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Home My WebLink About04-1713 unREN 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 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION . : Cumberland County v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) : NO. 04 - /'1/.3 C.iU'lC-r~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. 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 previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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. /s/ 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: 470 McCulloch Road MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township COUNTY: Cumberland DATE EXECUTED: 7/23/02 DATE RECORDED: 7/26/02 1766 PAGE: 1282 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. S. 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 3/16/04: Principal of debt due Unpaid Interest at 9.5% from 9/6/03 to 3/16/04 (the per diem interest accruing on this debt is $57.63 and that sum should be added each day after 3/16/04) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $0 should be added in accordance with the terms of the note each month after 3/16/04) Prior Interest Fees Appraisal Fees Attorneys Fees (anticipated to 5% of principal) TOTAL and actual $221,403.15 32,962.34 250.00 280.00 o 56.81 225.00 11,070.16 $266,247.46 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 limitsJ 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 $266,247.46 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) SQUI~E UDREN LAW OFFICES, P~C. Attorney for Plaintiff Attorney I.D. No. 04302 ~~ b thst oe~Ca1n traot of lend ly1ng csnd boing sHusto tn Southampton :J:ovn,h1p IllIl orland County, ponnsylvanis, boing Lot No. 12 ona Subdivis10n Plan of Ed"a:rd G. Newswanger and H :r Properties, prepared by John R. Xi.sin er <fa d ~uno 9, 1992, ,aid plan betng.recordod in the Office of the Rocordor o~ O~od. t:f umbsrlend County in Plan Book 66, ot Page 55. more fully bounded snd describod alS follows: BEGINNING at an .,,1't1ng railrosd spik. in loe8is1at1vo Rout. 121006 kno McCulloch Ro..d~ at t.he cortttr of Lot No. 1l an the here::lDbafQr:"'d.SC~b:: Subd1vidon nan; thenco in said roaduay, Norch f1fty-four (54) degruB e~ ~06~ minuto. thirty (30) .sconds East, ono hundrod thirty-six and t.n-hund~odth. 13 .10} feet to a railrDad spike at the. corner of Lot tfo. 13 on the afore.sid ~Ubdivi.ion Plan; thenco along ssid Lot No. 13, South thirty-nins (39) dagro.. OUI' (04)1IIfnutes one (~l) liIecond Eas:t I four h\lndr~d thirty....fouJ; aod one: ono-hundr.dth (434.01) fest to an iron pin; thonco along .Bid Lor No 13 N tl fiEty..f:i.ve (55) dllsre.. ~ero (DO) lQinutes fotty-two (42) seconds' E..'t, o~n~ hundred and t"enty-thr.. hundredths (100.23) foot to on existing iron pin at lands now oX' formerl,. of Edward G. NewswAnger; thence "long said lands now or fo<me.ly of Neu,wenser. South thirty-nine S39) desr.e. four (04) minut.. ~h~~tY-f1ve (3.s) seconds Esst, five hundr.d t1ft:y-siX and seventC!en-hurtdrl!!:dthe , .17) feet to an iron pin at tho edse of 3 pro90aed fifty (50) foot private right-of-way knlMl1 as Wo\.a1tall'l Drive; thence along said proposed fihy (50) foot private rlght~of-way, Soutt> fl!ty (50) degrees fl fty-..v"" (57) minutes .ero (DOl seconds We.t, two ,",-,Mred forty-seven and fl ft.....-l>JI'\dredths (247.15) f."t to an Iron pin: U'encI along gald proposed fffty (SO) foot prlVilt" right-Qf-way, along a curve to the right designated as CiJrve "C", having. chord bearing of North elgMY-(O\.Ir (64) degrees three (03) mlrll.Jle. zero (001 ssconds West, one hundred soventy-shi and sevanty-elght to.ndredtt>s (176.78) feet, e r6llluli of ~ hundred twenty-five and zero-/lUndredtt>s (125.001 feet, and an arc length of one hundred ninety-six and thirty-five hundredth. (196.35) feet to an Iron pin; thlme" along said proposed fitty (50) foot private right-of-way, North thirty-nine (391 degrees three (03) minutes zerO (00) second, West, four hundred flfty~seven and fifty-eight hundredth, (457.58) feat to on iron pin at the comer of LDt No. II on the aforesaid Subdivision Plan; thence along said LDt No. 11, North fifty-five (55) dll\lrees zero (00) minutes forty-t,,", (42) .econ<is East, one hundred thirty-six and twenty-nine hUndredths (136.29) feet to an Iron pin; thance along seld Lot No. tl, North thirty-nine (39) degrees three (03) minutes twenty-seven (27) .ecoMs Wut, four hundred thirty-one and eighty-six hundredths (431.86) feet to a r.llroad spike In l.eghleti"" Route 21006, \<nov<<l as W<:O.>lloch Road, tl)Ol place of eB:;IN'lIi'Q. ClJIITAINIi'Q 6.IQ .cr.. pursuant to the aforesaid SUbdivIsion Pian. ( lnh f from the centerline 0 Sl6JECT 10 a twenty-five (25) foot dedicated r~"_~dos.':~"iSlon Plan. legislative Route 121006. a8 shown on the afor.sa, 4 ___._~^. . ._.__.._.,__.J' .'. March 17,2004 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thj~ j~ an offirial notire that the mort!?\el' on YOllr home i~ in defalllt, and the lender intend~ to forerlo~e. ~ecifir information ahollt the nah.re of the default i~ provided in the attarhed p~~. The ROMROWNF.R'S MORT(ar.R ASSTSTANrR PROr.RAM (RRMAP) m'IY he ahle to help to ~ave YOllr home. Thj~ Notire eYplain~ how the prl\P)'am work~. To ~ee if RF,M A P can help, YOII mild MRRT WITH A rONSTTMRR rRRnTT rOTTNSRLTNG Ar.RNrV WITRTN 10 nA VS OF TRF. nATR OF TIDS NOTTrR. Take thi~ Notice with YOII when YOII meet with the rOlln~elil1e A!')'nr~. The name, addre~~ and phone nllmher of ron~lImer rredit rOlln~eli~ ;\ernrie~ ~ervi~ YOllr rounty are lided at the end of thj~ Notice. If YOII have al\Y qlll'<ltion", YOllm'IY call the Penn'\Vlvania ROII~ille Finanre ;\ernry toll free at 1-ll01l-:142-2197. (per~on~ with iTl\paired hearille ran rail (717) 7110-HlIi9). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU IUPOTECA. EXHIBIT A Page 1 016 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Barbara E. Trindel 470 McCuUough Road Shippensburg. P A.. 17257 20-0051.02751602 Citifinancial Services Citifinancial Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM VOTJ MA V RR F.T,IGIRLR FOR FINANCIAL ASSISTANCR WHICH CA N SA VF, VOTJR HOMR FROM FORRCI ,OSTJRR A NO HRI,P VOTJ M A KR FTTTlJRR MORTGAGR P A VMRNTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CffiCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TRMPORA RV ST A V OF FORF.CI,OSTJRR - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MRF.TlNG MTTST OCClTR WITHIN THR NF.XT (lO) nAYs. IF YOIT DO NOT APPLY FOR FMERGENrV MORTGAGE ASSTSTANrE, YOIT MITST RRTNG YOTJR MORTGAGE IrP TO DATE THE PART OF Tms NOTTrE rATJ.ED "HOW TO CORE YOTJR MORTGAGE DEFATJLT", EXPLATNS HOW TO RRTNG YOTJR MORTGAGE TrP TO DATE CONSIIMF.R CRF.nIT COITNSF.T ,ING AGF.NCIF.S - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. Th" nHm"., Hnnr"..". linn t"I"Phon" nnmh"r. of n",.ienHt"n con.nmer CT"nit conn."line HErnc;". for the connty in which th" propmy i. locHt"n Hr" ."t forth Ht th" "nrl of thi.. Notic" It is only necessary to schedule one face-to-face meeting. Advise your lender immf".tliHt"ly of your intentions. APPLICATION FOR MORTGAGF. ASSTSTANCR - 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 Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency, Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. Page 2 016 YOU MTTST 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, FqRECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APP.LICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGF.NrY 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. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fIled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CITRF, VOITR MORT(;A(;F, ORF A lIT ,T (Rrille it lip to fhde). NATITRF. OF THF. OF.FAITT,T - The MORTGAGE debt held by the above lender on your properly located at: 470 McCullough Road Shippensburg, P A., 17257 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Partial Monthly Payment for the month of October 6, 2003 = $928.09 Monthly Payments of$1867.77 for October 6,2003 through March 6, 2004 = $11206.62 Monthly Late Charges of $0.00 for October 6, 2003 through February 6, 2004 = $0,00 Other charges (explain/itemize): Title/Appraisal Fee = $225.00 TOTAL AMOUNT PAST DUE: $1 H'i9.71 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (00 not use ifnot "pp]i~"hle): .ISLA HOW TO CITRIC THF, OF.F A TTT ,T - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $12~'i9 71 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WmCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P::Iyme:nt!';, mn~ he: m::lne either hy ~::I<;;:h, r.::I~hler's. r.her.kJ C'1':t1ifiecl r.her.k or Tncmf':Y nrnf':T m::lne pl'lY::Ihle ::Inn C;::M1ttoo l!dren Law Offire~ P.C Woodcred Corporate Center 111 Woodrred Road, Suite 200 Cherry Hill, N.T 01l00~_~620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (00 not use if not "ppli~"h]e): .ISLA IF VOl! DO NOT CIIRF, THF, DF.FATTT,T - If you do not CUTe the default within THIRTY (30) DAYS Page 3 of6 of the date of this Notice, the lender intend. to exerd.e iio rieJoto to a......elerate the mortVlel' deht. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made willi!n TIIIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to fore...lo.e Ilpon YOllr mo~d pr"l'erty. T1i' THF, MORTr.Ar.R IS FORF,c.J ,OSRO IIPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will 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 YOIl cllre the defalllt within the THmTV '~II) OA V period, YOIl will not he reqllired to PllY attorne.y'. fee.. OTHF,R I,RNllF.R RRMFnrnS - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. Rlr.HT TO c.JJRR THF, OF,FAlrr,T PRIOR TO SHF,RIFF'S SAI.R - If you have not cured the default within the TIIIRTY (30) DAY period and foreclosure proceedings have begun, YOll .till hRve thp. rieht to ClIre, thp. ciefRlIll Rnd prevp.nt thp. "R]P. Rt Rny time lip to onp. hour heforp. the Sheriff'. SR]" VOll m"y 00.0 hy p::lylne the: tot~l ~monnt thEm pa~t nllt\ pln.;: ::my 1Aft": or othP.T c:harer.