L_ :; 0' ~ -m- - V, U\ \..-,'\ <1) '" ""- - ---0 -;11 = ;>:>- - 5= C' 5L- ., <'" ::> SHERIFF'S RETURN - REGULAR CASE NO: 2004-00224 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS SISTI LINDSEY M RON KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SISTI LINDSEY M was served upon the at 1953:00 HOURS, on the 22nd day of January 2004 DEFENDANT at 333 WEST PERRY STREET ENOLA, PA 17025 JENNIFER E SISTI, by handing to ADULT IN CHARGE 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 18.00 11.04 .00 10.00 .00 39.04 Sworn and Subscribed to before "'" me this .:i '{ - day of (f~~;2OlJ'f A.D. C Q fn~,~/~ . P othonotary ,~ So Answers: -;;},,"""'q'/-;,:.<'i"~'i~ ,:' ....... ",'.'.>> "'l R. Thomas Kline 01/23/2004 MARK UDREN By: ~~ Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-00224 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS SISTI LINDSEY M RON KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SISTI JENNIFER E the DEFENDANT at 1953:00 HOURS, on the 22nd day of January 2004 at 333 WEST PERRY STREET ENOLA, PA 17025 by handing to JENNIFER E SISTI 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 Aff idavi t Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 0. ./p' ~~ r::-r::r'. ~. _";" '" .,,$ ~.,'- - . -.-,......... .~ ,.,:;1'" .c..;'...:...,....'.'..,,-_. ',_.<-.'. ,/~~ R. Thomas Kline 01/23/2004 MARK UDREN Sworn and Subscribed to before By: &~ ta me this ';(7~ day of ~~'1 A.D. (i Q /YwOI<" .0& pr~otary I ~/- I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Lindsey M. Sisti Jennifer E. Sisti Defendant(s) o&l NO. ~-224 Civil PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. UDREN LAW OFFICES, P.C. DATED: February 27, 2004 BY: V E R I F I CAT ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: h~ <;:},c2oD'l ~a N~e: ,ere/.:; tJ{~ . T~tle: Ih~f-. Pice; fJAuum'l1'/ Company: _. l:i&mecr/Y'(:J /rn;7/'CldJ ;je-fiWlk Lindsey M. Sisti Jennifer E. Sisti Loan #0435822929 MJU #03120543 (") S :,;.. "TlrT' nt~l,. ;;; ;:~~' ~.~~~':': .-'- ~C.: >E~ ~ --.;. ..., = c-"' or- ::II:: > ;00 I W o "Tl -l ::r: nl~ -om 66 :r!"'Ti ~-." ~~ ~ V =:!: w (~.) (TI UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 0"'- NO. ~224 Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the plaintiff and against the Defendant (s) for failure to file an Answer to 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 1/14/04 to 2/27/04 Late charges per Complaint From 1/14/04 to 2/27/04 $99,176.76 1,274.85 87.94 TOTAL $100,539.55 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. UDREN LAW OFFICES, P.C. DAMAGES ARE HEREBY ASSESSED DATE: (fl';:ULr (, 3, ~0CJ'f 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 JP Morgan Chase Bank, as Trustee c/o Residential Fundin~ Corporation Pla~ntiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Lindsey M. Sisti Jennifer E. Sisti Defendant(s) NO. ~-224 Civil TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 February 17, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. DATE of Notice: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE 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 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLE R AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION 0 D WILL BE USED FOR THAT PURPOSE. \ /s/ Mark J. Udren, E qu~re Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 JP Morgan Chase Bank, as Trustee c/o Residential Fundin~ Corporation Pla:mtifI ! COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Lindsey M. Sisti Jennifer E. Sisti Defendant(s) 61.( NO. ~-224 Civil TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 February 17, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. DATE of Notice: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT CO LAW FIRM IS DEEMED TO BE A DEBT COLLEC COLLECT A DEBT. ANY INFORMATION OBT PURPOSE. LECTION PRACTICES ACT, THIS R AND THIS IS AN ATTEMPT TO WILL BE USED FOR THAT /s/ Mark J. Udren, qu~r Woodcrest Corporate Cent r 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 .< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. AFFIDAVIT STATE OF /Il1?'",;.eS'()~ COUNTY OF ~Or..h7Cu OF NON-MILITARY SERVICE SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon invest~gations 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: Lindsey M. Sisti Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Jennifer E. Sisti ~~~ldence: ~~e~a~~ioned abOV~. / ;- Employment: Unknown ~ C-/~ ~r l~. j<?IC'c u.J11ke,t , Company: j)-"6f-; v/~u PI>Utc4A;/ J/..rYvn e e OIrljy ;::', nan? let! J<-/ tJ.1,Wtf)k Sworn to and subscribed before me this aZ day of r.bb/Wl.~' 20t7~ CalvTne/P. 'if ~r?~. Notary l'Ubl~C CJ ~----..----. ;.. - - CARMELA D. LAGARILE ' . NOTARY PlJBLIC. MINNESOTA ' MY COMMISSION ' ~ EXPIRES JAN. 31. 2008 .: ~. . . . - . - - - - - - - t -p 0 ..tq ft- ~ -c 0 ...... cc:> 0 0 ~; c=> --n .r- ~,~-J~ .... ~ "1 0 '=c :::r: - :v- f1,::D r ~ - AJ " "'Q f? :";/ -on'1 ~ (t\ I -~.(--; j ~ -< <..-, ,Sf., 10 ,-,. -~ _:~I .. -., 7~ :',~j III :B _0.... '.;;.:;-'(j , _:.... ~ -ft >''', W t'~l'n ~ .. ~ .~_l ..- -.,., , (,) -~ 0-'1 -< 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Ol{ NO. ~-224 Civil TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest From 2/28;04 to Date of Sale 6 9/04 Per diem $28.33 $100,539.55 2,917.99 (Costs to be added) $ UDREN LAW OFFICES, P.C. r::J ~ p ~ ~t r ~ C e. '+ ~ 1 ~~ ~ g r-{) ~(' -- w ~ () .t::. f ~ ~ - - ~....w~ JlJ ....0 trt f' :0 ~ ~6~OODO DC O<e, I I I I V "~'~F- .... ... ... "'" ~ .:.:::::~~ ,<.":.,. :::::. 2t;<; t5~ '>. r~: l. 2: f'.> .....) --.. C"'"J ~ ....; ~ .. ~.~.: .-1 .-:J... ::c -n -:D'.' r11= :;0 -om I ~nQ 0.J SQ -," ~~ ':'? -j (,,) C"~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-224 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE C/O RESIDENTIAL FUNDING CORPORATION, Plaintiff (s) From LINDSEY M. SISTI AND JENNIFER E. SISTI (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 attachmeut has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upou an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $100,539.55 L.L. $.50 Interest FROM 2/28/04 TO DATE OF SALE 6/9/04 - PER DIEM $28.33 - $2,917.99 Arty's Comm % Due Prothy $1.00 Arty Paid $137.04 Plaintiff Paid Date: MAR4CH 3, 2004 Other Costs CURTIS R. LONG (Seal) Prothonotary r-; ~ o..J!y: ~O~,. ~~. / '(~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY 1.0. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. s?f~0 ~!~: - ~-' ~_: .3-" (') <;::;: ...., = = o -0 =? ffi::D .- :om _00 () ; ::;jQ ~;~ ?tt ,,~\fTl ;~:l .:- 3: ~,. ;:0 I W (:1 J '='? (..> 0' --<. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 1 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, (East pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.). 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address Same as No. 1 Above 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other knowledge who has any interest affected by the sale: Name person of whom the plaintiff has in the property which may be Address Tenants/Occupants 333 West Perry Street (East pennsboro Township) Enola, PA 17025 (Incorrectly Stated in legal Description as North Perry St. ) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 27, 2004 "'-- ~:} ,- ::';::, .,.;-:, n r- ~,..: ~;i c.) 0', ,...., C7,;o C::::l ~ - :WlO ::u I W () --r; -/ fhiJ:~ =38 ~() ..""-1-, ;.J ~;j <~n'! -::J (,..) :::J :< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 'COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, (East pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorneyls fees. To find out how much you must pay, you may call: (856) 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. 