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HomeMy WebLinkAbout04-1241 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO, 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619,7038 Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION . _ Cumberland County v. Ray L. Deihl 320 Mountainview Road Mt. Holly Springs, PA 17065 Defendant(s) : NO. 04 - /;)..41 C(.)~L'--rfJL~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717,249,3166 800-990-9108 AV1SO Le han demandado a usted en la corte. Si usted 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. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Isl Mark J. Udren, Esquire Woodcrest 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: N/A Assignments of Record to: N/A Recording Date: N/A 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 151 West North Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 08/23/01 DATE RECORDED: 09/04/01 BOOK: 1732 PAGE: 2265 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 03/15/04: Principal of debt due Unpaid Interest at 8.60% * from 10/01/03 to 03/15/04 (the per diem interest accruing on this debt is $12.70 and that sum should be added each day after 03/15/04) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $84.00 and that sum should be added on the first of each month after 03/15/04) Late Charges (monthly late charge of $25.52 should be added in accordance with the terms of the note each month after 03/15/04) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $53,917.41 2,122.61 250.00 280.00 (722.67) 127.60 2,695.87 $58,670.82 * 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 fees will be charged in Act 6, if applicable. 8. The combined prior to the sale, reasonable attorney's accordance with the reduction provisions of 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 $58,670.82 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. U ren, ES UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CllMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOllNDED AND DESCRIBED AS FOLLOWS, TO-WIT: BOllNDED ON THE SOUTH BY WEST NORTH STREET, BOllNDED ON THE WEST BY PROPERTY FORMERLY OF RICA AND MAGGIE BROWN, NOW OR FORMERLY OF SHULTZ; BOllNDED ON THE NORTH BY A 12- FOOT ALLEY; AND BOllNDED ON THE BAST BY PROPERTY NOW OR FORMERLY OF J.W. HANDSHAW ESTATE. CONTAINING 28 FEET MORE OR LESS, IN FROM ON WEST NORTH STREET AND EXTENDING IN DEPTH 114 FEET, MORE OR LESS, TO THE AFORESAID 12 FOOT ALLEY. ALSO KNOWN AS PARCEL NUMBER 05-20-1798-123 January 27, 2004 Ray L Deihl 320 Mountainview Rd Mt Holly Spgs, P A 17065-11] I Homeowners Name: Ray L Deihl Property Address: 15] W North Ave, Carlisle PA ]7013 Loan Account No.: 0004900296 Original Lender: OPTION ONE Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASS]STANCE PROGRAM YOU MAYBE ELIGIBLE FOR FlNANC]AL ASS]ST ANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROV]SIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, · IF YOU HAVE A REASONABLE PROSPECf OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL V AN]A HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE EXHIBIT A YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OPI7IRe: Loan No. 0004900296 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice, or you may contact HUD directly at 800-569-4287 or visit the HUD website at www.hud.gov/officeslhsglsfhlhcclhccprofl4.cfm.ltis only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see foIlowing pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fiIl out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for me program and mey wiIl assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within mirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDlA1EL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. OPI71 Re: Loan No. 0004900296 ********************************************************************** NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATfEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy. you can still apply for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 15] W North Ave, Carlisle P A 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: I MONTHS @ $ 509.29 2 MONTHS @ $ 509.29 $ 1527.87 (b) Previous late charges; $ 127.60 (c) Other charges; Escrow,Inspection, NSF checks $ (d) Other provisions of the mortgage obligation. if any $ (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $1178.83 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $1178.83, PLUS ANY MORTGAGE PA YMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIlE TIlIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and send to: Overnight Mail Address Western Union Quick Collect 3 Ada Irvine. Ca. 92618 Pay to: Option One Mortgage Corpomtion Code City: Option, Ca You can cure any other default by taking the following action within tbirty (30) days of the date of this letter. (Do not use if not (applicable. ) OPI72 Re: Loan No. 0004900296 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, tbe lender intends to exercise its rights to accelerate tbe mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past dne is not made within THIRTY (30) DAYS. the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you bave not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due. plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OPI73 Re; Loan No. 0004900296 HOW TO CONTACT THE LENDER; Name of Lender; Option One Mortgage Corporation Address; 7515 Irvine Center Drive Attn; Ed Turner Address; Irvine, CA. 92618 Phone Number; 800-326-1500, Ext. 48004 Fax Number; 949-784-6033 Contact Person; Ferdinand Um Office bours; Monday through Thursday 8:00 a.m. to 8:00 p.m. Friday 8:00 a.m. to 5:00 p.m. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your funtishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mongage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MA Y ALSO HAVE THE RIGHT TO: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY CALENDAR YEAR.) · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THIS IS AN AITEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS ATI'EMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS BEEN DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES. OPI74 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 I Mark J. Udr ,ES~RE UDREN LAW OFFICES, P.C. authorities. NR~ ~ it. ~ __ 6" frt ~ ..() 0 ~ <.tv ~lfl ~ r-j /'-.:> " () ::j '-..,I t SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-01241 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND OPTION ONE MORTGAGE CORPORATIO VS DEIHL RAY L R. Thomas Kline Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DEIHL RAY L , to wit: unable to locate Him in his bailiwick. He therefore returns the but was COMPLAINT - MORT FORE the within named DEFENDANT 320 MOUNTAINVIEW ROAD MT HOLLY SPRINGS, PA 17065 NOT SERVED , as to , DEIHL RAY L DEFENDANT LIVES AT THIS ADDRESS ON WEEKENDS. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 4.83 .00 10.00 .00 -2 b-:sT s~answ.er:/ / ///' _/// 2.":-~~~" )" - /- R. Thomas Kline Sheriff of Cumberland County MARK UDREN 03/29/2004 Sworn and subscribed to before me this St:: day of OrP .Jnt>~\ A . D . '--f1~()' 7Yu1'.6., ,~ Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004,01241 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OPTION ONE MORTGAGE CORPORATIO VS DEIHL RAY L KEI\'NETH GaSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DEIHL RAY L the DEFENDANT , at 0842:00 HOURS, on the 29th day of March , 2004 at 151 WEST NORTH STREET CARLISLE, PA 17013 by handing to SERENA MAELOWE, DAUGHTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- DEFENDANT LIVES AT THIS ADDRESS MONDAY THROUGH FRIDAY. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 ~9-L::~~~ R. Thomas Kline 03/29/2004 MARK UDREN Sworn and Subscribed to before By: a fA p / DfPutiY ~iff me this ~ day of Or-e \ ~'i . A.D. i : v-C.~% ~othonotary , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669,5400 Option One Mortgage Corporation .!\.TTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Ray L. Deihl NO. 04-1241 Defendant(s) PRAECIPE TO SUBSTITUTE VERIF'ICATION 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: May 4, 2004 BY: (~) Mark J. Udren, Esquire Attorney for Plaintiff V E R I F I CAT I 0 ~ 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:~lo'\- ~O.~~ Name: Title: Company: Lora A. Sattler Sr. Legal Action Specialist Option One Mortgage Corp. Ray L. Deihl Loan #0004900296 MJU #04030326 t'r, () c ~t; ';;'-'- (f~ ~~~ ;.~. ~2 z ~ i'. r :, l . ~ "i t- o IH, ~ ',I';'"" j, 11,1,1, ,. . ...., = = .s:- ::c: J:>>'" -< ~ ~ ~~ :rJCJ 0' ._-<0 :L'"' ,,:!.J ,",0 om ---I 55 -< ~ ~ 9? U1 .,;- , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 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) Ray L. Deihl 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 I s damages as follows: As set forth in Complaint Interest Per Complaint From 3/16/04 to 5/4/04 Late charges per Complaint From 3/16/04 to 5/4/04 Escrow payment per Complaint From 3/16/04 to 5/4/04 $58,670.82 635.00 25.52 168.00 TOTAL $59.499.34 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 Mark J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED DATE: fY/ '::1'( ". :J.f)oV AS '~;~ 12. ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-482-6900 Option One Mortgage Corporation Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Ray L. Deihl Defendant(s) NO. 04-1241 Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 DATE of Notice: April 21, 2004 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CuYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION IS DEEMED TO BE A DEBT COLLECTOR AND DEBT. ANY INFORMATION OBTAINED WILL ~ PRACTICES ACT, THIS LAW FIRM S AN ATTEMPT TO COLLECT A OR THAT PURPOSE. /s/ Mark J. Udren, Woodcrest Corpora 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 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Ray L. Deihl 320 Mountainview Road Mt. Holly Springs, PA 17065 Defendant(s) NO. 04-1241 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF FL COUNTY OF Dw0J2 SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon invest1gations 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: Ray L. Deihl Age: Over 18. Residence: As captioned above Employment: Unknown Sworn to and subscribed before me this I day of . /J.?' 200'1'. (v~ ~u.b.L~ ~Q.~ Name: Title: Company: Lora A. Sattler Sr. Legal Action Specialist Option One Mortgage Corp. "",-_ _.- ,'" 4~'" .".,/ill '............. , .""'" KWH CI.Al<I' . ~NokIry PublIC - Stale 01 FlorIda . , _. . Call.,rI>*",eq:iet~3,2Ol7, ~ \~, ~cammISSlan#OOl99485 ~ ..,f;,9f.f.\..... Bonded By Natlonal NotaryAsSn. ~ J-.,...._,-_....... --. ... - .. - - .. ~ iV @ "9- tl=-t~ o r-~~-~ ~ ~ p= ..;) !';I ~- f2 f 1- () 1"-.."1 c: g 9" ..1..-- :::r: :? ::- -< i'i1F) -orr' -':lei ."" t ,-~,", J~1<- -,~ -~:'; --'- --,-;; co "-1 (Jl .< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Defendant(s) NO. 04-1241 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 5/5/04 to Date of Sale September 8, 2004 Per diem @$12.70 $59,499.34 1,612.90 (Costs to be added) $ UDREN LAW OFFICES, P.C. Mark J. U ren, SQUIRE ATTORNEY FOR PLAINTIFF AJ C ~r r TdP -- w ~ 't~ ~"'l;l. .J:: ~-:-O~~~ ~ . :--- /o-l '10' . . !"t ff- '- - '" 0 '"'Q oCd~~8 ~ () o D- r ~ I I I I ' -v ~~ ~ ~ - ~ GJp.-. ~ ~ ... ... . ... ::-!q.. ... ... ,f11- : :: ... + ... it l .-., '" ~~~ g o __ -n ::r: :::! ::.;:'",.. r:il:D -< ,- :g5 -:->,1, -j ~ --.-----,> ~"I ;;.2 ,I, 0,) en WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-1241 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION, Plaintiff (s) From RAY L, DEIHL (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attac\unent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attac\unent 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 $59,499.34 L.L. $.50 Interest FROM 5/5/04 TO DATE OF SALE 9/8/04 (PER DIEM @ $12.70) - $1,612.90 Ally's Comm % Due Prothy $1.00 Atty Paid $134.28 Other Costs Plaintiff Paid Date: MAY 11, 2004 CURTIS R. LONG (Seal) Prothon~ry p '-m- ~ ~- ~- ,"~_.Irt[ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P .C. WOODCREST ROAD CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY fiLL, 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 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 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. <IDREN LA~?,\ ~ ) Mark J. !Udren~ESQ~IRE ATTORNEY FOR PLAINTIFF () '" 0 c-,o C ~ oj " -t --,"". -.- ;Q :J;..":" rl1 --c !]J =8 T' C) -T, ~ " '~r ' --- ',. tr: C:) , -, U1 .~r; .:;:- :-< -UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. MORTGAGE FORECLOSURE Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 151 West North Avenue, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 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 on the property: Name of every other person who has any record lien Address Borough of Carlisle 53 W. South Street Carlisle, PA - 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 person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 151 West North Avenue Carlisle, PA 17013 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: May 4, 2004 Mark J. Udren, ESQ. Attorney for Plaintiff C' c"~ ,...., (~--=> (~ J.- o ., ..... ~~:o r' ~--::C y' CJ -r. .' ~ --""" )...,.. ~ ),-:ro <> T1 "-:.:"; ~:~;~: ::<. CD en &" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Your house (real estate) at 151 West North Avenue, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $59,499.34, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call, (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 8S6-482-6900. 