~ thEm rlllf>, Tp.f1S0nflhle Rffomp.y's. ff':f':s :mci c:oc:ts c:onne:c,te:n with the: fOTf":doSllTf': AAle And Rny oth~ ~osts connp.dp.o with the Shf":riff's ~::tlp. as spe:C:lfie:rl in writine hy thp. ]p.nop.r Rno hy perfonnine Rny othp.r re'l"irp.mp.nt. nnciP.T the mortSi'ef' Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F,ARLTFST POSSlRLR SHRRTFF'S SALR OATR - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately " months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THR LRNllRR: Name of Lender/Servicer: Address: Citicorp Trust Bank. FSB 7467 New Ridge Road, Suite 222 Hanover, MD 21076 800-446-7876 410-689-1610 Jaoa Gantt Phone Numher: Fax Number: Contact Person: RFFF.CT OF SHF.RTFF'S SALR - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSTTMPTION OF MORTr.Ar.R - You May Not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 40f6 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 ofliability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s! Mark J. Udren, Esquire W oodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 482-6900 Page 5 of6 von M A V A I ,SO H A VF. THF. RIGHT: . 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 OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT 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 BANKRUPTCV LAW. CONI':ITMFR CRF.nTT COTTNI':FI.TNG AGF.NCTFI': I':FRVTNG VOTJR COITNTV c.TTMRF.RI,AND C:0l1NTV CCCS of Western Pennsylvania, Inc. 2000 Ling]estown Road Harrisburg, P A 17102 (717) 54]-1757 FAX (717) 541-4670 Financial Counseling Services of Franklin 3] West 3rd Street Waynesboro, P A 17268 (717) 762-3285 FAX nla Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, P A 1710 I (7] 7) 234-5925 FAX (7 I 7) 234-9459 YWCA of Carlisle 30] G Street Carlisle, PA 170]3 (7]7) 243-3818 FAX (7]7)73t-9589 Community Action Corom ofthe Capital Region 1514 Derry Street Harrisburg, P A 17] 04 (7] 7) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 CarIis]e St. Gettysburg, P A 17325 (7]7) 334-]5]8 FAX (717) 334-8326 Page 6 of6 c::c. ~ ~ ~ ~ ~ ::E o Oc O~Oo ~=g:X1 m""mm :D <: '^ Z :DO~ -<oor; :I:Co::E r=o:DO 1:C~'" zmO'T1 <-~:DO O:D~rn CX>om5'" 8>0< c.:>Omc- z' -t m :D :::::~;;'r ___~1;h $ ~'Ll U~ C)tJ} $ -.. ~ ~ U".~."E~""""":L!.,~,..2.,!",~,,.~.,g~..,..J ~ ~ ' ~1'1""""II."'r. ::!=!::!=! ,,1.1. ~Il. 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I 1 ! (-..I 3'1 CJ 31 CJ ~, w ~I n. ru ill I ru "31 II"' 'CJ ~I CJ ~.' t:J "S!c III"' i-..J fir 'I ru :w '" w 1fJ1 'II"' ! ~ * , ....... --1J ~~ ~ "-.J ~~~ a ~~~~. 8. Il.~a<' '" ;:; 1l;:; 16 ~ ~ Bl. ~ - i~o g~ if 93 ii ~ JJ 0 H "[- ~ ;:; ~ a ~ . ~ c. o' ~ o ~ o ~ . . I .-'"P .. 0)> tIl ""C ~ C') ...... -'=O::J-(ll3'" ;; gfj:;:3. 3 ii _'::Ta-< ~"9.. ~:f:eg:;:~ i ",li;"~; ~~ II. CioC)Q:I~CD .!!. ~ll)~3.:t3 ~ :::;;a...CDU-<n I!. ~o~~~=- ;; Q:I:f"'" o.ON - g (ll ~g) ~~ II.. r:TJa.-.~ ~Q)Q1Q-~Q. ~ 3~gm~~ :.t -. 0 a. '" 0;"" !'l "'. - 0 - II ... --:::l 0.(1) I i~ s:!l~ .. i~; ~ll: - .. .. ~ lil <D " ::;; iii ~J ll"i ~ ~ -< \li &~ iil - o 1f !l; n- p..... p ~ '" a ~ 5l. '" .. <' . -< DO ~~ !l' JJ [ < 8. 5l >< ;r> "' <6' ~ . ~r~ ~ ~ ~~J "'" ' 0 ~\ 11 .. . & I DO ~~ ~a m . I . , i;-"'!.lII ~ . =- ~ - ;:. ~ ' ;5 '- i!'"" . ! . . " . i I V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udre\\ E'Q UDREN LAW OFFICES, 7V (2 'fq ~rl lrt .In.. (;; ...a Vl D f' 0 ~~r $ \-. " , .... --I 8 SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-01713 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS TRINDEL BARBARA E 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 , to wit: TRINDEL BARBARA E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT , TRINDEL BARBARA E 470 MCCULLOCH ROAD SHIPPENSBURG, PA 17257 ALTHOUGH THERE WAS OBVIOUSLY SOMEONE AT GIVEN ADDRESS, NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 28.98 .00 10.00 .00 56.98 ~,.. . Thomas Kline Sheriff of Cumberland County UDREN LAW OFFICES OS/20/2004 Sworn and subscribed to before me this J '[@ day Of~ Jcv'f~l A. D /) (--17"' (AI IuAd,<./, ~ Prothonotary 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 V\ WE HEREBY CERTIFY THE WITHIN TO BE A TRUE AN CORRECT COpy OF THE ORI~ ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION . : Cumberland County v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) : NO. 04 - 1'1\1 CI~~L 7~ 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 --- TRUE COpy FROM RECORD Iii r;~"lWj(m)' 'ii<fi':\f6i.if, I here unto set my hand ;}.~ '"~r"'" ?In-.. ~ . /Uft .r~ · ,~'5 P1GltlullOtaly V\!fV ^ l,~qHnd "J-'" c~ l \ '<'~ ~1 rO. "cl az t Ollld~ UtiOGO ;: I ",3'd"00 ;l;l1\l3HS 3Hl 30 3:lI;ljQ AVISO Le han demandado a usted en la corte. Si usted guiere defenderse de est as 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 previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Dsted 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 POll. TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONnE SE PUEDE CONSEGUIR 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 W oodcrest 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: 470 McCulloch Road MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township COUNTY: Cumberland DATE EXECUTED: 7/23/02 DATE RECORDED: 7/26/02 1766 PAGE: 1282 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. S. 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 3/16/04: Principal of debt due Unpaid Interest at 9.5% from 9/6/03 to 3/16/04 (the per diem interest accruing on this debt is $57.63 and that sum should be added each day after 3/16/04) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $0 should be added in accordance with the terms of the note each month after 3/16/04) Prior Interest Fees Appraisal Fees Attorneys Fees (anticipated to 5% of principal) $221,403.15 32,962.34 250.00 280.00 o 56.81 225.00 and actual TOTAL 11,070.16 $266,247.46 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 Defendant(s) the Plaintiff demands judgment, herein in the sum of $266,247.46 in rem, against plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren,\ SQUT~E UDREN LAW OFFICES, P~C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL that ~exta1n tra~t of land lying cand being situata ~n Southampton ,owns hip , Cwberland County, Pennsylvania, being tot No. 12 01\ a 5ub41vis10l\ Uan of Edward G. lIewsManger and 1\ , l?Iopertiaa, pUpated by John R. Kisalngor, dat.d June 9, 1992, said plan be~~g,r.co~ded ~n ene Office of the R~corder of D$e~s of Cusb.rland County in Plan Book 66, at lIage 55, mote fully bounded and d.scribad aa follo".: BEGl\lllING at an e"~.tlng railtoad .pike in Legislative Route #21006, known ao McCulloch Road, at the corntr of tot No. 11 Dn the h.reinbefore~doocrlbed SubdivisiDn l?bn; thence in said roadway, NDrth fifty-foux (54) degre.s oj;< (06) Minutes thirty (30) .econd. East, on. hundrod thixty-six and ten-hundredth. (136.10) feet to a railroad spike at the corner of Lot No. l3 on tin .aforesaid Subdivision l?lan; tbence aloog ..id LDt No. 13, South thirty-nine (39) degro.. four (04) minutes one (~l) second East. four hu~dr~d thirty~fou~ and one Qne-h':J'tldrl!dtb (434.01) fillet to .n iron pin; thence aloQg said Lot No. 13, North fifty-five (55) degreea oero (00) ..inuto$ forty-two (42) .ocond. En', on. hundred and twe"ty-tbru hundxedths (100.23) het to an ex~sting irOD pin Dt lands now ox fotmf.rly of Edward G. Newswang.er; the.nce .along $:a:l.d lands now or iox..ex1y of Newe.ansee, South thlrty-nine ~39) degre.. four (04) Minut.. thi1;ty-five. (3.5) second, :e.SBt., five hU1\dre:d f1fty-s1x and Bevent.etl-hundr~d the ('56.17) feet tD an lrOD pln at the edge of . proposed fifty (50) foot pxivate right-of-way knav.n as ~tait\ Drive; thence along silld proposed fifty (SO) foot private rlgllt-of-wllY, Scutl> fl fty (5.0) degrees fI Ity-saVIlt\ (57) minutes zero (00) ".conds West, two hundrad forty-sevon and II fteell-hundredths (2~7 .15) feat to an Iron pin; thence along said proposed frlty (SO) foot prlVllte right-Of-wllY, along. curve to tho right de.lgneted as OJrve "C", havirog a ct>ord bearing of North eighty-four (Sq) degrees three (03) minutes zero (OOl seconds Wast, one hundred seventy-siX end sevonty-eight hunclreOths (;16.19\ feet, a radius of one hundred twenty-five and zero-hLoldrodths (125.00) feet, and an arc length of ona lxJndred nlnety-sl" al1d thirty-five hundredtN (196.351 feet to an Iron pin; thence along said proposed fi ftv (50\ foot prIvate right-of-way, North thirty-nine (391 dogrees three (03) minutes zerO (00) seconds West, four hundred fI fty-seven and fi fty-elght hundredths (qS7.58) feet to an Iron pin at the comer of Lot No. lIon the aforeseld Subdivision Plan; then~ along said Lot No. 11. North fl fly-five (55) <legre..s ~*ro (00) minutes forty-t\w (ij2) seconds East, one hundred thirty-siX and twenty-nino hundredths (136.191 faet to pn Iron pin' thonce along said Lot No. \1, Nortl> thirty-nine (391 degr..S throe (03) mlnut~s twenty-savan (27) seconds Wut, four hundred thirty-one an;;! eighty-six hundredths (~31.86) feot to a rallrood spika In L.egialative Route 21006, knO\'O as M:OJlloch llDad, tl... place of BS:i1N'lltC. CINrAINltC 6.1Q ac.... pursuant to the aforesaid SUbdivision Plan. f . -of__ frc;tll the centerline 0 SUlJECf 10 a twenty-five (25) foot dedIcated r\!1'~d Subd\VIS1on Plan. legislative Route #21006. as shoWn on tho aforesa t March 17, 2004 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an offidal noti"e that the mortl'ftee on yonr home is in rlefalllt. anrl the lenrler intenrls tfl forerlflse. ~edfir information ahont the natnre flfthe rlefanlt is prov;rlerl in the IIttarherl pws The HOMF.OWNF.R'S MORTGAGE ASSTSTANCE PROGRAM (REMAP) may he ahle to help tfl save yonr home. This Notiee eyplains hflw the pr'Wam works. To see if HF.M A P ran help, yon mnst MKF.T WITH A CONSTTMF,R CRF,nTT COTTNSRT ,TNG AGENCV WITHIN 1/1 nA VS OF THF nA TF, OF THTS NOTTCR. Take this Nflti"e with yon when yon meet with thp C"nnselil\e A~enr}'. The namp, arlrlrpss anrl ph"np nnmher of Consnmpr Crp.rlit C:onnselin~ Aerneies sprville yonr Connt;y are IistPd at the enft of this Nflti"p'. If yon have any qnestions, Yflnml\}' can thp Pennvlvania Honsil\f Financp A!',f'n"y toll frep at 1-flno-:l42-2197. (persons with il11pairp.ft hearil\e can r..1I (717) 7flll-1 fl/i9). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECBO A CONTINUAR VlVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECBO A REDIMIR SU mpOTECA. EXHIBIT A Page 10(6 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Barbara E. Trindel 470 McCullough Road Shippensburg, P A., 17257 20-0051-02751602 Citifmancial Services Citifinancial Services HOMEOWNER'S NAME(S): PROPERTY ADDRESS: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM von MA V RF, F,T.Tr.IRI,F, FOR FTNANr.JAT. ASSISTANrF. WHIrR rA N SA VF, VOTlR ROMT<'. FROM FORRr.J ,OSnRF, AND HRT ,p von M AKF. FTTTIlRF, MORTGAr.R PA VMF.NTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE EUGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CffiCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELlGmlLITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF.MJ>OR A RV ST A V OF FORRr.J ,OSTlRR - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THTS MKIi',TINr. MTTST OCr.JTR WTTHTN THF, NRXT (111) nAYS. TF YOTT no NOT APPLY FOR EMERGENCY MORTGAr,E ASSISTANCE, YOn MTJST RRTNG YOTTR MORTGAGE lIP TO DATF. TIfF PART OF THTS NOTTCE r.ATJ.FD "HOW TO CTTRE YOTfR MORTGAGE DRFATJTT", EXPIATNS HOW TO RRTNG YOTJR MORTGAGE lIP TO DATE, rONSTJMIi',R rRF,DTT rOTTNSF.T ,TNG AGRNrmS - 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. Tb", n"m"'., "nnr",..",. "nn t""'T'hnn", n11mher. of C1",.iV'"t",C1 "on'"m"", """,nit cOlm.",linr; "B'n";,,,. fm thp, c011nty in which th", prop"'rty i. loc"tp,n "T'" .",t forth "t thp, p,nn of thi. Notic",. It is only necessary to schedule one face-to-face meeting. Advise your lender immp,.cli"t",ly of your intentions. APPUrATION FOR MORTGAGF, ASSTSTANrF, - 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 Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. Page 2 016 YOU MnST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. Ar.F.NCV ArrTON - 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. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have f'Iled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO r.lJRF, YOlTR MORTGAGF, DRF A lIT ,T (Rrine it 1IJ1 to dHte). NATTTRF, OF Tlffi nRFAIlT,T - The MORTGAGE debt held by the above lender on your property located at: 470 McCullough Road Shippensburg,P~,17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Partial Monthly Payment for the month of October 6, 2003 = $928.09 Monthly Payments of $1867,77 for October 6. 2003 through March 6, 2004 = $11206.62 Monthly Late Charges of $0.00 for October 6. 2003 throuzb February 6. 2004 = $0.00 Other charges (explain/itemize): Title/Appraisal Fee = $225.00 TOTAL AMOUNT PAST DUE: S12l59.71 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (no not 11<e if not .I'I'Ji~-"hle): JSLA HOW TO r.lTRF, THl/, nli'.1I A lIT ,T - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WIDCR IS S12,'<;9 71 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WillCR BECOME DUE DURING THE TlllRTY (30) DAY PERIOD. Paym~nts. mn.:rr he marlf', f':ither hy ~~~hJ rMhlP,r'~ ~h~r,kJ ....R:T1ifien (".hp.d( or mnnpy ornPT m~U'Je p::lyahl~ ann ~P.ntt(\. ndren I ,aw Offi~ell, l' .C. W ooder,,<f c.o'1'orat" C"nt..r 111 W ooder"ot Road, Snit.. 200 Ch..rry Hill, N.J 01l00~-~/i20 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (no not 1,"" if not 'I'I']i~.hl"): JSLA IF von no NOT c.TTRF TRF OFli' A TlT ,T - If you do not cure the default within THIRTY (30) DAYS Page 3 0(6 ofthe date of this Notice, tb.. l.mder intend. to e"erd... its ripbt. to a~.~elerate tbe mort~ d..bt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to rore~lo... 'Il'on )lonr mo~i1 pr'V'e11y. IF TIlF. MORTGAGF. IS FORF.n .OSF.n IWON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal 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. 1f )1m' ~nre tbe i1..r.1111t witbin tb.. THlRTV (.lll) nA V period )Ion will not he relp,ired to PllY attorn.."," ree.. OTHF.R I.F.NnF.R RF.MFnrn.S - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO r.IJRF. TIlF. nF.FATIl,T PRIOR TO SHF.RlFF'S SAI,F, - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon still hove the. rieht to r.ure the oefanlt ano prevent the <ale at any time np to one hOllr hefore the Sheriffs Sale Yon may 00 <0 hy payine the total amOlmt then pa<t ol1e, plns any late or oth.". r.harel's then o11e, rP.asonah1e attorney's fee< ann ensts conner.ten with the forer.ln<IlTe sale. ann any other r.o<ts r.nnner.ten with the Sheriff's SaIe as "l'ec.ifien in writine hy the lenn.". ann hy perfonnine any oth.". re'l"irements nnn.". the mnrtV'et' 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. FART.TF.ST POSSlRT,F SHF.RrFF'S SAT.F nATF. - It is estimated that the earliest date that such a Sheriff s Sale of the mongaged property could be held would be approximately (i 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. HOW TO r.om ACT TIlF, T ,F.NnF,R: Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person: Citicorp Trust Bank. FSB 7467 New Ridge Road, Suite 222 Hanover, MD 21076 800-446-7876 410-689-1610 Jana Gantt F.FFF,CT OF SHF,RIFF'S SAI ,F. - 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 Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSrlMPTION OF MORTGAGF. - You May Not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of6 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 Page 5 of 6 von M A V Al ,SO H A VF, TIfF, RIGHT: . 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 OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT 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. CONSTTMF,R CRF,DTT COITNSl?T ,TNG AGF.NCTF.S SF,RVlNG VOTJR COllNTY CIlMRF.RI.ANll r;OTfNTV CCCS of Western Pennsylvania, Inc. 2000 Lingtestown Road Harrisburg, PA 17102 (7]7) 541-1757 FAX (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAXn/a Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, P A 17101 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, P A 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capitat Region 15]4 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PAl 7325 (717) 334.1518 FAX (717)334-8326 Page 6 of6 ."-~.'-'-- ~ ~ ~ ~ :E o Oc O~CO :J:=~:D m"",mm :0 ""'en Z :oOO-lr -<OO~ :t:OO"'" FO;OO r:O~'" - mO'" ~~~o 0;0'-1'" ~omf' 0)>0"' ",ome Z' '-I m ;0 \, .,J CI CI UJ OJ .. . OJ = (p8lI'!Ilo>I~) II"' .........a.......... 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I ;rw"l1l::J if~. a soom!!l,m !!. -~~3:l3 a. ::;;Cl....<DUcn i' .go~~~':- II ~ st3 a.o~ -II ell lD ....8.2. m '00-::1'0.<:';:' =' cPl1l!1l.....~O' _ 3~~m-<~ i s=ad.~ii'~ it . :ro:,g.~ & (Do< :T~() = 3o"~o e; r~il" ~ ~ Q) !=' !ll ~ ~ c. Ii ~iii ir:i~ J,t) <" ~ ~ ~i ~ Q, ~J ~ - g~ - ~ ~~- :"l... C') ~ . :!' ".' Ii. ~ 3 a on ~~ " * 00 s. ~~ " ~ " "- j a ". " -< m >< ;>> !11 <g " ~ i S I ~ rI . " . i ~ V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udre~ "Q UDREN LAW OFFICES, ;RE P.C. (~'i~D ;hf~l .~:.ilJ - "~:,,::) l~~- .-.---..... \llfU ~'A <<'j;o .~~ v\ lfv!\ 1 ,\ C, IHl3d , ,'.i%'1 ~~i "d aZ e Q~ 111 Uti1\0\l "" !.J\JHM jjl\l~II~; ~ II g}f)\!jACI UDREN LAW OFFICES, P.C. BY: Mark J. Udren ESQUIRE ATTY 1.0. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-1713 Civil Term MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing senrice of the Complaint in Mortgage foreclosure upon Defendant(s), Barbara E. Trindel by regular mail and certified mail and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) at 470 McCulloch Road, Shippensburg, PA 17257, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit "A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being att:ached hereto as Exhibit "B". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage foreclosure by regular mail and certified mail upon said Defendant(s), Barbara E. Trindel and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. By: Mark J. Udr ,n, Attorney fo' P UDREN LAW OFFICES, P.C. BY: Mark J. Udren, ESQUIRE ATTY 1.0. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-1713 Civil Term MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265,. (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "Au, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage foreclosure. A good faith effort to discover the whereabouts of the Defendant(s)has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage foreclosure upon Defendant (s) by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW By: Mark J. Ud Attorney fo SHERIFF'S RETURN - NOT SERVED ~SE NO: 2004-01713 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS TRINDEL BARBARA E 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 , to wit: TRINDEL BARBARA E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT I' , TRINDEL BARBARA E 470 MCCULLOCH ROAD SHIPPENSBURG, PA 17257 ALTHOUGH THERE WAS OBVIOUSLY SOMEONE AT GIVEN ADDRESS, NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 28.98 .00 10.00 .00 56.98 -~ . Thomas Kline Sheriff of CU~Jerland County UDREN.LAW OFFICES OS/20/2004 Sworn and subscribed to before me i=XHIBIT A this day of A.D. Prothonotary (\l.l.n~o3l\~ May-24-04 12:38pm From-Player's Association 636 230 0!i58 T-924 P.023/036 F-193 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVEiST1GATION loan Number: 04030344 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number: Subject Barbara E Trlndel A.KA: None last Known Address: 470 Mcculloch Road Shlppensburg, PA 17257 last Known Number. (717) 532.9654 Melissa Kozma, being duly sworn sccording to law, deposes and says: 1. I am employed in the capacity of location Specialist for Players Nationall.ocator. 