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 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 o c- ~ -r.:i::-': [~): ;' "-> = = .e- :l: :r>> ~ I W !--', :-0 :;::: L...~ _..j -< (.~.) en o _1 ---I :r Ill::!:'! -0:;; ~Py '~C) ...,- --:', ~~., (') fn UDREN LAW OFFICES, P.C. RY, Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, (East Pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney!s fees. TO find out how much you must pay, you may call: (856)-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482- 6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 C) "" 0 = c;:; = -n .r- . ~ :z -, ",., -,-. ~ d'j ",. f('i , = r= .'.. -om ~~ , cOy w 86 -,~-r\ :~~ -n (~ -.'t ...-~( ~. C5 '- (~~. ~ll !1 '(::. (-- '-', ',:\ :':3 Go) '. -' UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff . - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Lindsey M. Sisti Jennifer E. sisti 333 West Perry Street Enola, PA 17025 Defendant(s) : NO. 04-224 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a I:rue and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party kno'ml 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". Dated: May 3, 2004 orth by Pa Rule C.P. All Notices were served within the time 3129. This Affidavit is made subject to the p relating to unsworn falsification to au 18 Pa.C.S. Section 4904 ,AW BY: Mark J. Udren, Esqu~re Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 1~TTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 04-224 Civil v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) DATE: May 3, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF I S SAl~E OF REAL PROPERTY OWNER(S): Lindsey M. Sisti << Jennifer E. Si.sti PROPERTY: 333 West Perry Street Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 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 AM, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your int:erests. 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 ~ ~ - -00:0 m- ~ ao~ .22 0)_ ~.S 0 ~~ $ (l) E '5. "'_ 0 0-00 Ea>(ij sea ~!E;e ._ t"O :.c B-g 'Q ~ $ "iij{f)l.1. ~ e.; ~ ~ $ _o:u. ;; '" "g Q; ""0", 't: aio "",U ~ ~~ 0':,0 ~~ 8 a"ffi a>i.E> g ~ f! a ~.5 m ~_ 1ti "C ('lI '~'ffi~1& e:E1i)C 8:~~g tt1Q),CJ:: ~(;):'!:::t::: Oleo ~ 'cn~ s: ~ e' "'moo-g~ t) 0::: tU..c "'U .8 '" g :c .E Qi o :e. 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MAY -.,1 A ,'::' ~~ v.~ . ~ .. i '''''~ - I ., 0 - . v#iflri,l,J.l,:: ... ::::. \'- -- -. '::';"e.M~lE" L ;:, ',!j ~/ . (.(Jt.725~ I.. m 0> .!i ~ o 0- '" ~ ..- ,; >- _0> ;; '" ~ 00 ~ 1ne ~ ~'" ~ "0 "'" en to " ~ "0 m~ C) WO < ~r- Q; -.\1 ~ m ~~ 0 "'< i5 ~ -. "'. m ;;: <= " ~ Q. 0 0- " ~ . m . '" e- en",,,, ;; ~e> .<: en f;'N"Ie ~,. 0 <= ~ '" 00 ,.~g;~ 7\.~' " 0- m.o "Ie ~ ",r-z ,if:'\. "0 > ~ 0 ~ 0- ~ ~ ~"" c m.<= Z g ~ o:~ '" -<" -~ "Ie ~ 0- <= (~ ....... ;;' 0'" ~ 5 " '0 .... ~ 15. :;;: ~,- 1il m'" <= U co; g:g 0"- .>2 ~ ~w ~ ~;i;i . ,; '" 13 m <ig Gl 15. -m ~ O-N en VJ .E2-o ~ co. <='" ~ -"'- m c:VJ9.: -6 o~ ",m ~R x 1i~m )i1 ",0 " ~o-' " Qi~ I- 01- m '0 ~ ff a:< Gl oe-5 00. ..'" m <= <= -~ 3.8 .5 E o.~ :;;ai ~o ~ EO. "''" Wr- <=~"O Z EE E'E ~~ ~ <= m 00 0 ~ ffiffiE uu OC) 0:0- I-O-~ ~ m 8~ .!!!o ~ ~ 0- ) ~m~ E"O ~ m z> -.cp g~ ~o: C Gl D.. ~ c '0 D.. co ED ~ o -'" .E / ... Ol Ol ~ ~ '" ::> .0 '" ... ~ '" <= m m ..- ~ >- E~ " - '" m <= ~ m 0 .o~ :a;~ N EO z ~ M ~U __1= <ii EO 0 U"O -,?- m "' <= 0 ~ N CO) ... ::J ~ N CO) ... "' <0 r- "" Ol ~ ~ ~ ~ ~ ~ ~ m u m . ~l~::: o CO ~ Q) (l') .0", E ~ ~ 18 T ~ g,* UJ ~:::i ~ JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation VS Lindsey M. Sisti and Jennifer E. Sisti In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-224 Civil Term Gerald Wrothington, Deputy Sheriff, who being duly sworn accoTding to law, states that on March 09,2004 at 8:05 o'clock PM, he served Ii true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by making known unto Lindsey and Jennifer Sisti, personally, at 333 West Perry Stn:et, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to them personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2004 at 5:33 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lindsey M. Sisti and Jennifer E. Sisti located at 333 West Perry Street, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by regular mail to their last known address of333 West Perry Street, Enola, P A 17025. These letters were mailed under the date of April 13, 2004 and never returned to the Sheriffs Office. This _ day of ~~~ R. Thomas Kline, ~e;:r; BY' l~rll J\.SwLcth Re~~uty Sworn and subscribed to before me 2004, A.D. Prothonotary r. '''\~~ "'n~r.'? ~ L' . ',...J",,"~J lJ \,J 0 ", 0 = c = -n -;-'Y .r- 'Jr'", :z =l :L...,. r-n ~.. :>z,- rnp= c, -< ,.. -nrn ~) N -;10 OJ 0(:' r:~ l ;-..J-Ti :s: ~ -0 ~~ "? '. -:~.. (~! :;:r:. ~.) ---I .. ,--" N <'I} -< N :< JP Morgan Chase Bank et al VS Lindsey M. Sisti and Jennifer E. Sisti In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-224 Civil Term c.... R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Surcharge Postpone Sale Law Journal Patriot News Share of Bills 30.00 15.20 15.00 15.00 .50 1.00 15.00 20.70 30.00 20.00 293.30 290.20 29.26 $ 775.16 Sworn and subscribed to before me This /s'e day of 4~ 2004,A.D.~Q~~ Prothonotary ~~s: ..t:~v<4' R. Thomas Kline, Sheriff BY jkS~ Real Eli!ite Deputy \.~ Clt..Y 110'1 id. /.t?J5:L UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, (East Pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.). 1. Name and address of Owner(s) or reputed Owner(s) Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address Same as No. 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 f o every mortgage Plaintiff herein. Address See Caption above. 5. Name and address on the property: Name of every other person who has any record lien Address 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 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 other knowledge who has any interest affected by the sale: Name person of whom the plaintiff has in the property which may be Address Tenants/Occupants 333 West Perry Street (East Pennsboro Township) Enola, PA 17025 (Incorrectly Stated in legal Description as North Perry St.) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 27, 2004 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 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 NO. ~-224 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, (East Pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Salel you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. TO find out how much you must pay, you may call: (8561-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482- 6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go full amount due in the sale. 856-482-6900. through only if the buyer pays the Sheriff the To find out if this has happened, you may call 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 UDREN LAW OFFICES. P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 ou. NO. ~-224 Civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, (East pennsboro Township), Enola, PA 17025, (Incorrectly Stated in legal Description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on June 9, 2004, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action~ 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment. if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482- 6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, FA 17013 BOO-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ALL XHAT CERTAIN TRACT OF LlWD SITll"ATE IN nm TOWNSHIP OF