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HomeMy WebLinkAbout01-6506MARK J. umREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 8S6-482-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 c/o Option One Mortgage Corporation P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff V. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION i Cumberland County LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 \ / 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 YOU'k LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AV~SD Le hah 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 o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las 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 o 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 o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UNABO~ADO IMMEDIATAMENTE, SI NO TIENE ABO~ADO 0 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 AVERI~UAR DONDE SE PUEDE CONSE~UIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 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. Ifyou do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignee: Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 Recording Date: 12/11/00 Book: 662 Page: 165 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 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 313 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Hampden COUNTY: Cumberland DATE EXECUTED: 5/21/99 DATE RECORDED: 05/26/99 BOOK: 1544 PAGE: 886 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 Note 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. 10124101 The following amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 10.99%* from 6/01/01 to 10/24/01 (the per diem interest accruing on this debt is $26.66 and that sum should be added each day after 10/24/01) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $.01 and that sum should be added on the first of each month after 10/24/01) Late Charges (monthly late charge of $51.38 should be added on the fifteenth of each month after 10/24/01) Total fees Recoverable balance Attorneys Fees (anticipated and actual to 5% of principal) $88,527.54 3,882.77 250.00 280.00 5,416.05 205.52 46.00 1,649.59 TOTAL $104,683.85 * 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 $104,683.85 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. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN PIECE OR PARCEL OF LAND, WITH IMPROVEMENTS THERE~N ERECTED, SITUATE IN THE TOWNS;IP OF HAMPDEN, COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA, MORE PARTICu'.ARLy DESCRIBED AS FOLLOWS, TO WITs BEGINNING AT A POINT ON THE SOu'~'~tw=STERLY SIDE OF LAMP POST LANE AT T~ DIVIDING LINE BETWEEN LOT NOS. 9 ARD 10, BLOCK "H" OF THE HEREINAFTER M~NTIO~sm PLAN, WNICK POINT IS 627.23 FEET IN A NORTHWESTERLY DIRECTION FROM TH~ SOUTHWESTF~tLy COI~N~R OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE OF THE PLA~ TE~NcE BY SAID DIVIDING LIN~ SOUTH 35 DEGREES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LIN~ OF LOT 13, BLOCK #R= OF THE PL/~N~ THENCE ALONG LOTS NOS. 13 /%L'D 12, NORTH 59 DEGREES, 30 MII~UTES WEST '~00.33 FEET TO THE DIVIDING LINE BETWEEN LOTS NO.S 10 AND 11, BLOCK =H" OF THE PLAN; '"tus~CE BY 'SAID DIVIDING LI1TE NORTH 35 DEGREES, 10 MII~uTES ~AST 121.43 FEET TO A POINT ON THE SO0'~'nw~sSTF, RLy SIDE OF LAMP POST LANE; ~'~us~CK BY SAM~ SOO'r~ 54 DEGREES, 50 MII~u'rES EAST 100 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NO. 9 AND 10, BLOCK eH= OF THE PLAN, THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK .H=, PLAN 4 OF PINE BROOK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER~S OFFICE IN PLA~ BOOK 15 PAGE 41. 'LOAN NO 1693340 DATE 09/07/01 LETTER VER REQ DESCRZPTZON DATE 10/24/01 0P171 014 NS3 Part I Pennsylvan£a NO! September 07, 2001 Carter Harrison 313 Lamppost ~ane Camp Hill, PA 17011- Homeowners Name: Carter Harrison Property Address: 313 Lamp Post Lane, Hampden PA 17011 Loan Account No.: 169334-0 PF: I SC F Exhibit A , LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P171 014 NS3 Part I Pennsylvania NOI Original Lender: OPTION ONE Current Lender/Servicer: Opt'~on One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU~,MAY BE :ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YO~.MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: PF: I SC F 2 SC B 'LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P171 014 NS3 Part I Pennsylvania NOI * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUNSTANCES BEYOND.YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYNENTS, AND * IF YOU MEET OTHER.ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitied to a temporary s~ay of foreclosure on your m~rtgage 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 agenc±es listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO PF: I SC F 2 SC B ,LOAN NO DATE LETTER VER REQ DESCRIPTZON DATE 10/24/01 1693340 09/07/01 0P171 014 NS3 Part I Pennsyivan£a NOI _ NOT APPLY FOR EMERGENCY MORT~GAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. ,' OP1 71 PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P171 014 NS3 Pa~t I Pennsylvania NOI Re: Loan No. 169334-0 CONSUMER CREDIT COUNSELING AGENCIES - If you meet uith one of the consumer credit counseling agencies liste~ at-~he 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 uhich the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ 1693340 09/07/01 0P171 014 NS3 your lender immediately of your intentions. DESCRIPTION DATE 10/24/01 Part I Pennsylvania NOI APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the-nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file.a completed Homeowner's Emecgency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end'of this Notice.~ Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your appiication MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P171 014 NS3 Part 1 Pennsylvania NOI OR IF YOU DO NO~ FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR ~OME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They.~ill'be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has s~xty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings ~11 be pursued against you i~ you.have met the time requirements set forth above. You ~ill be notified directly by the Pennsylvania Housing Finance Agency of its~'decision on your application. OP1 71 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 1 0/24/01 1693340 09/07/01 0P172 024 NS3 Part 2 Pennsylvan£a,NO! Re: Loan No. 169334-0 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING pART OF THIS NOT[CE IS FOR INFORMATION PURPOSES ONLY.AND SHOULD NOT"BE CONSIDERE~ AS_AN ATTENPT TO COLLECT THE DEBT. (If you have f£1ed bankruptcy, you can styli apply for Emergency Nortgage Assistance.) HON TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). PF: 1 SC F LOAN NO DATE LETTER 1693340 09/07/01 0P172 VER REQ DESCRIPTION DATE 10/24/01 024 NS3 Part 2 Pennsylvania NOI NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on \ your property located at: 313 Lamp Post Lane, Hampden PA 17011 IS SERZOUSLY IN DEFAULT because: A. YOU HAVE NOT NADE MONTHLY MORTGAGE PAYMENTS for the folloNing months and the folloNing amounts are non past due: (a) Nonthly payments: I NONTHS · $ 856.42 2 NONTHS ~ $ 856.42 -.. '~ $ 2,569.26 (b) Previous late charges;. $ 102.00 $ O0 (c) Other charges; EscroN, Inspection, NSF checks (d) Other provisions of the mortgage obligation, PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ 1693340 09/07/01 0P172/ 024 NS3 if any (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE DESCRIPTION DATE 10/24/01 Part 2 Pennsylvania NOI $ O0 $ 2,272.02 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE T~E DEFAULT - You may cure:th~'default u£th£n thirty (30) days of the date of th£s notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $2,272.02, PLUS ANY MORTGAGE PAYMENTS ' AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY .(30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and send to: PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCR[PTZON DATE 10/24/01 1693340 09/07/04 0P172 024 NS3 Part 2 Pennsylvania NO[ Overnight Mail Address Nestern Union Quick Collect 3 Ada Pay to: Option One Mortgage Corporation Irvine, Ca. 92618 Code City: Option, Ca You can cure any other default by taking the following action Nithin thirty (30) days of the date..of this letter. (Do not use if not (applicable.). 0P172 PF: 2 SCB LOAN NO DATE LETTER VER 1693340 09/07/01 0P173 012 REQ DESCRIPTION .DATE 10/2~/01 NS3 Part 3 Pennsylvania NOI Re: Loan No. 169334-0 . ~..: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default Nithin THIRTY (30) DAYS of the dare'of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt Hill be considered due immediately and you may lose the chance to pay the mortgage in monthly installments, If full payment of the total amount past due is not made Nithin THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your PF: I SC F LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P173 012 NS3 Part 3 Pennsylvania NOI mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off..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 ~ill still be required to pay the reasonabie attorney's fees that ~ere actually incurred, up to $50.00. Hq~ever, if legal proceedings.