2. On OS/24/2004, I conducted an investigation Into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER(S):177-30-4458 B. EMPLOYMENT SEARCH: We were unable to verify current employment for Barbara E T'rlndel. C. INQUIRY OF CREDITORS: Creditors Indicated the last reported address for Barbara E TI~ndells 470 Mcculloch Road, Shlppensburg, PA 17267, with the home number of (717) 532.9654. Barbare E Trlndel filed chapter 7 bankruptcy in November 2003 with attorney Robert L Obrien. Release date of February 2004 Is given, Case # 2003-06547. INQUIRY OF TELEPHONE COMPANY. A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no IIsllng for Barbara E Trlndel. Wle contacted the home number of (717) 532.9654 and spoke with Barbara who stated ahe is IIvll~g al470 Mcculloch Road, Shippensburg, PA 17257. INQUIRY OF NEIGHBORS - N/A EXHIBIT B INQUIRY OF POST OFFICE- A. NATIONAL ADDRESS UPDATE: As of May 21, 2004 the National Change of Add..... (NCOA) has no change for Barbara E Trindel from 470 Mcculloch Road, Shippensburg, PA 17267. MOTOR VEHICLE REGISTRATION. A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Motor Vehicles has Barbarl' E Trlndellisted at 470 Mcculloch Road, Shippensburg, PA 17257. OTHER INQUIRIES- A DEATH RECORDS: As of May 21, 2004 the Social Security Administration has no> death record on file for Barbara E Trlndel and/or A.K.A's undsrths socielsecurlty number prov'lded. May-24-04 12:39pm from-Player's Association 636230 om T-924 P.024/036 f-193 B. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC. J; None Found. C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Barbara E Trlndelllsted at 470 Mcculloch Road, Shippensburg, PA 17257. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: August 1938 .. .NOTARY SEAL" Kr,sUml M. Scott, Netary Public SI. Lows C.ourlly, State of MIssouri My CommJsslon Expires 9/2/2006 Players National Locator 174 Clarkson Road, Suite 22~j St. Louis, MO 63011 Phone: (636) 230-9922 Fax: (636) 2"0-0558 E:XHIBIT B VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec .a904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Date: ~ Mark J. UdJ Attorney for 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 Citifinancial Services, Inc. Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-1713 Civil Term CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: x Regular First Class Mail Certified Mail Other Date Served: TO: Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 UDREN By: Mark J.' T r n, squire Attorn~y for Plaintiff (") "'" c:: = 0 c""> "'- ...., 5;: ~ -< fll :::D t"'.) .- vrn a. .o? C) :r:... ::~j ~i'} ci -", (:~f~ ,~--- <;:~) qcn :::'::j -< :.0 C) -< ~ UDREN LAW OFFICES, P.C. BY: Mark J, Udren, ESQUIRE ATTY I,D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 MAY 2 7 2004Y ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. Plaintiff . : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-1713 Civil Term AND NOW, this consideration of ~ ORD C day of Plaintiff's Motion and the , 20 fI~ ,upon Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage foreclosure and all subsequent pleadings on Defendant (s) , Barbara E. Trindel, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage foreclosure and all Subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Barbara E. Trindel at 470 McCulloch Road Shippensburg, PA 17257 and by posting the mortgaged premises located at 470 McCulloch Road, (Southampton Twp)Shippensburg, PA 17257. J. . \f1~,\\;i,/\1}.,:;i Al~!nc.(i c: I Z :t; lid 1- f,!ilr ~OOZ I\HV10NOH10cd 3Hl :10 381:1:10-0311.:1 AT'TORNEY 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 Defendant(sl \ COURT OF COMMON PLEAS \ CIVIL DIVISION \Cumberland County \ NO. 04-1713 Civil Term citifinancial services, Inc. Plaintiff v. Barbara E. Trindel PRAECIPE TO REINSTATE COMt"LAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: June 9. 2004 unREN, ~S, P.C. Mark ~. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF 0 '" = ~ c = 5: .r- l:JG. '- ~:D rnn c:: Z:::r. ~. ~ -or;:; ~~. i80 <c.: --IQ ~t."l> r'~ ;I>> :;r:=H z"-) ::r u-.. -C.I .,..0 >c Gin ;i:~ ~~ _h! N 3'j -< +' -< UDREN LAW OFFICES, P.C. BY: Mark J, Udren, Esquire ATTY I,D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-171.3 Civil Term The undersigned hereby verifies that he is counsel for plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Complaint in Mortgage foreclosure to Defendant (s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER DATE MAILED: Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 I verify that the statements made herein a.re true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: ,,"REM ~CES' P.C. Mark J. Udren, Esquire Attorney for plaintiff :-1 :<( '-D .- ~ o Ii o Ir- <!'I' , - if"" ~I.L t ~ ~l~f ! I.L .. ~ Ii if .. , 0 . l~ ~i t iN LAW OFFICES. P.C. ~liIi CORPORATE CENTER WOOOCREST ROAD ~AAV Hill. NJ 08003 .. E& 9000 0922 9000 0922 II I J\[ .J '''llffW 031:111H33 ... ... .. .. ... ... ... -;;'-ai'~oa l.V o,(;,t sS3~aQ;N~n~';; ~H'i JO ... ... .. .. ... ... ... lH!)Il:l 3H.t. OJ. 3d013M13,jO dO.lllf tB)lOl.l.S 3:J'lf1d '~: ~c-b'l'<c-~ ~. \c-:NCQ..\ 470 YY\"-c...ull~ ~A,\) SI....\>~~V\'SIou\.3. l I(A \'l'Z.s-rz . ...Ej...n 0:.-- . · :'O>);Io)>CD c.:.~ ~2.:::;: m8,"" ;;tlDS':Dg.6' 115 fJ go (i r:: 3== ~~Q (Dill a.g-@@-S' ~...c ~::3:iit :I\!!= aII:::11:D lD" 8-; ~'Cmi([)!!I @-z Ei =::J 8.g::iCD = ~-I-S:-2 0$~ &g&.1a.~QJ men 8. &.... a (D c5=- &~ ~ ii"i3" !!lm lD . s-3-=Oo'8: 91 ~ ~ 3:i 2.1f (;! _n-l& lDmti8:, lDCI)Oa:"2.>l!!.e.ao.::Ig_ ;'.,,: = ;l~ ~lg. &igi!; ~ ~ ~~ i ~"S:; _00: CD ~ ~::I :::111::1::1 Cil m .... '<'" .""'1'" ..... ~Cl GI 8. O~::f l !!. ; CD:Dat 8 Cl a o~ '< S' ~ C1._ (ll CD:;;t. _ CD<ll (11::1 !l! z' ~... _ :1 ~~ po 0 ii J i. ~~.lD !~ ~!:( ! g =-- ~= c; i~~i.! go ~;PS':IJ~! m~ ~ i oi i !It "'Olg,,}.. - c'!"'iE!"" "'m li'ii.;;;" Q. .lii .,3ii 3 l!!.. Pi. ii . sr; i ~l -< . " ~ .....;1-. . ;;r,,~ ~-- Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front jf space permits. 1. Article Addressed to: B. Received by ( Printed NamE~) o Agent o Addressee C. Date of Delivery x D. Is delivery address different 1'rom item 1? 0 Yes If YES, enter delivery address below: 0 No ~M'~A- Q.. - l - \ (\ ~6e.. l.\lC YYl<L~L>lto~ \?o.A.D Sh\Q>~'"-"".sb\J':)( ?A n2.51 3. ServiCj)JYpe IZJ,.<:'6rtlfied Mail 0 9PF~s Mail o Registered ~etum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes " ll...+!"l...."... ..._.. 7003 2260 0006 7567 5176 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 <C"" . -. 0 ,.., = 0 c = " ~ ..... -1:.:' , (.... .-1 c= .,- -"-- -,. Ri:D ~- ,- -om " , CI'> :0'1' ...- ~3() ~ :Do -,..."T. .J::( i'? .,'[ )-~}~ :::: 0 ,S m ""--, ,.-1 :;! :>- 0 :n -.I -< CASE NO: 2004-01713 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS TRINDEL BARBARA E RON KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TRINDEL BARBARA E DEFENDANT was served upon , at 1530:00 HOURS, on the 25th day of June at 470 MCCULLOCH ROAD SHIPPENSBURG, PA 17257 POSTED AT 470 MCCULLOCH ROAD by handing to SHIPPENSBURG, PA a true and attested copy of COMPLAINT - MORT FORE the , 2004 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Posted Surcharge 18.00 8.97 6.00 10.00 .00 42.97 Sworn and Subscribed to before me this Ijf::- day of C),~ ,){tIJ'f A.D. n 0. '1H-<~ ' A w.; ~onotary '7-' So Answers: .r~%-~~~ R. Thomas Kline 06/28/2004 UDREN LAW OFFICES By: 1Z~)c-- Deputy Sheriff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) NO. 04-1713 Civil Term 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) Barbara E. Trindel for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 03/17/04 to 07/30/04 TOTAL $266,247.46 7,837.68 $274.085.14 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. DAMAGEf: ARE HEREBY ASSESSED AS DATE:U~ } aCff{ INDlfrED . l -A.M~ PRO FROTHY Riu ~ ,:,".'l ".::1- G,":: L~,-. ,:,.) _.--~----_............--,_._---_. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Citifinancial Services, Inc. Plaintiff ATTORNEY FOR PLAINTIFF v. 1 COURT OF COMMON PLEAS 1 CIVIL DIVISION i Cumberland County i ~ NO. 04 -1713 Civil Term Barbara E. Trindel Defendant(s) Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 DATE of Notice: July 19, 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 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAB DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED 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 COL IS DEEMED TO BE A DEBT COLLECTOR DEBT. ANY INFORMATION OBTAINED W CTICES ACT, THIS LAW FIRM IS AN ATTEMPT TO COLLECT A FOR THAT PURPOSE. UDREN LAW OFFICES, P.C. BY: MARX J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) NO. 04-1713 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Barbara E. Trindel Over 18 As captioned above Unknown Sworn to and subscribed before me this 30th day ~J0~,~ Notary Puolic CARA STIARS ~OINEWJERSFf 0lmmItaI0n ~.4/16/DJ4 UDREN LAW OFFICES, P.C. ,-', BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER l~l WOOD CREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) NO. 04-17~3 Civil Term TO: Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. -K- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 ~ I~% ~ f '" "-/ r () c> c -" c--.-. - - ~ 0'\ ~ t( 0' 'r--' t \ c4 ,_.,l -1,(_) C' :---",'"'; -~ ,,' - - -,.....- \ --- ?' .' r .,~, -- r ~ (- --==- --- ~ <::./I c...J'I \ , =- ~ d D --{:. 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 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 04-1713 civil Term TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due $274,085.14 0/ Interest From 07/31/04 to Date of Sale December 8, 2004 Per diem @$57.63 (Costs to be added) 7,549.53 $ UDREN LAW OFFICES, P.C. (~) r-,.') (~" 20.; I (,~L Go.., UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE I"" WRIT OF EXECUTION Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) 04-1713 Civil Term TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 470 McCulloch Road (Southampton Twp) Shippensburg, PA 17257 SEE LEGAL DESCRIPTION ATTACHED Amount due $274,085.14 Interest From 07/31/04 to Date of Sale December 8, 2004 Per diem @$57.63 (Costs to be added) 7,549.53 $ Prothonotary By Clerk Date COURT OF COMMON PLEAS NO. 04-1713 Civil Term -~-------------------------~--------- ------------------------------------- Citifinancial Services, Inc. vs. Barbara E. Trindel ------------------------------------- ------------------------------------- WRIT OF EXECUTION ------------------------------------- ------------------------------------- REAL DEBT $ 274,085.14 INTEREST $ 7,549.53 from 07/31/04 to Date of Sale December 8, 2004 Per diem @$57.63 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ PREMISES TO BE SOLD: 470 McCulloch Road (Southampton Twp) Shippensburg, PA 17257 ALL t:hat ~.