l!:AST PENNSBORO, CUMBlm1.1Ilm COO'NTY, PEN!lSYLVANL\, HAVING TaEUoN ERECTED TIm EASTERN RllLF OF A .DOUB!.E FRAME DWELJ;.I>>G HOUSE ltNClW1Q' AS 333 N. PJ!:1U1.y STREET, !:NOLA, PE!mSYLVl\N:tA, lolORE .FULLY :SOUNDED A2iD DltSCRIBED AS FOLLOWS: BEGIImING AT A POIN'.!:' AT THE NORTHERN LINE OF PERRY STRl!:ET, 82 l'EET FROM nm NOR'1'1l:EAST CORllER OF PB.Rl!Y AN]) ZION STREETS, AT A LINE OF LANDS NOW OR LATE OF WALTER J. NANNING: THENCE NORTHWARDLY ALONG SAID LINl$ AND PAllALr.EL WIn ZION STREltT, 120 FEET TO LOT NO. .9 ON TIm B:l!Rl!.'XNJUl'TER Mlm'l'IONED PLAN, THENCE WESTWAlWLY ALONG THE LrNJ!: OF LOT NO. .9, 32 FEET Ii INCImS, lolORl!: OR LESS, TO A POIN'I' ON THll: LINE lUlNNI>>G THROUGH TIn!: CENTER OF THE PARTI:t'rON WALL OF TIm DOtr.eLE FRlIMlI: DWELLI>>G HOUSE ERECTED IN PART UPON THE LOT aEUIN DESCRIBED, AN]) IN PART UPON %'llE LOT ADJOINING ON TIn!: WEST; THENCE IN AN SOl11'aERr.Y DIRl!:CTION ALONG SAID LAST Mlm'l'XONED LrNJ!: IUlD PAllALLEL WI'l'H ZION STREB'r, 120 FEET TO PB.Rl!Y STRl!:ET; THENCE EASTWARDLY ALONG TIm NORTHERN LINE OF PB.Rl!Y S:t'Rl!:B'r, 3:2 FEET Ii INCllEs, lolORl!: OR LESS, TO THE PO:INT OR PLACE'OF BEGINNING. . .~-.. . BEING A PORTION OP'. LOT NOS: 6, 7 AND 8, BLOCK A', PLAN NO.1, ROOPY'S ADDITIon TO ENOLA. BEING KNOWN AS ENOLA, PA 17025 PERRY ST.). PROPERTY ID NO. 09-14-0832-216 LINDSEY M SISTI AND JENNIFER TITLE TO SAID PREMISES IS VEsiEgEErg FROM KELLY L. RINGLER, SINGLE E. SISTI, HUSB/AND /oANDo :iJ~RD~D 03/13/00, BOOK 217, PAGE 496. WOMAN DATED 02 29 , 333 WEST PERRY STREET (INCORRECTLY STATED IN (EAST PENNSBORO TOWNSHIP) LEGAL DESCRIPTION AS NORTH WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) . TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE C/O RESIDENTIAL FUNDING CORPORATION, Plainti{f(s) From LINDSEY M. SISTI AND JENNIFER E. SISTI NO 04-224 Civil CIVIL ACTION - LAW (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 attacb 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 debtto or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) [fproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of auyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $100,539.55 L.L. $.50 Interest FROM 2/28/04 TO DATE OF SALE 6/9/04 - PER DIEM $28.33 - $2,917.99 Atty's Comm % Due Prothy $1.00 Atty Paid $137.04 Other Costs Plaintiff Paid Date: MAR4CH 3, 2004 CURTIS R. LONG (Seal) Prothono-'?Y n ~ .1.-(/J 0.-.,. , ~?" ' Deputy ,7ptYl/U~' 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: 856-482-6900 Supreme Court lD No. 04302 Real Estate Sale #56 On March 08, 2004 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 333 West Perry Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 08, 2004 I I. . By: .~' UCL<"'J .~(,,,,,,,j ~ Real Estate Deputy ~ ~ c;:til c:;:::::3 @ \IViI PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of al11egal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 16,23,30,2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2004.224 CIVIl . M'~C rYEd. lsa ane o,;:!, ~ ltor SWO TO AND SUBSCRIBED before me this 30 day of APRIL 2004_ REAL ESTATE SALE NO. 58 JP Morgan Chase Bank. as Trustee, c/o ReSIdential fundIng Corporation VS. Lindsey M. Sisti and Jennifer E. S1sti Atty.: Mark Udren ALL TIiAT CERTAIN tract ofland situate in the Township of East Pennsboro. Cumberland County, Pennsylvania, having thereon erect ~ ed the eastern half of a double frame dwe1l1ng house known as 333 N. peny Street, '€nola. Pennsylvania, more fully bounded and described as fol- lows: BEGINNING at a point at the northern line of Perry Street, 82 feet from the northeast corner of Perry - - - ,.........li_".{lIoJ..nd.a. ~ ~J.).. J/J7A.fd-Uu ~flIAL SEAL (J LOIS E. SNYDER, Notary Public Carlisle Bore, Cumbertand County My Commission Expir8s March 5, 2005 ""'-,. . Lindsey M. Sisti and Jennifer E. Sisti Atty.: Mark Udren ALL THAT CERTAIN tract of land situate in the 'township of East Pennsboro, Cumberland County. Pennsylvania. having thereon erect- ed the eastern half of a double frame dwelling house known as 333 N. peny Street. Enola. Pennsylvania. more fully bounded and described as fol- lows: BEGINNING at a point at the northern line of Perry Street 82 feet from the northeast comer of Perry and Zion Streets. at a line of lands now or late of Walter J. Manning; thence northwardly along said line and parallel with Zion Street. 120 feet to Lot No.9 on the hereinafter mentioned plan: thence westwardly along the line of Lot No.9, 32 feet 6 inches, more or less, to a point on the line running through the center of the partition wall of the double frame dwelling house erected in part upon the lot herein described, and in part upon the lot adjoining on the west: thence in an southerly direc~ tion along said last mentioned Hoe and parallel with Zion Street. 120 feet to Perry Street: thence east- wardly along the northern line of Perry Street, 32 feet 6 inches, more or less. to the point ar place of be- ginning. BEING a portion of Lot Nos. 6, 7 and 8. Block A. Plan No.1. Hoopy's Addition to Enola. BEING KNOWN AS 333 West Peny Street {East Pennsboro Tovm.- ship) Enola, PA 17025 (incorrectly stated In legal description as North Perry St.). PROPER1Y 10 NO. 09-14-0832- 216. TlTLE TO SAID PREMISES is VESTED IN LIndsey M. Sisti and Jennifer E. Sisti, husband and wife by deed from Kelly L. Ringler, single woman dated 02/29/00, recorded 03/13/00, Book 217, Page 496. . ~ , THE THE PATRIOT NEWS 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~ 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 said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County f auphin in Miscellaneous Book "M", ~ Volume 14, Page 317. My commission expires June 6, 2006 Member, P,nnsylv.nlaAnodalton 01 Notarits PUBLICATION COpy SALEII56 REAl. LE MO." "Jlti.'.i'f.' ........,,,;,,RE......... . . ,', _"~-'l'..J':""y;l.:_;';,_::; A1L'IIIA'l.~J.I_in lbOllMIIllP-.iU.' ....f' -w" =~I~""!'>!t~.......~ _ . m N. _ ..'-.... ~.~~...........~ 1IIlIIIIlNO..... .lbO IllItI-. II.. of,.".....iDa& """'.II...... .' """'711i1'1l1ii........IfWIlI&.: Publisher's Receipt for Advertising Cost 1."'_I.~__, ~GII&""'IiJ>'_I,... ..,._=:;: Co., publisher of The Patriot-News and The Sunday Patriot-News. newspapers of general ~~J.or.t::.,.-"::=Ofl"''''' edge receipt of the aforesaid notice and publication costs and certifies that the same have 9.J2r.t.-._ar......poIDI"""" r'.....;..l!.i\ij~ lbO_ofllleportilloll ir-!~?i ..t; '1':':.1 ;'Il'~t(l ,< .: ~" !1i11.1J11l1y....lbO NorlIlem line ofPonySlrojl,l2foet6iDchoo,_..Ieu.Io lIle(lOiDl.."",.,~. . '1lI!INO,'';'''~~ '~ 8, B~,,' T.' ..w. ~. . '. ...~~"lr~ (~ .......1: Nl!tSl.).f>..,.... ,....j.... ,.\~~P!~~.~ B!::J211~",:i CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 290.20 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 OB003-3620 B56-669-5400 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 04-224 Civil TO THE SHERIFF: PRAECIPE TO ISSUE WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 02/28/04 to Date of Sale March 2, 2005 Per diem @$28.33 $100.539.55 10,453.77 (Costs to be added) $ EN L~FFICE~ P.C. . ~/ \0 . U ren, ESQUIRE ORNEY FOR PLAINTIFF ;;;J 9- (:) S? ~ ~ !i- ~ ~ r ~ "- ~~ l -e. + B ~ r ~ \) \) ~ ~ E; ::I-w~ ....... ~V(f"...o~ ~ ~ :'\ ~. 