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. home back, You may also have other rights and defenses, or ways of getting your if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 (') c~ , " -;; -,< I'--> 8 ~- o " .... ::L....,..., Ill....:...! ,-- -n:"'fl ~30 -0"5:7': .n ~~3f'"l ,.-~~ :...~ 21: -" ~ ~ ,1- C? (Ji t.n 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 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Defendant(s) : NO. 04-1241 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.p.RULE 3129.1 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 at.tached 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". rth by Pa Rule C.P. All Notices were served within 3129. This Affidavit is made subject to relating to unsworn falsification If 1 Pa.C.S. Section 4904 Dated: August 3, 2004 E:N P.C. BY: Mar J. Udren, Esqulre Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. MORTGAGE FORECLOSURE Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO FtULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the fOllowing information concerning the real property located at: 151 West North Avenue, Carlisle, PA 17013 I. Name and address of Owner(s) or reputed Owner(s) : Name Address Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 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 Borough of Carlisle 53 W. South Street Carlisle, PA 17013 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, Pl\. 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, Pl\. 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 151 West North Avenue Carlisle, Pl\. 17013 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 state ents h in are made subject to the penalties of 18 Pa.C.S. 490,~ lating to unsworn falsification to authorities. ~W FFICES, P.C. DATED: August 3, 2004 rk . Udren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 11.1. WOOD CREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County \ v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Defendant(s) NO. 04-1241 DATE: May 19, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SAI.E OF REAL PROPERTY OWNER(S): RAY L. DEIHL Improvements: RESIDENTIAL DWELLING PROPERTY: 151 West North Avenue, Carlisle, l?A 1.7013 The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 8, 2004, at 10:00 am, at the COMMISSIONEERS MEETING 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 ::he 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 ~ "--i! 0; m o ~ ~a:: a: ~$ cn"- w 1lI ....__ "0.0 ~:: .52 ~o'" ,~ 0'::: :!::.S 0 ~~ m CO E'a "'_ 0 0.00 E"- .s<<l~ lIl~~ :ei:g <om ~ q m ';;cn"- ~ :;: ;sc:;:R -a:"- ~ ] li5 '''0 "t: 150 ! ~~ " ~- oeo ~~ ?J ~ i6 Q)t:,E> g ~ !!! ~ ~.s " ~- ~=~-m c..tU~i;; ~::E~.: l5:~&'5 m$=~ .::.:. (1)'- -- Ol d:I 1iJ;'c,S: S::E ~ '" "DO];! m ua:: ttI.c IU " .E ~ o o :is ,,- ~ .,; (ij'i5'l >" ....a: 0_ <"'- .E 0; - 0 0. 'C . ,,"""-' =-,..:....,--- ._----,-~ .- d:I Q;I= " .,"?t7' ;0:;;..._.<<,;;,./_____.._________ , o "m 1f':,~:~~~~~-i ; (l)Q)....;:E " /t;,A,_' " a::.!:2 8 U) "- ,'~~( {~1 ;;,~'I,i.d,lllbt :~ C:"CQ)Ul ~[ij~~ -.,.' """, ,'to ;""'" ,jUl i 6'(;', ." ''''1 -Ir .,-~1 }.. cu.c:... x u .S 1 "',.,. a:: ~.Ew'---I- , -,:~:s~tl~ \J - l ~ D~DD " " ,\I [, e> > .-.,.- ._,.~'-q,'," : ~, m ;; 'C 0 ~ 0. 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Diehl In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1241 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 07, 2004 at 4:17 o'clock PM, he served a true GOPy ofthe within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Ray L. Diehl, by making known unto Robert Speck, adult in charge for defendant, at 151 West North St., Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 13. 2004 at II :35 o'clock A.