~t"1n tra"e of laM lyi..& aM ba1n& situata l.n Southampton Township Cumberland Count" l'annaylvanl.a, baing Lot No. 12 ona Subdivision Plan of Edward G. New....anger and 11 l' Properti.., pupated by John R. Kinin or Jun~ 9, 1992, said plan b.jn8.reco~d.d in ~he Office of the aecorder o~ D~e::C:~ cum:elr11and County in Pt.n Book 66, at 1'ag. 55, more fully bound.d .nd d.scrib.d AS...O Olf'S; I I BIlGIlIIlING at: an edoting raHroad spike in L.g1s1acive Roote #21006 klUl &CullCJctl Ro.ad', at toe canter of tot No. 11 on the: tuH:..1D.b..fQre....de:9c~b:~ Subdividon PIa,,; th....,e in sdd roadway, Norch fifty-fout (54) degr... .1>< i~~~ ~~,,)ut.. thirty (30) .econda Ea.t, one hundred thlrt,-s1x and ten-hundr'dths . feet t'o " railroad spi.ke at the corner of Lot No. l3 on the ".fore.Bid :Ubdiv(i8ion Plan; then.. along .aid Lot No. 13, South thirty-nine (39) deg~... ou%' O~) Dlinutes one (~l) ..c.ond East. four l1undrltd th:irt1-fou.t" .a~d one: on.-lt~ndradt:h (434.00 i..t to an iron pinl th..... alo..g ...d !.ot 1/... D, Nn~th fifty f:1v. (") d.grees "~o (00) ..:1nuto. forty-two (42) s.cnnds Eest one hundred and tw""ty-.llru hundredth. (100.23) foet to an oxis<1ng iron p~" at ;lndB now 07: tormtl:t'ly ot Edward C. Newsve.nger; thancl! slo1:lg sa{d land. now or nr..etly of Newswanger. South thirty-nine (39) degr... four (04) ..inu... ~~;~tY-liva (35) s."onds Ees., av. hundred fJ.fty-si>l and uV''l.taen-h"ndtedth. .17) fee. to an iron pl... at the .d.. of . propos.d fi~ty (SO) foot private right-of~way knov.n all Mluntllln DrIve; thence alCI'Q said proposed Tlfty (50) foot prlVllte right-of-way. South fI fty (50) degrees fI ftY-SllVllll (57) minutes zero (001 sec:oncls West. tv<> t1.mdrQd forty-seven and flft..Il-tlJodredtM (2~7.15) f.et to an iron pin; thence along said proposed frtty (50) foot private rlght-QI.......y. along a cLlrve to the rIght designated as u"ve ''C'', haV11Ig a chord bearIng of North eighty-four (S~) degrees three (03) minutes Zero (001 saconas West, one hundred ."venty-slx and sevonty-eight l1Jndredtlls (176.78) f....t, a radluli of Qne luldred twenty-five and zero-hundredths (125.00) feet, and an arc length of one n..nared ninety-six and thirty-five Iu1dredths (196.35) f.et to an iron pin: thence along .aid proposed (j (ty (SO) foot private right-of-way. North thirty-nine (39) d"9rees three (03) minute" zerO (00) seconds West, four hundred fl fty-seven and fj fty-elght tJJndredth. (~57 .58) feet to an iron pin at the comer of Lot No. lIon the 8for8$8ld Subcllvlsloo Plan; thence al""" said LDt No. 11. North fl fty-flve (55) degrees ..ro (00) mInutes torty-tv<> (~l) seconds ea.t, on.. hundred thirty-six and hNenty-nlne hundredth. (136.2S) leet to ~ Iron pin; thence along said Lot No. 11, North thirty-nine (39) dllgr.." three (03\ minutes tWCllty-seveo (27) .econds Weat, four hundred thirtY-aile and elghty-.ix hundredths (UI.86) feet to a railroad spike In Legislative Rout.. 21006, kIl<lHl as M:OJlloch Road, t1'\4 place of as:aN'lII'G. Ct:NTAININ:: 6.1Q acr.s pursuant to the aforesaid SUbdivision Plan. . . f frc:tn the eMI.r! lne of SLBJECr 10 a twmty-five (25) foot dedicated r\-9ht;;t s.'::'\vislon Plan. legiSlative Route #21006. as shown on the afor"5el - r-J' BEING KNOWN AS: 470 MCCULLOCH ROAD, (SOUTHAMPTON TWP) SHIPPENSBURG, PA 17257 39-15-0177-048 PROPERTY ID NO. : TITLE TO SAID PREMISES IS VESTED IN BARBARA E. TRINDEL BY DEED FROM H T PROPERTIES, A PARTNERSHIP COMPOSED OF J. MICHAEL HILL, JAMES R. HILL, DONALD E. THRUSH, AND LANE I. THRUSH DATED 07/22/93 RECORDED 05/03/94 IN DEED BOOK 104 PAGE 998. ~p c;:>'C) ;0 ~ ~ 0= cf \ .-- <1G f; U\ Uj R., '" ~ 2' ? '?\ -+-'1" LA .....c'\ ~- C;' 4:'\ 0<:' '€) --i '> i r- Im '- . .-., c.'" c:::' I c,) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-1713 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC. Plaintiff(s) From BARBARA E. TRINDEL, 470 MCCULLOCH ROAD, SHIPPENSBURG PA 17257. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 470 MCCULLOCH RORAD, SOUTHAMPTON TWP., SHIPPENSBURG P A 17257 (SEE LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $274,085.14 L.L. $.50 Interest FROM 7/31/04 TO 12/8/04 @ $57.63 per diem = $7,549.53 Ally's Comm % Due Prothy $1.00 Ally Paid $18145 Other Costs Plaintiff Paid Date: AUGUST 3, 2004 (Seal) CURTIS R. LONG prothJ. tary / I By: \. ~./d Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: 111 WOODCREST RD" STE 200 WOODCREST CORPORATE CENTER CHERRY HILL NJ 08003-3620 Attorney for: PLAINTIFF Telephone: (856) 669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 NO. 04-1713 Civil Term Defendant(s) C E R T I FIe ATE Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark C) r-:'I , c.":':) .~',~' C"~ c' .\'- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF 1:. !COURT OF COMMON PLEAS 1 CIVIL DIVISION i Cumberland County I MORTGAGE FORECLOSURE ~ Barbara E. Trindel ~,.:NO. 04-1713 Civil Term 470 McCulloch Road Shippensburg, PA 17257 I Defendant(s) ~ AFFIDAVIT PURSUANT TO RULE 3129.1 Inc. Citifinancial Services, 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff v. 7, k!).c aft Na,rnE FenCl 1: Citifinancial Services, Inc., 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: 470 McCulloch Road, (southampton Twp) Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Address Name Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 1reri:cy 'l:':t'ect t lief C th.e' 1 lei.!' Per; ~CCit. ~l f Defendant(s) in the judgment: 2. Name and address 0 d Ad ress Name SAME AS # 1 ABOVE , dent creditor 3, Name ~d addr~s o:ale;r;p~:tito be sold: record l~en on t e r Address Name whose judgment is a 4. Name and of record: Name recorded holder of every mortgag< address of the last rED: JUly 3 None Address plaintiff herein. see caption above. Pennsylvania Housing Finance Agency 2101 North Front Street pOBOX 15530 H~r~isburg, PA 17105-5530 ------ --~.~_..- -------- -, ~-...~._~ f , , ( {; c. c . , ..r~' 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Department 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 470 McCulloch Road (Southampton Twp) Shippensburg, PA 17257 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: July 30, 2004 c- c) .: "0 f;"" C':;':::) ....C'~ ("' -lj . . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 NO. 04-1713 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Your house (real estate) at 470 McCulloch Road, (Southampton Twp) Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 8, 2004, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $274,085.14, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s Sale, you must take immediate aotion: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may calI: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 5400. 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 calI 856-669- 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 (-;-, ~, <.:;:-.:.:) .:::_~ -"^.'" in I c.-. (,,,J .,J;;:~. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) NO. 04-1713 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COm~T ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defe.ndant (s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: November 8, 2004 & November 23, 2004 Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 7, 2005 Mar 04030344 MAY 2 7 2004 , f; UDREN LAW OFFICES, P.C. BY: Mark J. Udren, ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. Plaintiff . . COURT OF C:OMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04-1713 Civil Term consideration of o R D E R 1st day 0 f .:j u..t..l'e.. Plaintiff's Motion and the l~ffidavit of Good Faith , 20 aLl , upon AND NOW, this investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage foreclosure and all subsequent pleadings on Defendant (s), Barbara E. Trindel, shall be complete when plaintiff or its counselor agent has mailed true and correct copies of the Complaint in Mortgage foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Barbara E. Trindel at 470 McCulloch Road Shippensburg, PA 17257 and by posting the mortgaged premises located at 470 McCulloch Road, (Southampton TwplShippensburg, PA 17257. BY THE COURT: ~t~ see:! 'S' e5InsOd ~o.L ..... .......... (pelrnbel:;! iU8W88JOpt.13) 99:1 Nw.i}eO ~el:l (p9J''''''H_31 El9:!ld9!O&l:IWnt9t1 98:;lP9!:IAJ&.) .-.. 3sn ''\fIOL::i (paplAOJd a15eJ9AO:) a:JuI!JnSUI oN :AfuO flew ~llsawOa) .1dI3:)38 "ll'VW 031:11.183:) "'<lOI^J3S 1l!ISOd 's'n '" '" CI ' CI CI ' CI .>:: .>:: CI CI '" '" U1 i U1 CliO CI CI CI CI CI ' CI UJ UJ Ln , Ln ru ,ru CI CI UJ UJ l.n l.n ..D ..D ... ... ru ru i",:' 'i\,l)'~, .'i:: ::";:,{{:1~ ' "~ r.. 0 '"' H F( <J] 00 r.. r.. H t- p:: U) '"' N III t- OO rl'O..... <IJ n:l r.. '00"; 0 r:;p::p., -rl r>l ",.r:: - u E-; U OJ H o '" E-l . rl ;:J 0 Wrl..Q Z ;:J [J] n:l U r:: '" U <IJ n:l ~o. ..Q 0. 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"'~~fl.1t ~ :-- \ " ~ o 1 '" c 'S 'ffi ~i;l a: l~ \ \i~ 0. ~ ~ w m E -a; o 0. ~ "- - C '0 "- Iii en ~ o "'- .EO .: ! 'C ~ g; ~ > .<l ~ ;; Q. E o o Q) .<l - <II " ::0 E ~ o u. o m 1l)5~~ ~O- 0._ "68 ... _Cl. \ .8~ OJ OJ E] - -f _~ 1:- ~ '" su \ ~&: ;: "" Q) w U. m ,..: g to- - a:.... <Xl ~~ '" E ~<f) '--, (; - E> U. ~.P -;:] (fJ :E Q) - ~- Cl. ~ -0 0- cr 1~ I~::l 1ii ~ r ..;- El '" ~ :E " yo ~ ~ " '" ~ 0. 1'" ..L. .- 1"' .t- oo .b 1-";- '" \."\\ .--:~ --- (...." G' UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) : NO. 04-1713 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit: "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the daters) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit liB" . 