0 ';> ~ \)BB~8-c() \)0 Ilf::cJ I;: ~~;: I~ ~ ~ [~ ~ ~ - - -o:Jt:. ~ -. ~....:q (..:':'1 -- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-224 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE CfO RESIDENTIAL FUNDING CORPORATION, Plaintiff(s) From LINDSEY M. SISTI AND JENNIFER E. SISTI (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 accouut 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 fouud in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is eujoined as above stated. Amount Due $100,539.55 L.L. Interest FROM 2/28/04 TO DATE OF SALE 3/2/05 PER DIEM @$28.33 - $10,453.77 Atty's Corom % Due Prothy $1.00 Arty Paid $924.70 Other Costs Plaintiff Paid Date: NOVEMBER 30, 2004 (Seal) CURTIS R. LONG Prothonot'!I"Y p ~ ~y: ~ __ ~~L';-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: WOODCREST CORPORATE CENTER HI WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 civil C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorit~s. E~~iC rk J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ~, c::) C) ~:;;f -'1'1 (,~ C;,) r::.5 Ul . . 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 civil AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 1. Name and address of Owner(s) or reputed Owner(s): Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 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. . ~ . S. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 333 West Perry Street Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 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. r DATED: November 24, 2004 T\7C''V ~.k J. Ud.on, ESQ. A torney for Plalntlff ) r....) ~::') I',:':) s;-- (~" C'} 0:- Ul 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on March 2, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffts Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 669-5400. mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 f-..j C) f~~~ ~-, l .J,:- .._\ .'1'. f(\ c.) C:;'" ~ cJ1 ,I - UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on March 2, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) -669-5400. mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ..., c:':") c::) ~ (-) ':T\ --I (;'~~t ,', ..,".: (,.) c:; ,n ~.. JP Morgan Chase Bank, as Trustee clo Residential Funding Corporation VS Lindsey M. Sisti and Jennifer E. Sisti In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-224 Civil Term Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that n December 06, 2004 at 3:44 o'clock PM, he served a true copy of the within Real Estat Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by making known unto Lindsey Sisti, personally and husband of Jennifer Sisti, at 333 West Per Street, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, state that on January 03, 2005 at 2:57 o'clock P.M., she posted a true copy ofthe within R Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lindsey M. Sisti and Jennifer E. Sisti, located at 333 West Perry Street, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within nam d defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by regular mail to their last known address of333 West Perry Street, Enola, PA 17025. These letters were maile under the date of December 29, 2004 and never returned to the Sheriffs Office. R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark J. Udren. Sheriffs Costs: Docketing 30.00 Poundage 9.26 Advertising 15.00 Posting Bills 15.00 Levy 15.00 Mileage 22.20 Surcharge 30.00 II ~ \. ,W 0'1 'Y \Jt4,q ~RllPjl~\ Prothonotary Law Journal Patriot News Share of Bills 1.00 200.30 103.59 30.73 $472.08 Sworn and subscribed to before me This 6l.~ dayo{1-f;."."J 2005, A'D;s.. I '. - M,.,,< h~ Prothonotary ~. So Answers' T"~~.,<t:. ~-'-I' . . R. Thomas Kline, Sheriff BY', it~j~ Real Estat Deputy I :ny~EN LAW OFFICES, p C . Mark J . . AT . Udren E . TY X D N ,squ~re Wonn~n~"~ _0. 04302 ATTORNEy FOR LAXN'I'IFF ATTORNEY FOR PLAX IFF 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 civil AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corpo ation, Plaintiff in the above action, by its attorney, Mark J. Udren, ES ., sets forth as of the date the Praecipe for the Writ of Execution was f'led the following information concerning the real property located at: 33 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Inc rrectly stated in legal description as North Perry St.) 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 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 i a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every m rtgage of record: Name Address ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHE EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. RIGHTS 1. If the Sheriff's Sale is not stopped. your property will be s ld 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 f 11 amount due in the sale. To find out if this has happened. you may call 856-669-540 4. If the amount due from the Buyer is not paid to the Sheriff, you wi 1 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 amOli t due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, he buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for yo A schedule of distribution of the money bid for your house will be filed by th within 30 days after the sale. This schedule will state who will be recei money. The money will be paid out in accordance with this schedule unless e (reasons why the proposed distribution is wrong) are filed with the Sheriff w' (10) days after Schedule of Distribution is filed. r house. Sheriff . ng that eptions thin ten 7. You may also have other rights and defenses, or ways of getting y ur 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 L WYER 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 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 y ..- 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 LAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East ennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on March 2, 2005, at 10:00 AM in the Commissioners Hearing Room, 2 d Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $1 0,539.55, obtained by Plaintiff above (the mortgagee) against you. If t e sale is postponed, the property will be relisted for the Next Availab e Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the charges, costs and reasonable attorney's fees. you may call, (856)-669-5400. mortgagee the back pent, late To find out how much y u must pay, 2. You may be able to stop the sale by filing a petition asking the COli t to strike or open the judgment, if the judgment was improperly entered. You ay also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedin s. 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 cant ct one, the (See notice on pag two on how YOU MAY STILL BE ABLE TO SAVE. YOUR PROPERTY AND YOU HAVE OTHE EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. RIGHTS 1. If the Sheriff's Sale is not stopped, your property will be so d 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 id 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 fu 1 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 wil 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 amoun due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, t e 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 heriff within 30 days after the sale. This schedule will state who will be receivi g that money. The money will be paid out in accordance with this schedule unless exc ptions (reasons why the proposed distribution is wrong) are filed with the Sheriff wit in ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting you 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 LA ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE Y U CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, FA 17013 800-990-9108 . ALL THAT CERTAIN TRACT OF LAND SI'l'UATE IN THE TOWNSHIP OF EAST PENNSBORO, I CUf'lBERLAND COUN'rY, PENNSYLVANIA, HAVING THEREON ERECTED THE 1!AS'l'EllN HALF OF A '.I?OUBLE FRAME DWELLING HOUSE KNOWN AS 333 N, PERRY STREET,' E;NOLA, PENNSYLVANIA MORE For.LY BOUNDED AN'D DESCRIBED AS FOLLOWS: ,......,.. ~ BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE ..NORTHEAST--G10RNER~-OF'-P.E~' ZION STREET-S,--AT- A LINE"-o~LJtj NOW-OP..