~are-started against you, you ~ill have to pay all reasonabie attorney's fees actually incurred by the lender even if they exceed'$50.O0. Any attorney's fees ~ill be added to the amount you o~e the lender, ~hich may also include other reasonable costs. If you cure the default ~ithin the THIRTY (30) DAY period, you ~ill not be required to pay attorney's fees. PF: I SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P173 012 N~3 Part 3 Pennsylvan±a NOI OTHER LENDER REMEDIES - The lender may also sue you personally for the unpa±d pr~nc±pal balance and ail other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default N£th£n the'THIRTY (30) DAY per£od and foreclosure proceedings have begun, you st~[1 have the r£ght to cure the default and prevent the sale at any t~me up to one hour before the Sheriff's Sale. You may do so by paying the total ~mount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected Nith the foreclosure sale and any other costs connected Nith the Sheriff's Sale as specified £n Nr£ting by the PF: 1 SC F 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P173 012 NS3 Part 3 Pennsylvania NOI lender and by pe~Torming any other requirements ~nder 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 SAEE DATE - It is estimated that the eariiest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of ~he actual d~te o~.the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default wili increase the longer you wait. You may find out at any time exactly what the requiredpayment or action will be by contacting the lender. OP1 73 PF: 2 SC B LOAN NO DATE LETTER VER REQ DESCRIPTION DATE 10/24/01 1693340 09/07/01 0P174 020 NS3 Part 4 Pennsylvania NOI Re: Loan No. 169334-0 HON TO CONTACT THE LENDER: Name of Lender: Address: Attn: Address: Phone Number: Fax Number: PF: I SC F Option One Mortgage Corporation 7515 Irvine Center Drive Kerry Delahunty Irvine, CA. 92618 800-326-1500, Ext. 8001 949-784-6033 LOAN NO DATE LETTER 1693340 09/07/01 0P174 VER REQ DESCRIPTION DATE 10/24/01 020 NS3 Part 4 Pennsylv~n£a NOI Contact Person: Office hours: ~ NONA SPENCER EXT 8001 Monday through Thursday 7:00 a.m. to 9:00 p.m. PST Friday 7:00 a.m. to 6:00 p.m. PST. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale Hill end your omnership of the modtgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a laNsuit to remove you and YoUr furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF'MORTGAGE - You may or'~ X may not (CHECK ONE) sell or transfer your home to a buyer or transferee ~ho Hill assume the mortgage debt, Provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. PF: I SC F 2 SC B YOU MAY ALSO HAVE THE RIGHT TO: LOAN NO DATE LETTER 1693340 09/07/01 0P174 VER REQ DESCRIPTION DATE 10/24/01 020 NS3 Part 4 Pennsylvan£a NOI * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO'BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT'CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD O~CURRED~ 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 LANSUIT INSTITUTED 'UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO 'SUCH PF: 1 SC F 2 SC B LOAN NO DATE 1693340 09/07/01 ACTION BY THE LENDER. 0P174 LETTER VER REQ DESCRIPTION DATE 10/24/01 0P174 020 NS3 Part 4 Pennsylvania NO! TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAI~. PF: 2 SC B 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. Ud~ MARK J. UDREN &'ASSOCIATES MARK J. UDREN & ASSOCIATES By: Mark J. Udren ATTY I.D. NO. 0%302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff Vo Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS 'CIVIL DIVISION . Cumberland County i NO. 01-6506 Civil Term AFFIDAVIT OF SERVICE PuKSUANT 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". Ail Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to auth0ri~ies. Dated: May 1, 2002 ~. UDREN & ASSOCIATES Mark J.'-~dren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Bank Minnesota, National Association, F/K/A Norwest Bank Minnesota, National Association, as Trustee for SASCO Mortgage Loan Trust, 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff Vo Carter Harrison 313 Lamp Post Lane Hampden Twp Camp Hill, PA 17011 Defendant ( s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6506 Civil Term DATE: January 4, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF R]ZAL PROPERTY OWNER(S): CARTER HARRISON PROPERTY: 313 Lamp Post Lane, Hampden Twp, Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~ County Sheriff's Sale on ~, at 10:00 A.M., at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE,CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A crJ uii uJi,- 00' I ~- A Wells Fargo Bank Minnesota, N.A. F/k/a Norwest Bank Minnesota, N.A. as Trustee for SASCO Mortgage Loan Trust 1999-BC4 VS Carter Harrison In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6506 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriffs Costs: Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.20 Mileage 17.94 Levy 15.00 Advertising 15.00 Certified Mail 2.78 Poundage 432.22 Law Journal 316.55 Patriot News 251.35 $1142.54 paid by attorney 6/06/02 This // day of R. Thomas Kline, Sheriff 2002,^.D. Prothonotary Real Estate Deputy