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served w'thin the time limits set forth by Pa Rule C.P. 3129. BY: enalties of 18 Pa.C.S. ification to authorities. This Affidavit s m Section 4904 reI Dated: February P.C. UDREN LAW OFFICES, Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 04-1713 civil Term v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) DATE: October 12, 2004 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Barbara E. Trindel PROPERTY: 470 McCulloch Road (Southampton Twp) Shippensburg, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on DecembeJ~ 8, 2004, at 10:00 AM, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specif ied 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 ~ ~12 ~ rn o ~ ~o:: '" ~$ ",u. m (\l ......_ "00'" ~- m ~o~ }!J.~_ _CO '$~ $ 113 E'a ~o8 E,!1Oi m m C mgg .~:e ;p ~5~ ~ ci $ .::'ciJu.. ~ . '" cci:R <lolo:'u... ~ ~ 'ai 0"0" 4:: &0 ""'0 E Ill::= " 0 ~" ~~ ..... 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NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 plaintiff v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 04-1713 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defe.ndant (s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: November 8, 2004 & November 23, 2004 Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 7, 2005 04030344 Mar UDREN e J.S8iHjfa MAY 27 2004 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, ESQUIRE ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Citifinancial Services, Inc. Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Barbara E. Trindel Defendant(s) : NO. 04 -1713 Civil Term AND NOW, this 1St. o R D E R day of .j~ , 20 0'1 , upon consideration of Plaintiff's Motion and the 1\,ffidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage foreclosure and all subsequent pleadings on Defendant(s), Barbara E. Trindel, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Complaint in Mortgage foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Barbara E. Trindel at 470 McCulloch Road Shippensburg, PA 17257 and by posting the mortgaged premises located at 470 McCulloch Road, (Southampton Twp) Shippensburg, PA 17257. BY THE COURT: ~jC:. ~J rE,r.H U:~ rr e . - ch17 $ see.::l'lle~ fBIO.l (P8Jtnbey ~UBWesJoplf3) 88;jAl9AII8CP8JOIJIS8I::1 ..... -)L f (P9Jlnbel::lIU8W98JopU3) -.. ~Jd8roe1:lWl'll&l::I (Ir; r ""'''''''00 L " $ ""- L 3sn ''\1101.:fdlQ I .. . . . . .. (paplllO.Jd a6eJiJl1o:J iJ:Juemsuf oN :A,UQ flew :J/Jsawoa) 1.d13J3~ 'll'VW a3I:::1I1.~3J aJI^Jas 18jSOd 's'n """"';"'i.'..""U., -~~"._-"., I::::,; ;:!i= ...,~ i.'i~fU~ '~ ,.d==" ;':'\3~~w'.~. ,,; ,[ "\;'.;~-::.{NI!~ (~; ,,~;;,Cp~~ i' 't:;.,.: :~ ;"""" -.'" '':"L '_C, ~.' :8'''" ;;. . i '';\N'l~,n, .' 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Trindel In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1713 Civil Term Valerie Weaxy, Deputy Sheriff, who being duly sworn according to law, states that on September 10,2004 at 2: 11 o'clock PM, she served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Barbara E. Trindel, by posting the premises located at 470 McCulloch Road, Shippensburg, Cumberland County, Pennsylvania, with a true copy of the Real Estate Writ, Notice of Sale and Description, pursuant to order of court, according to law. Cpl. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 26,2004 at 6:18 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Barbara E. Trindellocated at 470 McCulloch Road, Shippensburg, 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: Barbara E. Trindel, by regular mail to her last known address of 470 McCulloch Road, Shippensburg, P A 17257. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of ~~n;?rs: ~ - ~,....-:.~ -r _e-- ~ R. Thomas Kline, Sheriff Br0C\~I.NLl1--t\ Real Estate eputy 2004, A.D. Prothonotary EXHIBn- B -"1 {,I - ...... . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: ()</-/7~ I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby cert fy that the Sheriffs Deed in which Central Penn Propertv Serv Inc is the grantee the same having bee sold to said grantee on the 2nd day of March A.D., 2005, under and by virtue of a writ Execution issu d on the 3rd day of August, A.D., 2004, out of the Court of Common Pleas of said County as of Civil erm, 2004 Number 1713, at the suit ofCitifinancial Serv Inc against Barbara E Trindel is duly recorded i Sheriffs Deed Book No. 268, Page 1955. IN TESTIMONY WHEREOF, I have hereunto s t my hand c;-t/ and seal of said office this day of ,A.D. Record r of Deeds ~~::. . ' . .. ... SCHEDULE OF DISTRIBUTION SALE NO. 24 Date Filed; April 0 I, 2005 Writ No. 2004-1713 Civil Term Citifinancial Services, Inc. VS Barbara E. Trindel 470 McCulloch Road Shippensburg, P A 17257 Sale Date: Buyer: Bid Price: March 02, 2005 Central Penn Property Services, Inc. $174,900.00 Real Debt: Interest: Attorney Costs: $274,085.14 7,549.53 181.95 Total: $281,816.62 DISTRIBUTION: Receipts: Cash on account (08/13/2004): Cash on account (03/02/2005): Cash on account (03/18/2005): Total Receipts: $ 1,500.00 17,490.00 164,812.00 $183,802.00 <J 6 4. >\~q~1' C \(g '1\~{ Q.. Disbursements: Sheriff's Costs Legal Search State Transfer Tax Local Transfer Tax Cumberland County Tax Claim Bureau Vivian Coy, Local Tax Collector Attorney Mark J. Udren Citifinancial Services, Inc. Total Disbursements: Balance for distribution: So Answers: r~ ,~t:~ R. Thomas Kline Sheriff $ 4,773.46 200.00 1,852.00 1,852.00 2,942.69 414.90 1,500.00 170,266.95 ($183,802.00) 0.00 TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SA TIS FACTO Y EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 24 as advertised for December, 2004 Sheriff Sale Held Wednesday, March 2, 2005 Date: March 2, 2005 TAXES: Receipts for all taxes for the years 2002 to 2004 inclusive. Taxes for the curre t year 2005. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or se er. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2005, and record , 2005, in Cumberland County Deed Book , Page RECITAL: Being the same premises which H. T. Properties by deed dated July 22, 19 3 and recorded May 3, 1994 in the Office of the Recorder of Deeds in and for Cumberland Co nty in Deed Book 104, Page 998, granted and conveyed to Barbara E. Trindel. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in rea and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of L.R. 21006, known as McCulloch Ro d. 6. Conditions, easements and restrictions shown on or set forth on Plan for Edwar G. Newswanger and H T Properties recorded in Cumberland County Plan Book 66, Page 55. 7. Mortgage in the amount of $222,119.00 given by Barbara E. Trindel to Citifinan ial Services, Inc.. dated July 23, 2002 and recorded July 26, 2002 in Mortgage Book 1766, Pa e 282. Complaint in Mortgage Foreclosure filed on April 20, 2004 by Citifinancial Ser ces Inc. as Plaintiff against Barbara E. Trindel as Plaintiff in the Office of the Prothonotary to Ie number 2004-1713. Judgment in the amount of $274,085.14 entered on August 3, 2004. 8. Mortgage in the amount of $31 ,500.00 given by Barbara E. Trindel to PHFA da ed September 12,2003 and recorded September 23, 2003 in Mortgage Book 1849, Page 1685 9. Delinquent real estate taxes turned over to the Cumberland County Tax Claim in the amount of $2,923.17 as of the date of this report. 10. Rights granted to Adams Electric Coop, Inc. by instrument recorded in Miscell eous Record Book 481, Page 700. 11. Rights in private road adjoining the subject premises as shown on the aforemen ioned subdivision plan. No right of access over said private road is covered in this report. 12. Rights granted to United Telephone Company of PA. by instrument recorded in Miscellaneous Record Book 103, Page 385. 13. Rights granted to Adams Electric Coop, Inc. by instrument recorded in Miscell eous Record Book 225, Page 668 and in Miscellaneous Record Book 253, Page 873. 14. Rights granted to the Shippensburg Borough Authority by instrument recorded n Miscellaneous Record Book 377, Page 117. 15. Rights granted to Pennsylvania Electric Company by instrument recorded in Miscellaneous Record Book 85, Page 350. 16. Under and subject to building and use restrictions as imposed by deed recorded 'n Deed Book 104, Page 999. 17. Satisfactory evidence to be produced that proper notice was given to the holder of all liens and encumbrances intended to be divested by subject Sheriff Sale. 18. Building set back lines and conditions as shown on or set forth on subdivision ans recorded in Plan Book 28, Page 30 and in Plan Book 34, Page 72, which may be imposed n the subject premises by implication. 19. Real estate taxes accruing on and after July 1,2005 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made t determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has an search been made for environmental liens in Federal District Court. J, Robert G. Frey, Agent Note: This Title Report shall not be valid b" ding until countersigned by an authorized signata y" .IS} feet to an iron pin; th nee along said proposed fifty (50) D t private right-of-way. along a cu e to the right designated as Curve "C", hav- ing a chord bearing of No eighty- four {84) degrees three (O minutes zero (00) seconds West. ne hun- dred seventy-six and sev nty-eight hundredths (176.78) feet. a radius of one hundred twenty five and zero-hundredths (125.00) feet. and an arc length of one hundr d ninety- six and thirty-five hu dredths (196.35) feet to an iron p ; thence aiong said proposed fifty (50) foot private right-of-way. Nor thirty- ~e (39) degrees three (03 minutes zero (00) seconds West. ur hun- dred fifty-seven and fifty-e ght hun- dredths (457.58) feet to iron pin at the corner of Lot No. 1 on the aforesaid Subdivision PI ; thence along said Lot No. II. N rth fifty- five (55) degrees zero (00) minutes forty-two (42) seconds ast, one hundred thirty-six and tw nty-nine hundredths 036.29) feet t an iron pin: thence along said Lo No.1!, No.rth thirty-nine (39) de es three (03) minutes twenty-seven (27) sec- onds West. four hundred -one and eighty-six hundredths (431.86) feet to a railroad spike i Legisla- tive Route 21006, known a McCul- loch Road, the place of BE INNING. CONTAINING 6.14 acres ursuant to the aforesaid Subdivisi Plan. SUBJECT TO a twenty five (25) foot dedicated right-of-way om the centerline of Legfslatfv Route #21006, as shown on the oresaid Subdivision Plan. BEING KNOWN AS: 47 McCul- loch Road. {Southampton ) Ship- pensburg, PA 17257. PROPERTY ID NO.: 39- 048. TITLE TO SAID PRE VESTED IN Barbara E. T 'ndel by deed from H T Properties a part- nership composed of J. Mic ael Hill. James R. Hill, Donald E. Thrush, and Lane I. Thrush dated /22/93 recorded 05/03/94 in De d Book 104 Page 998. REAL ESTATE SALE NO. 24 Writ No. 2004-1713 Civil Citifinancial Services. Inc. vs. Barbara E. Trindel Atty.: Mark Udren ALL that certain tract of land ly- ing and being situate in Southamp- ton Township, Cumberland County, Pennsylvania, being Lot No. 12 on a Subdivision Plan of Edward G. Newswanger and H T Properties, prepared by John R. Kissinger, dated June 9. 