-r;xTE--cflf -~--- WALTER J. M1,NNING; THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, ~20 FEET TO LOT NO.9 ON" THE llEREINAP"l'ER MENTIONED PLAN; 'THENCE WEST!! ALONG THE LINE OF LOT NO.9, 32 FEET 6 INCHES, MORE OR LEl;1S, TO A POINT ON TIlE RmmING THROUGH THE CENTER OF THE PARTITION WALL OF TIlE DOUBLE FRAME DWELLING OUSE ERECTED .IN PART UPON THE LOT HEREIN PESCRIBED, AND IN PART UPON THE LOT ADJOIN NG DN THE WEST; THENCE IN AN SOur-HERLY DIRECTION ALONG SAID LAST MENTIONED LINE PARALLEL WITH ZION STREET, .~20 FEET TO PERRY STREET; THENCE EASTWAllPLY ALONG T NORTHERN LINE OF PERRY STREET, 32 FEET 6 INCNES, MORE OR LESS, TO THE POINT OR , PLACE'OF BEGINNING. BEING A PORTION or. LOT NOS: 6, 7' AND 8, BLOCK A, PLAN NO.1; HOOPY'S ADDITION 0 ENOLA. BEING KNOWN AS: 333 WEST PERRY STREET, ENOLA, (EAST PENNSBORO TOWNSHIP) PA 17025, (INCORRECTLY STATED IN LEGAL DESCRIPTION AS NORTH PERRY ST.) PROPERTY ID NO. : 09-14-0832-216 TITLE TO SAID PREMISES IS VESTED IN LINDSEY M. SISTI AND JENNIFE E. SISTI, HUSBAND AND WIFE BY DEED FROM KELLY L. RINGLER, SINGLE WOMAN D TED 02/29/00 RECORDED 03/13/00 IN DEED BOOK 217 PAGE 496. WRIT OF EXECUTION and/or A IT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE C/O NO 04-224 Civil CIVIL ACTION - LA RESIDENTIAL FUNDING CORPORATION, Plaintiff (s) From LINDSEY M. SISTI AND JENNIFER E. SISTI (1) You are dirccted to levy upon the property ofthe 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 fr paying any debt to or for the account of the defendant (s) aud from delivering any property of the defend nt (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as garnishee and is enjoined as above stated. Amount Due $100,539.55 L.L. Iuterest FROM 2/28/04 TO DATE OF SALE 3/2/05 PER DIEM@$28.33 - $10,453.77 Atty's Comm % Due Prothy $1.00 Atty Paid $924.70 Other Costs Plaintiff Paid Date: NOVEMBER 30, 2004 CURTIS R. LONG (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: WOODCREST CORPORATE CENTER I I 1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephoue: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #28 On December 0 l, 2004 the Sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 333 West Perry Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 01, 2004 By:Jo~5~ Real EstatgDeputy SO :b V' I - 330 ~OOZ 'Vd '}"HlnO:J iJN'.r\cl38HflJ 331~3HS 3Hl 30331330 ~ ~/{};> ~~~* REAL ESTATE SALE NO. 28 Writ No. 2004-224 Civil JP Morgan Chase Bank. as Trustee. c/o Residential Funding Corporation vs. Lindsey M. Sisti and Jennifer E. Sisti Atty.: Mark Udren ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro. Cumberland County. Pennsylvania. having thereon erect- ed the eastern half of a double frame dwelling house known as 333 N. Perry Street. Enola. Pennsylvania. more fully bounded and described as follows: BEGINNING at a point at the northern line of Perry Street. 82 feet from the northeast corner of Perry and Zion Streets. at a line of lands now or late of Walter J. Manning; thence northwardly along said line and parallel with Zion Street. 120 feet to Lot No. 9 on the hereinafter mentioned plan; thence westwardly along the line of Lot No.9. 32 feet 6 inches. more or less. to a point on the line running through the center of the partition wall of the double frame dwelling house erected in part upon the lot herein described. and in part upon the lot adjoining on the west; thence in an southerly direc- tion along said last mentioned line and parallel with Zion Street. 120 feet to Perry Street; thence east- wardly along the northern line of Perry Street. 32 feet 6 inches. more or less, to the point or place of Be- p'innin~. BEING a portion of Lot Nos. 6. 7 and 8. Block A., Plan No.1. Hoopy's Addition to Enola. BEING KNOWN AS: 333 West Perry Street, Enola. (East Pennsboro Township) PA 17025. (incorrectly stated in Legal Description as North Perry St.). PROPERTY ID NO.: 09-14-0832- 216. TITLE TO SAm PREMISES IS VESTED IN Lindsey M. Sisti and Jennifer E. Sisti. husband and wife by Deed from Kelly L. Ringler. single woman dated 02/29/00 recorded 03/13/00 in Deed Book 217 Page 496. ,f REAL ESTATE SALE No. 28 Writ No. 2004-224 Civil Term JPMorgan Chase Bank, 88 Trustee clo Residential Funding Corpomlon V4\ ' Lindsey M. Sisti and JennlferE. SIsti Atly: Mark Udren DESCRIPTION AlL THAT CERIAlN tract ofJand situate in Ihe Township of Basi Pennsboro, Cumberland County, PtJmsylvania, having Ihereon erected the Eastern ba1f of a double frame dwelliDg ~ome ,. known as 333 N. Peny S1reet, Enola, PtJmsylvania, more fully bounded and described as follows: '. BEGINNING at apoiat atlhe Nortbem line of Peny Street, 82 feel from the Nonl1east comer ofPeny and Zion S1r<elS, 3t a Ieeoflands now or late of Walter J. Manning; thence Northwardly along said line and pmlIel willi Zion Street, 120 reel to Lot No. 9 ,on the bereinafter mentioned plBn; lbeJtce westwardly along tl)e line of Lot No. 9,32 feel 6 inches, more Qrless;to a point on the line I1IllIling tlm)ngb llie centor of the partition wall of thedoobl. frame Ji\velling honse meted. in pBrt upon the lot bereitl described, imd in pBrt upon the lot adjoining on the West; thenre in a Southerly direction along said lasi mentioned line and pmlIel willi Zion S1reet, 120 feel to Peny , SIreel; thence Eastwardly along Ihe-Nortbem ~, of Petty Street, 32 feel 6 incbe&. more or less, to the point or place ofBEGJNNING. BEING a por1ion of Lot Nos. 6, 7 and 8, BlockA, Plan No.1, Hoopy'sadditiontoEno1a. BEING KNOWN AS: 333 West Peny Street, Enola (East Peons-boro Township), PA 11025 (incur-rect\y ~ in L.g,;! Description as North Peny St) , Property ID iIO').l4-0832-216. TITLE to said premises is vested in Lindsey M. Sisti and Jennifer E. Sisti, husband and wife, by Deed from Kclly L. Ring-le!', single woman, dated 02129/00 recorded 03113/00 in Deed Book 217 Page 496. . . UDREN LAW OFFICES. P.C. BY: Mark J. Udren. Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD. SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 02/28/04 to Date of Sale 12/07/05 Per diem @$35.46 $100,539.55 23,013.54 (Costs to be added) $ r UDREN LAW OFFICES, P. C. : t (\ "i \ ) . " ! : ; \ ) ' /r.........~"" k ~I " , rk . 'Udren, 'ESQUIRE , ATTORNEY FOR PLAINTIFF v -,c) ~ ""'" - r ..t ....2::- -l ~ () - - ..... \n ~ -4' - tv D - IA V'\ ..{) V't ,., V) b ...0 Yt ~ ~ . f'r::J t - ~ C () \) ~ 0 \) D- O 1- - 'i) ~ C ~ C \) "'" r c .J:: \J 0- f ~ - W \ \ I , P pd (j- ~ ~ .- ~ ~ W :: :: , :: ::. " ' + E " , S ~ S- - , - , :r:r - - , - - - - , ? +- ~ II) ~ Q ~ 0 (;:::> -n C, d' ~-n .'"" '- -n~::~' j"'-lr' C PiC r -01'1 .-- - ~hQ V~ vJ ()()..} -, .--{:f; r;.: -0 -;: ~\~ ~_. ;;:~~Y~A -~',. ,- "",' /~._ -f'-~ - ~;'C:: r;-? ~..-\ ? J'.~~ ;;::- 2. -Z Ci' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-224 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE C/O RESIDENTIAL FUNDING CORPORATION, Plaintiff(s) From LINDSEY M. SISTI AND JENNIFER E. SISTI (l) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing lhereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $100,539.55 L.L. $.50 Interest FROM 2/28/04 TO DATE OF SALE 1217/05 - PER DIEM @ $35,46 - $23,013.54 Atty's Corum % Due Prothy $1.00 Atty Paid $1411.78 Other Costs Plaintiff Paid Date: JULY 13, 2005 CURTIS R. LONG (Seal) Proth~ {} ~ ____Bv: -/1.{1. . /T?