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ray L. Diehl located at 151 West North Ave., Carlisle, 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 defendant, to wit: Ray L. Diehl, by regular mail to his last known address of 151 West North Street, Carlisle, P A 17013. This letter was mailed under the date of July 13, 2004 and never returned to the Sheriff's Office. Sworn and subscribed to before me This day of So Answers: ~~ .c..i'<' ~~ R. Thomas Kline, Sheriff" BY. /',.A, J'/VU/-/; Rea~>Uty 2004, A.D. Prothonotary t~.". , " , ' If, ~'11 :",,, -,,~ . ,..,.lfT ~ ""'l...1...)fJ a ~ () c:,~',) -n J;:- )';'" c,: G.' I U.., ...", -."'" (-:? ", N , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: (Ji/- /~ / I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby cert fy that the Sheriffs Deed in which Wells Fargo Bank Minnesota N A Tr is the grantee the same havi g been sold to said grantee on the 8th day of ~ A.D., 2004, under and by virtue of a writ Executio issued on the lIth day of Mav, A.D., 2004, out ofthe Court of Common Pleas of said County as ofCivi Term, 2004 Number 1241, at the suit of Option One Mtg Com against Ray L Diehl is duly recorded n Sheriffs Deed Book No. 266, Page 805. IN TESTIMONY WHEREOF, I have hereunto et my hand 4:: and seal of said office this day of , A.D2004 .' Option One Mortgage Corporation VS Ray L. Diehl In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1241 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, state that on June 07, 2004 at 4:17 o'clock PM, he served a true copy of the within Real Esta e Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Ray L. Diehl, by making known unto Robert Speck, adult in charge for defendant, at 151 West North St., Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states th t on July 13,2004 at II :35 o'clock A.M., he posted a true copy of the within Real Estat Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ray L. Diehl located at 151 West North Ave., Carlisle, Pennsylvania, according to la 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 name defendant, to wit: Ray L. Diehl, by regular mail to his last known address of 151 Wes North Street, Carlisle, P A 17013. This letter was mailed under the date ofJuly 13, 20 4 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 08, 2004 at 10:00 o'clock A.M. He sold the sam for the sum of$1.00 to Attorney Mark J. Udren for Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2001-D, Asset Backed Certificates, Series 2001-D. It being the highest bid and best price received ~ r the same, Wells Fargo Bank Minnesota, National Association, as Trustee for Option ne Mortgage Loan Trust 2001-D, Asset-Backed Certificates, Series 2001-D of 3 Ada, line, CA 92618, being the buyers in this execution, paid to Sheriff R. Thomas Kline the su of $655.78. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 12.86 15.00 15.00 30.00 10.00 .50 1.00 , . Mileage Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed $ 7.15 15.00 20.00 191.00 213.28 30.49 25.00 39.50 655.78 Sworn and subscribed to before me ThisL.-dayof (,ih'~ / I 2004, A.D. ~'" (;/ )u/etl, ~ /(J,c- . 17.7 ( P tho notary So Answers: r~#~ R. Thomas Kline, Sheriff BY J~/~ Real Estate eputy Q . leV !PI, ~-o LA... 11QJ..., fcL- tJSOr,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 PLAI IFF Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. MORTGAGE FORECLOSURE NO. 04-1241 Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Option One Mortgage Corporation, Plaintiff in the above acti ,by its attorney, Mark J. Udren, ESQ., sets forth as of the da the Praecipe for the Writ of Execution was filed the fol owing information concerning the real property located at: 151 West North Avenue, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgme lS a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 4. Name and address of the last recorded holder of every m rtgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address on the property: Name of every other person who has any reco d lien Address Borough of Carlisle 53 W. South Street Carlisle, PA 6. Name interest sale: Name and address of every other person who has any re ord 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. 28 946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintif has knowledge who has any interest in the property which ma be affected by the sale: Name Address Tenants/Occupants 151 West North Avenue Carlisle, PA 17013 I verify that the statements made in this affidavit are tru and correct to the best of my personal knowledge or informatio and belief. I understand that false statements herein are made s ject to the penalties of 18 Pa.C.S. sec. 4904 relating to u sworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark J. Udren, ESQ. Attorney for Plaintiff DATED: May 4, 2004 ATTORNEY FOR PLAINT FF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v. Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 NO. 04-1241 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ray L. Deihl 151 West North Avenue Carlisle, PA 17013 Your house (real estate) at 151 West North Avenue, Carlis e, 17013 is scheduled to be sold at the Sheriff's Sale on Septe 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Courthouse, Carlisle, PA, to enforce the court judgme $59,499.34, obtained by Plaintiff above (the mortgagee) a you. If the sale is postponed, the property will be relist 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 late charges, costs and reasonable attorney's fees. To find out you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the strike or open the judgment, if the judgment was improperly enter 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 proce You may need an attorney to assert your rights. The sooner yo one, the more chance you will have of stopping the sale. (See page two on how to obtain an attorney.) PA er 8, loor, t of ainst d for ayment, ow much ourt to d. You ings. contact otice on YOU MAY STILL BE ABLE TO SAVE YOUR PROpERTY AND YOU HAVE 0 HER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 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 856-482-69 O. 2. You may be able to petition the Court to set aside the sale i 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, yo 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 due is paid to the Sheriff and the Sheriff gives a deed to the buyer. A timel the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid fo house. A schedule of distribution of the money bid for your house will be by the Sheriff within 30 days after the sale. This schedule will state wh be receiving that money. The money will be paid out in accordance wit schedule unless exceptions (reasons why the proposed distribution is wron filed with the Sheriff within ten (10) days after Schedule of Distribut filed. your filed will this ) are on is 7. home back} You may also have other rights and defenses, or ways of getti if you act immediately after the sale. your YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO-WIT: BOUNDED ON THE SOUTH BY WEST NORTH STREET, BOUNDED ON THE WEST BY PROPERTY F RLY OF RICA AND MAGGIE BROWN, NOW OR FORMERLY OF SHULTZ; BOUNDED ON THE NORTH BY 12- FOOT ALLEY; AND BOUNDED ON THE EAST BY PROPERTY NOW DR FORMERLY OF J.W. HAND HAW ESTATE. CONTAINING 28 FEET MORE OR LESS, IN FROM ON WEST NORTH STREET AND EX ENDING IN DEPTH 114 FEET, MORE DR LESS, TO THE AFORESAID 12 FOOT ALLEY. ALSO KNOWN AS PARCEL NUMBER 05-20-1798-123 BEING KNOWN AS: 151 WEST NORTH AVENUE, CARLISLE, PA 17013 PROPERTY ID NO. 05-20-1798-123 TITLE TO SAID PREMISES IS VESTED IN RAY L. DEIHL BY DEED FROM RICHARD B. STEFFY AND DANA H. STEFFY DATED 8/23/01 RECORDED 9 4/01 IN DEED BOOK 248 PAGE 1141 WRIT OF EXECUTWN and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-1241 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OPTION ONE MORTGAGE CORPORATION, Plaintiff (s) From RAY L. DEIHL (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defend (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 hirnlher that he/she has been added as garnishee and is enjoined as above stated. Amount Due $59,499.34 L.L. $.50 Interest FROM 5/5/04 TO DATE OF SALE 918104 (PER DIEM @ $12.70) - $1,612.90 Atty's Comm % Due Prothy $1.00 Atty Paid $134.28 Other Costs Plaintiff Paid Date: MAY 11, 2004 CURTIS R. LONG (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.c. WOODCREST ROAD CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 TP"- ,...,~",..( F""C\ ; \ t,; ~" " i.,~.t.~~ !'''' ~"1 ',.;~ If. T".:.II.... . ..,.".1, '''";1'\/ "I:';;;-,"...t "X'"k N ~ Real Estate Sale #05 On May 12, 2004 the sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 151 West North Ave., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 12,2004 By: .J () cLt-IJJvVU-t~c-' Real Esta4 Deputy ~ c;:;;) c;:;;) c::::::J (;E) u;ril VIHV./.,,'1.~.SHN3d -j: .,: '; '/'; rO. ~~ 5t 0\ \ \ lU" J..1NCivJ ,:1,', ~:.,2H'Hl;,} 3;l11l3HS 3,,1 JO :;:1\;130 ( ~ . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth ofPennsytvania, 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 un er the laws of the Commonwealth ofPelUlSylvania, with its principal office and place of business at 812 to 818 Mar et Street, in the City of Harrisburg, County of Dauphin, State ofpennsylvania, owner and publisher of The Patri t. News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 arket Street, in the City, County and State aforesaid; that The Patriot.News and The Sunday Patriot-News were est lished March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever sin ; That the printed notice or publication which is securely attached hereto is exactly as printed and p blished in their regular daily and/or Sunday! Metro editions which appeared on the 27th day(s) of July and the 3rd d 10th day(s) of August 2004. That neither he nor said Company is interested in the subject matter of said printed otice or advertising, and that all of the allegations of this statement as to the time, place and character of publication re true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to ver this statement on behalf of The Patriot. News Co. aforesaid by virtue and pursuant to a resolution unanimously p sed and adopted severally by the stockholders and board of directors of the said Company and subsequently dul recorded in the office for the Recording of Deeds in and for said County of Daupbin in Miscellaneous Book 'M", Volume 14, Page 317, ALL 11IAT CERTAIN tract of land situate in the Borough of Carlisle, County of Cumberland and ComrtlOllweafth of Pennsyl-vania, more particularly bounded and described as follows, to wit: Bounded on the South by West North Street. bounded ~ the West by property formerly of Rica and Maggre Brown, now or formttly of ShuJtz; bounded. on the North by a 12.foot alley; and bounded on the East by property now or fonnedy of J. W, Hand.haw Esta~. CONTAIN1NG 28 feet more or I~.. in lrom on WesI Nonh Slfeel and Publisher's Receipt for Advertising Cost extending Jndepth 114 feet, more or less, to the oforesaid 12.loolal1.y. Iisher of The Patriot-News and The Sunday Patriot.News, newspapers of gene I 179~ KNOWN .. Parc.l Nwn.ber 05.2(). ,ledge receipt of the aforesaid notice and publication costs and certifies that the same have BEING KNOWN AS: 151 Wesl North Avenue, Carlisle, PA 17013. PROPERTY ill NO.: 05.2ll-1798.12J. TI1tE 10 SAID premises is vested in Ray L. Deihl by deed from Richard B, Steffy and Dana H.Steffy_81231OIrccorded9/41OIinDetd Book 248 l\lge 1l41. PUBLICATION COpy S ALE #5 REAL ESTATE SALE NO.5 Writ No. 2004-1241 Civil Term Option One Mortgege Corp. v. Ray L. Deihl I'1ty: Mark Udren DESCRIPTION CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 213.28 By......................,.......................... .................. .j REAL ESTATE SALE NO. 5 Writ No. 2004-1241 Civil Option One Mortgage Corporation vs. Ray L. Deihl Atty.: Mark Udren ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, County of Cumberland and Com- monwealth of Pennsylvania, more particularly bounded and described as follows. to-wit: BOUNDED on the South by West North Street, bounded on the West by property formerly of Rica and Mag- gie Brown. now or formerly of Shultz; bounded on the North by a 12-foot alley; and bounded on the East by property now or formerly of J.W. Handshaw Estate. Containing 28 feet more or less, in from on West North Street and extending in depth 114 feet, more or less, to the afore- said 12 foot alley. ALSO KNOWN AS PARCEL NUM- BER 05-20-1798-123. BEING KNOWN AS: 151 West North Avenue. Carlisle, PA 17013. PROPERTY ID NO. 05-20-1798- 123. TITLE TO SAID PREMISES IS VESTED IN Ray L. Deihl by deed from Richard B. Steffy and Dana H. Steffy dated 8/23/01 recorded 9/4/01 in Deed Book 248 Page 1141. . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland aw Journal, a legal periodical published in the Borough of Carlisle in the County and State afo esaid, 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 regu arly 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 ofthe said Cumberland aw Journal on the following dates, VIZ: JULY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumbe land Law Journal, a legal periodical of general circulation, and that he is not interested in the s bject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO.5 ~~_ ~l ditor Wrlt No. 2004-1241 Civil Option One Mortgage CorporatJon vs. Ray L. Deihl Atty.: Mark Udren ALL THAT CERTAIN tract ofland situate in the Borough of Carlisle, County of Cumberland and Com~ monwealth of Pennsylvanja, more particularly bounded and deSCribed as follows, to-wit: BOUNDED on the South by West North Street, bounded on the West by property formerly afRica and Mag- gie Brown, now Of fonnerly of Shultz; bounded on the North by a 12-foot alley: and bounded on the East by property now or formerly of J.W. Handshaw Estate. Containing 28 feet more or less, in from on West Nnrth ~treet and extending in depth ~-_/ SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 N SEAL LOIS E. SNYDER, Notary Public Canisle 80ra, Cumberland County My Commission Expires March 5, 2005