1992. said plan be- ing recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66, at Page 55. more fully bounded and described -- as follows: BEGINNING at an existing rail- road spike in Legislative Route #2 1006, known as McCulloch Road, at the corner of Lot No. lIon the hereinbefore-described Subdivision Plan: thence in said roadway. North fifty-four (54) degrees six (06) min- utes thirty (30) seconds East, one hundred thirty-six and ten-hun- dredths (136.10) feet to a railroad spike at the corner of Lot No. 13 on the aforesaid Subdivision Plan' thence along said Lot No. 13. South thirty~nine (39} degrees four (04) minutes one (01) second East. four hundred thirty-four and one one- hundredth (434.01) feet to an iron pin: thence along said Lot No. 13, North fifty-five (55) degrees zero (00) minutes forty-two (42) seconds East. one hundred and twenty-three hundredths {100.23) feet to an ex~ isting iron pin at lands now or for- merly of Edward G. Newswanger: thence along said lands now or for- merly of Newswanger. South thirty- nine (39) degrees four (04) minutes thirty-five (35} seconds East. five hundred fifty-six and seventeen- hundredths (556.17) feet to an iron pin at the edge of a proposed fifty (50) foot private right-of-way known as Mountain Drive; thence along said proposed fifty (50) foot private right-of-way. South fIfty (50) degrees fifty-seven (57) minutes zero (00) seconds West, two hundred forty~ seven and fIfteen-hundredths (247~ Citifinancial Services, Inc. VS Barbara E. Trindel In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1713 Civil Term Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on September 10,2004 at 2:11 o'clock PM, she served a true copy of the within R al Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upo the within named defendant, to wit: Barbara E. Trindel, by posting the premises locate at 470 McCulloch Road, Shippensburg, Cumberland County, Pennsylvania, with a tru copy of the Real Estate Writ, Notice of Sale and Description, pursuant to order of cou , according to law. Cpl. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 26, 2004 at 6:18 o'clock P.M., he posted a true copy ofthe with n Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon th property of Barbara E. Trindellocated at 470 McCulloch Road, Shippensburg, 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 name defendant, to wit: Barbara E. Trindel, by regular mail to her last known address of 47 McCulloch Road, Shippensburg, P A 17257. This letter was mailed under the date of October 06, 2004 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 March 02, 2005 at 10:00 o'clock A.M. He sold the same for the sum of $174,900.00 to Ann Gatchell for Central Penn Property Services, Inc. It bein the highest bid and best price received for the same, Central Penn Property Services, Inc. f 100 South 7th Street, Akron, PA 17501, being the buyer in this execution, paid to Sh iff R. Thomas Kline the sum of $182,302.00. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 3498.00 15.00 15.00 30.00 10.00 .50 1.00 29.60 Levy Postpone Sale Surcharge Posting Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 15.00 20.00 20.00 6.00 544.40 444.04 30.42 25.00 39.50 $ 4773.46 Sworn and subscribed to before me So Answers: This~dayof ~ r~ ~. #~ R- Thom~. Kline, Sher1ff.~ ~ 2005, A.D. - ~ j' r' .,', Prothonotary ~'fW I, O~'JYYUth Real Esta eputy UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLA NTIFF Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 NO. 04-1713 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Citifinancial Services, Inc., Plaintiff in the above attorney, Mark J. Udren, ESQ., sets forth as of Praecipe for the Writ of Execution was filed information concerning the real property located at: Road, (Southampton Twp) Shippensburg, PA 17257 action, y its the dat the the fol owing 470 McC lloch 1. Name and address of Owner(s) or reputed Owner(s): Name Address Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a None 4. Name and address of the last recorded holder of every mo gage of record: Name Address Plaintiff herein. See Caption above. Pennsylvania Housing Finance Agency 2101 North Front Street P.O. Box 15530 Harrisburg, PA 17105-5530 . . . 5. Name and address of every other person who has any reeor lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any in the property and whose interest may be affected cord the Address Real Estate Tax Department 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 470 McCulloch Road (Southampton Twp) Shippensburg, PA 17257 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 sub'ect to the penalties of 18 Pa.C.S. sec. 4904 relating to uns orn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: July 30, 2004 f ; . ATTORNEY FOR ?~A NTIFF . 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 Citifinancial Services, Inc. 7467 New Ridge Road Suite 222 Hanover, MD 21076 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 NO. 04-1713 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara E. Trindel 470 McCulloch Road Shippensburg, PA 17257 Your house (real estate) at 470 McCulloch Road, (Southampton Shippensburg, PA 17257 is scheduled to be sold at the Sher Sale on December 8, 2004, at 10:00 AM in the Commissioners He Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the judgment of $274,085.14, obtained by Plaintiff above mortgagee) against you. If the sale is postponed, the pro 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: T~) ff's ring ourt (the erty 1. The sale wil1 be cancel1ed if you pay to the mortgagee the back pa ent, late charges, costs and reasonable attorney's fees. To find out ho much you must pay, you may cal1: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Cou t 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 proceedin s. You may need an attorney to assert your rights. The sooner you co tact one, the more chance you will have of stopping the sale. (See noti e on page two on how to obtain an attorney.) , ) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. . THER 1. If the Sheriff's Sale is not stopped, your property will be s Id to the highest bidder. You may find out the price bid by calling 856-669-5 00. 2. You may be able to petition the Court to set aside the sale f the bid price was grossly inadequate compared to the value of your property. 3. amount due 5400. The sale will go through only if the buyer pays the Sheriff th full in the sale. To find out if this has happened, you may call 85 -669- 4. If the amount due from the Buyer is not paid to the Sheriff, y remain the owner of the property as if the sale never happened. S. You have the right to remain in the property until due is paid to the Sheriff and the Sheriff gives a deed to the time, the buyer may bring legal proceedings to evict you. the full buyer. A 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 w 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. will mount that your filed will this ) are on is 7. You may also have other rights and defenses, or ways of getti 9 your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FI 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 WYER O~ . ALL that c:eJ:tain tract:. of land lying an.d. being situate in Southampton I'Olrnship Cumberland County, Pennsylvania~ being Lot No. 12 ona Subdivision Plan Qf Edward G. Newswanger and H T Properties, prepar.td hy John R. Kissinger, dated June 9, 1992, said plan being .re.corded in t.he Office of the Record-er of De.eds of Cumberland County in Plan Book 66, at Page 35. more fully bounded and described ae follor.rs: BEGINNING a.t an ex.:f.sting railroad spiklll:: in l.egiglative Route i121006. known as McCulloch Road, at the. corn~r of Lot No. 11 on the hereinbefQre"'descr1.be;d Subdivision Pl.an; thence in said roadway, North fifty-four (.54) degrees a;lx (06) minue.. thirty (30) seconds E..t, one hundred thirty-six snd ten-hundredths (l36~lO) feet 'to .a railroad spike at the corner of Lot ~o. 13 on the ~fores8id Subdivision Plan; thence along said Lot No. 13, South thirty-nine (39) degr&es foUl: (04) minute.s one (01) second East. four hundrltd thirty-four aud one: one-h':Ifidredth (434..01) feet to ~m iron pin; the:nee .along said Lot No,. 