/7./r,J Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No, 04302 C'l c, ".., <=" c-,. c;:r. <- c:. ... 1.';' , -,' ,- - W 4:l ~. -- Q,. .-! ::C.... cnC :91\::; t:'-~\;>~) -::-::~~ -T-, "~_-'n r:~~~ _~.-i r';-? J:'" C'""\ ~'~.... :2. t~REK'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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 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. ~. Nome and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 333 West Perry Street Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 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. ','~\]\REN W OFFICES, P.C. i,' '\ I~ i I' r ~ ! / I Mark J. ~n, ESQ. , Attorney for Plaintiff \) DATED: June 22, 2005 . Q ~" ....' = e::::_"-' <f' '- c: ,- '- -, Co' c~_ -~ -< . - o -11 -< :t.-n n1~ -:r.\\;':-1 i~?lS~ {~ 1~A ~~\ '~ ~'<1 ::< c..:> :2, -,- N .' .r. en 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, FI 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorneyls 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 I if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff wi thin 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of. getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 (') "', 0 ('~;;) ('-~ c::::~ --n '.n '--. <.- .-1 -r '7) c.= nl r~~ ;= :8c:; w (~;.~ (~) -r1 "'''-.-. ::1,;: ~',"_:. 0 (-j l"il 1':;> " .r.- :::J 0" .< -- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, FI 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856)-669-5400. mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.} The sooner you contact one, the (See notice on page two on how YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale, This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (101 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 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 o c:: , c. ( :';-=1 -< or r-> = => CJ' <- c:;: r- o -n -1 I..,., rnr= -u,-Ti :l,Jt.,""J (~.~ ~~} -.:~ -~~ (:.;~C) I~r'l "'iJ :-< W -0 ::J;;; 1'.) ., 0"' WREN LAW OFFICES, P. C. :BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 2U. WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 04-224 Civil v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) DATE: July 12, 2005 'TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Lindsey M. Sisti and Jennifer E. Sisti PROPERTY: 333 West Perry Street, Enola, (East pennsboro Township) PA 27025 (Incorrectly stated in legal description as North Perry St.) I1Ilprovements: 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 AM, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ~, ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVAN!A, HAVING THEREON ERECTED THE EASTERN HALF OF A DOUBLE FRAME DWELLING HOUSE KNOWN AS 333 N. PERRY STREET, ENOLA, PENNSYLVANIA, MORE FULLY BOUNDED AND DESCRIBED AS FOLLOWS, '.'-' BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE NORTHEAST CORNER OF PERRY AND ZION STREETS, AT A LINE OF LANDS NOW OR LATE OF WALTER J. MANNING, THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, 120 FEET TO LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN; THENCE WESTWARDLY ALONG THE LINE OF LOT NO.9, 32 FEET 6 INCHES, MORE OR LESS, TO A POINT ON THE LINE RUNNING THROUGH THE CENTER OF THE PARTITION WALL OF THE DOUBLE FRAME DWELLING HOUSE ERECTED IN PART UPON THE LOT HEREIN DESCRIBED, AND IN PART UPON THE LOT ADJOINING ON THE WEST; THENCE IN AN SOUTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE AND PARALLEL WITH ZION STREET, 120 FEET TO PERRY STREET; THENCE EASTWARDLY ALONG THE NORTHERN LINE OF PERRY STREET, 32 FEET 6 INCHES, MORE OR LESS, TO THE POINT OR PLACE OF BEGINNING. BEING A PORTION OF LOT NOS: 6, 7' AND 8, BLOCK A, PLAN NO.1, HOOPY'S ADDITION TO ENOLA. PROPERTY ID NO. : 333 WEST PERRY STREET, ENOLA, (EAST PENNSBORO TOWNSHIP) PA 17025 (INCORRECTLY STATED IN LEGAL DESCRIPTION AS NORTH PERRY ST.) 09-14-0832-216 BEING KNOWN AS: TITLE TO SAID PREMISES IS VESTED IN LINDSEY M. SISTI AND JENNIFER E. SISTI, HUSBAND AND WIFE BY DEED FROM KELLY L. RINGLER, SINGLE WOMAN DATED 02/29/00 RECORDED 03/13/00 IN DEED BOOK 217 PAGE 496. --- UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA IN RE: LINDSEY MARC SISTI JENNIFER ELLEN SISTI CHAPTER 13 CASE NO.: 1-04-bk-00268 Debtor(s) ORDER DISMISSING CASE NOW, at Harrisburg, ;n said District, Upon consideration of the Debtor( s) Withdrawal of Bankruptcy, and it having been determined that this case should be dismissed, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U.S. Bankruptcy Court. By the Com1:, ~~~ This electronic order lS signed and filed on the same date. Dated: June 15, 2005 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, FI 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 civil AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits s t forth by Pa Rule C.P. 3129. This Affidavit is made subject to relating to unsworn falsification of .S. Section 4904 Dated: November 18, 2005 P.C. BY: Mark J. Udren, Esqu~re Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 1. Name and address of Owner(s) or reputed Owner(s) Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 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 East pennsboro Township 98 S. Enola Drive, Enola, PA 17025 6. Name and address of the property and whose Name every other person who has any record interest interest may be affected by the sale: Address in Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA17013 PA Department of Revenue Bureau of Compliance, P.O.Box 281230 Harrisburg, PA 17128-1230 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 333 West Perry Street Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge 0 infor tion and belief. I understand that false statements here n a e made u 'ect to th enalties of 18 Pa.C.S. sec. 4904 relating to un wo n alsi ic tion t authorities. E DATED: November 17, 2005 MarK J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES,P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 04-224 Civil v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) DATE: October 5, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S}: LINDSEY M. SISTI & JENNIFER E. SISTI PROPERTY: 333 West Perry Street, Enola, {East Pennsboro Township} PA 17025 (Incorrectly stated in legal description as North Perry St.) 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 AM, in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. 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' "' ~ fu i & '" ~o ~ <:) ~ '" 63 g ~ ~ - '" ~ '" '" '" t-- <Xl o '" - - \..;.. (] ~ "" <J 0, \~!\.;r~~ 1'. ~'i)'UI, ",d~O~ ..,,1"1 l1}U~ ~ \ 0" so~! lil~ ~~O~;; , H!h1 ~OO'" ~ i;lS;$.s.s~' ~:;~.,.... ", ~.~Jl~$~ 1-"2: 5 c:l.(,IL_ 1ld1~ l\;:i%go;. ~~~~'tJl n~~~t -a-oiIl>Ql- :g!Ell~ !n\\l .%~_n ,,< li031 \~!~~'" ~~g!l~~ ~S849~-a 15~~.';]~ ~hl~ i lSgll.*. ~ ~ \~h~ ~'5tl~ ~ 1l,;~ill,B ~~~~i-~~ .s! 5!E- ~~~,~t- ~~~8!~ ~s~~l ;(: 'Jl) :ll- t: "6 :lI- - 'ii. :ll1 ... o. S ~ ;:: ~ ... % g; +- ~ 1 -a. 1: '~ 8 ~~ lr4 . "- 'iI3 ... ~ \ '" ~ ~ ~ "' '" - ~ '" ~ ~ - <' - ~ l~ o:~ (It Dl i':' " " ~ "- ,.; iO '" E '5 u.. (/) 0.. Ol" ~l '" - " 1> " ~\ %~ ".D c", 'S.s ~.5 - """H'D'T 1\ I;::/\-. !.iL)t {-'1,. JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation VS Lindsey M, Sisti and Jennifer E. Sisti The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-224 Civil Term Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2005 at 5:10 PM, she served a true copy of the within Real Estate Writ, Notice ofSheriff'l Sale and Description, in the above entitled action, upon the within named defendants, to wit: Lindsey M, Sisti and Jennifer E. Sisti, by making known unto Lindsey Sisti, personally and husband of Jennifer E, Sisti, at 333 West Perry Street, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2005 at 8: II o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lindsey M. Sisti and Jennifer E. Sisti located at 333 West Perry Street, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the i;lbove Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by regular mail to their last known address of 333 West Perry Street, Enola, P A 17025, These letters were mailed under the date of October 10, 2005 and never returned to the Sheriffs Office, Sworn and subscribed to before me ....<---.,.,"'--~.,~....,.,.""';,,..'.. "'.,~'"",. So Answ~ ~ ,-t:~ R. Thomas Kline, Sheriff This _ day of 2005, A.O, Prothonotary BY r J()~~~{h Real Estate ergeant -,,.,. \7XH1B1T B (~', ....,,) c<' ,',..-) -;1 ..::;~ \',-\ ~ ,'~ 1 .--'.:.... C-.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which JP Morgan Chase Bank Tr is the grantee the same haying been sold to said grantee on the 7th day of Dec AD., 2005, under and by virtue of a writ Execution issued on the 13th day ofJuly, AD., 2005, out ofthe Court of Common Pleas of said County as of Civil Term, 2004 Number 224, at the suit of JP Morgan Chase Vauk Tr againsl Lindsey M Sisti & Jennifer E is duly recorded in Deed Book No. 272, Page 4852, IN TESTIMONY WHEREOF: I ha~ereunto set my hand and eal of said office this 3/ day of , AD, dOD (, ,t JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation VS Lindsey M, Sisti and Jennifer E. Sisti The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-224 Civil Term Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on Sept 27, 2Ud5 at 5:10 PM, she served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Lindsey M. Sisti and Jennifer E. Sisti, by making known unto Lindsey Sisti, personally and husband of Jennifer E. Sisti, at 333 West Perry Street, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy ofthe same. William CI i :1e, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 20u:, at 8:11 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entilJcd action, upon the property of Lindsey M. Sisti and Jennifer E. Sisti located at 333 West Perry Street, Enola, Pennsylvania, acclll ding to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Heal Estate Writ, Notice, Poster and Description in the following manner: The She:' mailed a notice of the pendency of Ihe action to the within named defendants, to wil Lindsey:, I. Sisti and Jennifer E. Si,ti, by regular mail to their last known address of ~33 West Perry Street, Enola, PA 17,:'5, These letters were mailed under the date of (-"ober 1 0,2005 and never returned to the Sheriffs Office. R. Thomas .ine, Sheriff, who being duly sworn according to law, states that after due and lega, ,lotice had been given according to law, he exposed the within described premise ilt public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsyll 'a on Decmber 7, 2005 at 1O:0u o',.lock A.M. He sold the same for the sum of $1.00 i ,\(Llme\' .lark Udren for JP Morgi!il Chase Bank, as Trustee. It being the highest b.\ and bes: price received for the san,c, JP Morgan Chase Bank, as Trustee of 1270 1\, 'land I, :'i ve, Suite 200, Mendota Lcights, MN 55120, being the buyer in this exeel: :,..1, paid to SheriffR. Thomas Kline the sum of$I,006.25. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Al:~nowledging lei Auctioneer Law Library Prothonotary Mileage :;30.00 19,73 15,00 15.00 30.00 10.00 ,50 1.00 28.80 " Certified Mail Levy Surcharge Postage Law Journal Patriot News Share of Bills Distribution of Proceeds Sh~riffs Deed 4.65 15.00 30.00 LlI 383.00 337.07 20.89 25.00 39.50 $1,006.25 Sworn and subscribed to before me 2006, A.D. So Answers: ,~~t-t:~~ R. Thomas Kline, Sheriff I , . .' BY; eM S(/V\d~ Real Estate Sergeant V /'lJ 00 rY 3D j'<)O ~ :s.7 '7'7(.. Ru.-. / 1J(, {) 'ir " 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant (s) NO. 04-224 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) 1. Name and address of Owner(s) or reputed Owner(s) Name Address Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 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 Sq, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 'Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 333 West Perry Street Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. /'., UDREN~AW 1 /. DATED: June 22, 2005 V Mark J, Ud~n, ESQ. Attorney for plaintiff OFFICES, P.C. r"" ' ~ UDREN LAW OFFICES, p.e. 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E, Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by plaintiff above (the mortgagee) against you, If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) -669-5400 , mortgagee the back payment, late To find out he".'! 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 !F 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 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTy, PENNSYLVANIA, HAVING THEREON ERECTED THE EASTERN HALF OF A ,DOUBLE FRAME DWELLING HOUSE KNOWN AS 333 N. PERRY STREET, ENOLA, PENNSYLVANIA, MORE FULLY BOUNDED AND DESCRIBED AS FOLLOWS, BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE NORTHEAST CORNER OF PERRY AND ZION STREETS, AT A LINE OF LANDS NOW OR LATE OF WALTER J. MANNING; THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, 120 FEET TO LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN; THENCE WESTWARDLY ALONG THE LINE OF LOT NO.9, 32 FEET 6 INCHES, MORE OR LESS, TO A POINT ON THE LINE RUNNING THROUGH THE CENTER OF THE PARTITION WALL OF THE DOUBLE FRAME DWELLING HOUSE ERECTED IN PART UPON THE LOT HEREIN DESCRIBED, AND IN PART UPON THE LOT ADJOINING ON THE WEST; THENCE IN AN SOUTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE AND PARALLEL WITH ZION STREET, 120 FEET TO PERRY STREET; THENCE EASTWARDLY ALONG THE NORTHERN LINE OF PERRY STREET, 32 FEET 6 INCHES, MORE OR LESS, TO THE POINT DR PLACE OF BEGINNING. '.",. BEING A PORTION OF LOT NOS. 6. 7' AND 8, BLOCK A, PLAN NO.1, HOOPY'S ADDITION TO ENOLA. BEING KNOWN AS: 333 WEST PERRY STREET, ENOLA, (EAST PENNSBORO TOWNSHIP) PA 17025 (INCORRECTLY STATED IN LEGAL DESCRIPTION AS NORTH PERRY ST.) PROPERTY ID NO. : 09-14-0832-216 TITLE TO SAID PREMISES IS VESTED IN LINDSEY M, SISTI AND JENNIFER E. SISTI, HUSBAND AND WIFE BY DEED FROM KELLY L. RINGLER, SINGLE WOMAN DATED 02/29/00 RECORDED 03/13/00 IN DEED BOOK 217 PAGE 496. ,. 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 JP Morgan Chase Bank, as Trustee c/o Residential Funding Corporation 12650 Ingenuity Drive Orlando, Fl 32826 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Lindsey M. Sisti Jennifer E. Sisti 333 West Perry Street Enola, PA 17025 Defendant(s) NO. 04-224 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lindsey M. Sisti 333 West Perry Street Enola, PA 17025 Your house (real estate) at 333 West Perry Street, Enola, (East Pennsboro Township) PA 17025 (Incorrectly stated in legal description as North Perry St.) is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 AM in the commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $100,539.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1, The sale will be cancelled if you pay to the charges, costs and reasonable attorneyls fees. you may call, (856) 669-5400, mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one! the {See notice on page two on how , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling 856-669-5400, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. S. 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 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 , "----- ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA, HAVING THEREON ERECTED THE EASTERN HALF OF A ,DOUBLE FRAME DWELLING HOUSE KNOWN AS 333 N. PERRY STREET, ENOLA, PENNSYLVANIA, MORE FULLY BOUNDED ANn DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE NORTHEAST CORNER OF PERRY AND ZION STREETS, AT A LINE OF LANDS NOW OR LATE OF WALTER J. MANNING; THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, 120 FEET TO LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN; THENCE WESTWARDLY ALONG THE LINE OF LOT NO.9, 32 FEET 6 INCHES, MORE OR LESS, TO A POINT ON THE LINE RUNNING THROUGH THE CENTER OF THE PARTITION WALL OF THE DOUBLE FRAME DWELLING HOUSE ERECTED IN PART UPON THE LOT HEREIN DESCRIBED, AND IN PART UPON THE LOT ADJOINING ON THE WEST; THENCE IN AN SOUTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE AlID PARALLEL WITH ZION STREET, 120 FEET TO PERltY STREET; THENCE EASTWARDLY ALONG THE NORTHERN LINE OF PERltY STREET, 32 FEET 6 INCHES, MORE OR LESS, TO THE POINT OR PLACE OF BEGINNING. BEING A PORTION OF LOT NOS: 6, 7' AND 8, BLOCK A, PLAN NO.1, HOOPY'S ADDITION TO ENOLA. PROPERTY ID NO. : 333 WEST PERRY STREET, ENOLA, (EAST PENNSBORO TOWNSHIP) PA 17025 (INCORRECTLY STATED IN LEGAL DESCRIPTION AS NORTH PERRY ST.) 09-14-0832-216 BEING KNOWN AS: TITLE TO SAID PREMISES IS VESTED IN LINDSEY M. SISTI AND JENNIFER E. SISTI, HUSBAND AND WIFE BY DEED FROM KELLY L. RINGLER, SINGLE WOMAN DATED 02/29/00 RECORDED 03/13/00 IN DEED BOOK 217 PAGE 496. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-224 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debl, inlerest and costs due JP MORGAN CHASE BANK, AS TRUSTEE C/O RESIDENTIAL FUNDING CORPORATION, Plaintiff (s) From LINDSEY M. SISTI AND JENNIFER E. SISTI (I) You are directed to levy upon the property of the defendant (s)and 10 sell SEE LEGAL DESCRIPTION (2) You are also directed to attach lhe 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 debl to or for the account oflhe defendanl (s) and from delivering any property of the defendant (s) or olherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject 10 attachment is found in lhe possession of anyone other than a named garnishee. you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amounl Due $100,539.55 LL $.50 Inleresl FROM 2/28/04 TO DATE OF SALE 12/7/05 - PER DIEM @ $35.46 - $23,013.54 Atty's Comm % Due Prothy $1.00 Atty Paid $1411.78 Plaintiff Paid Dale: JULY 13, 2005 Other Costs (Seal) CURTIS R. LONG Prolhonola91 n ~_ ~: &0-" 0 . ~ ~Jr..J Depuly REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Courl ID No. 04302 s ~ G=eI 1M! Real Estate Sale #23 On September 01, 2005 the Sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 333 West Perry Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. l~_'::' '. w__'- C' Bate: September 01, 2005 By:jaL-iSr~Jh Real Estate.Bergeant c~ , 0 .:J ~~ C;~-) =, c~ . ..' THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, Slale of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the Cily, Counly and State aforesaid; lhal The Palriot-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 lheir regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of Oclober and the 1st and 8th day(s) of November 2005, That neither he nor said Company is interested in the subjecl matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in lhe office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COPY da of November 2005 A,[), NOTARIAL SEAl --- Terry L Russell, Nolary PUblic City of Horrlsburg, Dauphin County My ComrnlsSJ Expire une 6, 2006 ......-J Member PElnnsv. 'A f' '. . anla or. alion of N I ' ;/ . 0 ana" l/~ 'j(~( NOT A Y PUBLIC My commission expires June 6, 2006 . CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA, 17013 ~, , REAL ESTAll! SALE _ 23 wrtlNo.2IJ04..:!24 CIvil Term - JP Morgan Chase Bank, as Tru8l8e cia __I FundIng CorporatIon Va Undsey M. SlsII & Jennifer E. SlsII Ally: MlIri< J. Udren DESCRIPllON ALL lHATCEKl'AIN tract of land situate in the ToWDSbip of East Pem1sboro, Comberlaod Coooty. ~lvania, having thereon erected the eastern hift of a double frame dwelling house known as 333 N. Pmy Street, Enola, Pennsylvania, more fully bounded and described as follows: BEGlNNING at a point at Ihe northern line of Perry Street, 82 feet from the northeast comer of Perry and Zion Streets, at a line of lands now or late of Walter J. Manning; thence northwardly along said line and parallel with Zion Street, 120 feet to Lot No.9 on the hereinafter mentioned plan; thence westw&rdly along the line of Lot No. 9,32 feet 6 inches. more or less, to a point on the lino romring through the ceoter of the partition wall of the _ fmme dwelling boose """"<I in part upon the lothetein described,and in part upon the lot adjoining on the west, thence in a southerly direction along said last mentioned line and parallel with Zion Street, 120 feet to Perry Street; thence eastwardly Wong the oortbem lino of Perry Street, 32 feet 6 inches, more or less, to the point og!aceofBEGINNING. ~G a portio~ of Lot Nos. 6, 7 and 8. Block A,PlanNo. CHoopY's Addition to Enola. BEING KNOWN AS, 333 West Perry SIreol, Eoola (East Pem1sboro: Towosbip), PA 17025 (incorrectly stated in Legal Description as North PerrySt,) PROPERJ'YJlil NO, 09-1<W832-216, Tl'I1.E-tosaidpremisesisvestedinLindseyM. Sisti and Jennifer E. Sisti. husband and wife, by deed from Kelly L. Ringler, single woman, dated 02129/00 recorded 03113100 in Deed Book 217 Page 496. , . , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, v!z: October 14, 21, 28, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. TO AND SUBSCRIBED before me this 28 day of October. 2005 r: tHty NO A A SEAL LOIS E. SNYDER, Nolary Pub!', Carlisle Boro. Cumberland County My Commission Expires t/~Ich 5. 2009 -,------ REAL ESTATE SALE NO. 23 Writ No, 2004~224 Civil JP Morgan Chase Bank. as Trustee c/o Residential Funding Corporation vs, Lindsey M. Sisti & Jennifer E. Sisti Atty.: Mark J. Udren ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro. Cumberland County. Pennsylvania, having thereon erected the eastern half of a double frame dwelling house known as 333 N. Perry Street, Enola, Pennsylva- nia. more fully bounded and de- scribed as follows: BEGINNING at a point at the northern line of Perry Street, 82 feet from the northeast corner of Perry and Zion Streets. at a line of lands now or late of Walter J. Manning; thence northwardly along said line and parallel with Zion Street. 120 feet to Lot NO.9 on the hereinafter mentioned plan; thence westwardly along the line of Lot No.9. 32 feet 6 inches. more or less. to a point on the line running through the center of the partition wall of the double frame dwelling house erected in part upon the lot herein described. and in part upon the lot adjoining on the west; thence in an southerly direc- tion along said last mentioned line and parallel with Zion Street. 120 feet to Perry Street; thence east- wardly along the northern line of Peny Street. 32 feet 6 inches. more or less. to the point or place of be~ ginning. BEING a portion of Lot Nos. 6, 7 and 8. Block A. Plan No.1, Hoopy's Addition to Eoola. BEING KNOWN AS: 333 West Perry Street, Enola. (East Pennsboro Township) PA 17025 (incorrectly stated in legal description as North Perry St.), PROPERTI lD NO.: 09~14~0832- 216. TITLE TO SAID PREMISES IS VESTED IN Lindsey M. Sisti and Jennifer E. Sisti, husband and wife by deed from Kelly L. Ringler. single woman dated 02/29/00 recorded 03/13/00 in Deed Book 217 Page 496,