13, North fifty-five. (55) de.greelil =ero (00) minutes fotty-tvo (42) seconds East, one hundred and, t.wenty-three hundredths (100.23) ffAet to an e.xisting iron pin at landEi now oX' formerly of Ed.ward G. Ne.wswa.nger; thence .!J,long said lands nQw or forme~ly of New~wanger. South thirty-nine ~39) degre~& four (04) minutes thirty-five (35) second!:: East, five hundred f~fty-s1x and seveI],t(!en-hundredthe (556.17) feet to an iron pin at the edge of 3 proposed eifty (50) foot private right-of-way knOW1 a. Nkluotaln Drive; thence along said proposed fi fty (SO) foot private right-of-way, South fi fty (SO) degrees fl fty-sevlltl (57) minute. zero (OOl second. IVe.t. two hundred forty-seven and fi ft.en-tLIndredths (2Q7.15) feet to .n iron pin; U)ence aiong said proposed fj'fty (SO) foot private right-of-way, along a curve to the right designated as CUrve "C', having a chord bearing of North eighty-four (SQ) degrees three (03) minutes zero (00) seconds West, one hundred seventy-.lx and seventy-eight rundredths (176.78) feet, a radius of one hundred twenty-five and zero-hundredth. (125.00] feet. and an arc length of one hundred ninety-six and thirty-five hundredths (196.35) feet to a i ran pin; thence along said proposed fi fty (SO) foot private rlght-of.......y. North thirty-nine (39J degrees three (03) minute. zerO (00) second. West. four hundred fifty-.even and fifty-eight hundredths (~57.5S) feet to an iran pin at the comer of Lot No. 11 on U)e aforesaid Subdivl.ion Plan; thence along .ald Lot No. 11, North fifty-five (55) degrees zero (00) minutes forty-two (q2) seconds East, one hundred thirty-six and twenty-nine hundredths (136.29) feet to an iron pin; thence .Iong said lot No. II, North thirty-nine (39) degrees thrae (03) minute. twenty-sav.n (27) second. West. four hundred thirty-one .nd eighty-.lx hundredths (Q31.B6) feet to a railroad spike in Leg'lslat!ve Route 21006, l<n""" as WcCUlloch Ro.d, the place of BB:aN'lIN::l. CXNrAININ::l 6.1ij acres pursuant to the aforesaid Subdivision Plan. . . f-wa from the centerline of SUlJECr 10 a twenty-five (25) foot dedicated rt9ht~o SubdiVision PI.n. legislative Route #21006. as shown on the afore..' t 'I, BEING KNOWN AS: 470 MCCULLOCH ROAD, (SOUTHAMPTON TWP) SHIPPENSBURG, PA 17257 PROPERTY ID NO. : 39-15-0177-048 TITLE TO SAID PREMISES IS VESTED IN BARBARA E. TRINDEL BY DEE H T PROPERTIES, A PARTNERSHIP COMPOSED OF J. MICHAEL HILL, J HILL, DONALD E. THRUSH, AND LANE I. THRUSH DATED 07/22/93 RE 05/03/94 IN DEED BOOK 104 PAGE 998. FROM ES R. RDED WRIT OF EXECUTION and/or ATTACHMENT < COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-1713 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC. Plaintiff(s) From BARBARA E. TRINDEL, 470 MCCULLOCH ROAD, SHIPPENSBURG P A 17257. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 470 MCCULLOCH RORAD, SOUTHAMPTON TWP., SHIPPENSBUR PA 17257 (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 defenda t (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as garnishee and is enjoined as above stated. Amount Due $274,085.14 L.L. $.50 Interest FROM 7/31/04 TO 12/8/04 @ $57.63 per diem = $7,549.53 Atty's Comm % Due Prothy $1.00 Ally Paid $181!?5 Other Costs Plaintiff Paid Date: AUGUST 3, 2004 (Seal) CURTIS R. LONG '],0,"''' ~( Q ~ By: ,.~ ~ YJ1fvv Deputy REQUESTING PARTY: Name MARK J. UDREN,ESQ. Address: 111 WOODCREST RD., STE 200 WOODCRESTCORPORATECENTER CHERRY HILL NJ 08003-3620 Attorney for: PLAINTIFF Telephone: (856) 669-5400 Supreme Court ID No. 04302 Real Estate Sale #24 On August 27,2004 the Sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, P A Known and numbered as 470 McCulloch Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 27,2004 By: J6~I.AM .l-L Real Est~~u't;r l .:",SNH3d '1'('\ , .,1 ~ r 30f! . '..:, .c' Alhl ;/;/ib::H , dJU ~ ~ ~ . ',j/ .... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing nnder the I ws of the Connnonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Str et, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, n the City, County and State aforesaid; that The Patriot-News and The Snnday Patriot-News were established Ma ch 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and pu lished in their regular daily andlor Sunday/ Metro editions which appeared on the 19th and 26th day(s) of October nd the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said rinted notice or advertising, and that all of the allegations of this statement as to the time, place and character of pu lication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to ver fy 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 Connty of Dauphin in Miscellaneous Book 'M", Volume 14, Page 317. COPY SALE#24 Sworn NOTARIAl Terry l. Russell, Nola II Oly of Harrisburg, Dau n My Commission Expires June 6, Y PUBLIC M.mb", P.nn'Ylv.nl'As80~~Brnwa~~n expires June 6, 2006 /" PUBLICATION 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 444.04 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Snnday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the sam have been duly paid. By.......................................................... ......... REAL ESTATE SALE No. 24 Writ No. 2004-1713 ClvIlllInn Cltlflnanclal Servlces,lnc. Va Bsrb8ra E. Trlndel Ally: Mark Udren DESCRIPTION ALL TWJ CEKfAIN tract of land lying and being si_ ini SonillampIon Township, CIIlIIberlaod O>ooty, Peoosylwoia, being Lot No. 12 on a Subdivision Plan of Edward G. News_ and /I. T. Properties, prepan:d by JoboR.Kissio&<r,datedhme8.I992,saidplao being recmded in !be 0lIice of !be Recorder of Deeda of CIIlIIberlaod O>ooty in Plan Book 66, at Page 55, mme fully bnooded and described " follows: BEGlNNING at an existing nliIrood apikil in Legislative RaDle 1121006, known " McColloch Road, at the oomer of Lot No. 11 on the _.deaaibed Subdirnioo Plan; lbeoc<: in said roadway, Nordlfifty-four (541 de-grees six (116) miootea lhirty (30) secooda East, one Inmdred lhirty-aix and teo-h_ (136.10) foltlD anliIroodapikil at the comernfLot No. 13 OIl doe af....,;d Subdivision Phm: thence along uid Lot No. 13, Sooth lhirty.nioe (39) degroea four (04) miootea one (01) second Eas, four IluDlked thirty-four and one one ~ (434.01) feet to an iVo pin; thence along said Lot No. 13, Nordl fifty-five (55) deg<ees zero (00) miD"es forty-two (42) secooda East,.one hundred and tweuty-<hree _ (10013) feet to au existing iron pin at laMs now or fntmmly of Edward G. Newswanger; thence along said Iaods now or formerly of Newswmger, South dlirty- nine (39) degroea four (04) miootea lhirty-five (35) seconds Eas, five bundred fifty-six and seveoteeI>-JomdredIbs (556.17) f..tto an iron pin at the edge of a JlIOIlO"d fifty (50) foot private right-of~way known as Mountain Drive; thence along said JlIOIlO"d fifty (SO) foot pi"'" ri8ht- of-way, Soo1h fifty (SO) degroea fifty-seven (57) miootea zero (00) seconds Wes, two hundred forty.seven and fifteOn_(247.15) feet to au iron pin; thence along said JlIOIlO"dfifty (SO) foot private ri&ht-of-way. along a curve to the right desilnared " Curve "C", having . choro bearing 01 North~.. -four (84) degroea three (03) miooles .... ( :loonds West, one Inmdred seventy-aixand' <ighth_(176.78) feet, a radius of one hundred twenty-five and zero hundredths (125.00) feet. and au arc Ieogth of one Inmdred oioety-six 'and lhirty-five hundredths (196.35) feet to an iron pin; thence alon8 said proposed fifty (SO) foot pri"" right-of.way, North lhirty-nioe (39) degrees three (03) min-otes zero (00) seconds Wes, foor Inmdred fifty-seven and fifty-eigbt_ (457.58) feet to an iron pin at !be oomer of Lot No. II on !be afmesnid Sobdivixion Plan; thence aJnog said Lot No. Il, North fifty-five (55) degroea .... (00) miootes funy-IWo (42) seconds East, one Inmdred lhirty- six and twenty-nine hnodredtha (136.29) feet to au iron pin; thence along said Lot No. Il, Nordl lhirty-nioe (39) degroea three (OJ) mioules twenty-seven (2'7) seconds West, four Inmdred lhirty.... and.eiptY-aixhnodredtha(43J.86)feet to a nliIrood .pike in l.egislaIive Route 21006. knowoaaMtCnllochllood,theplaceof _'~ - "OtmJ..IG' "M--.- flIII!Il!t............ ........ -=rTO.~(2S)font_ ......... loa .. ......" ~ .. f'ZltllI6, as' _ on the a!Qaoid SaWvision PIao BI!IIIG KNOWN AS; 470 McColloch load (SoothamplDn Twp.), SVnsbJrg, PA 17257. PROPI!I1fY ID f39-15-0177-{)48. TITLE TO SAID -"" is vested in Barbara E. Triodel by Deed from H T Properties, . _ compoaed of J. MidJael Hill. J""" it Hill. DonahI E. 11o:ooIl. and Lane 1. 1brosb datedOOf1ll93 recmded IllI03I94 in Deed Book 104 Page 998. . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the Count and State aforesaid, being duly sworn, according to law, deposes and says that the Cumber1an Law Journal, a legal periodical published in the Borough ofCarIisle in the County and State afi resaid, 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 reg larIy issued weekly in the said County, and that the printed notice or publication attached heret IS exactly the same as was printed in the regular editions and issues ofthe said Cumberland aw Journal on the following dates, VIZ: OCTOBER 8,15,22,2004 Affiant further deposes that he is authorized to verify this statement by the Cumber and Law Journal, a legal periodical of general circulation, and that he is not interested in the su ject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chs 'acter of publication are true. S RN TO AND SUBSCRIBED before me t is 22 day of OCTOBER 2004 NO SEAL LOIS E. SNYDER, Notary Public Carlisle Bora, Cumberland County My CommissiOfl Expires March 5, 2005 REAL ESTATE SALE NO. 24 Writ No. 2004-1713 CM] Citifinancial Services. Inc. vs. Barbara E. Trindel Atty.: Mark Udren ALL that certain tract of land ly- ing and being situate in Southamp- ton Township, Cumberland County. Pennsylvania. being Lot No. 12 on a Subdivision Plan of Edward G. Newswanger and H T Properties, prepared by John R. Kissinger, dated June 9. 1992, said plan be- ing recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66. at Page 55. more fully bounded and desCJibed as follows: BEGINNING at an existing rail- road spike in Legislative Route #21006, known as McCulloch Road. at the comer of Lot No. lIon the hereinbefore-described Subdivision Plan; thence in said roadway, North fifty-four (54) degrees six (06) min- utes thirty (30} seconds East. one hundred thirty-six and ten-hun- dredths (136.10) feet to a railroad spike at the comer of Lot No. 13 on the aforesaid Subdivision Plan; thence along said Lot No. 13. South thirty-nine (39) degrees four (04) minutes one (01) second East, four hundred thirty-four and one one- hundredth (434.01) feet to an iron pin; thence along said Lot No. 13. North fifty-five (55) degrees zero (00) minutes forty-two (42) seconds East. one hundred and twenty-three hundredths (100.23) feet to an ex- isting iron pin at lands now or for- merly of Edward G. Newswanger; thence along said lands now or for- merly of Newswanger. South thirty- nine (39) degrees four (04) minutes thirty-five (35) seconds East. five hundred fifty-six and seventeen- hundredths (556.17) feet to an iron pin at the edge of a proposed fifty (50) foot private right-of-'WaY known as Mountain Drive; thence along said proposed fifty (50) foot private right-of-way. South fifty (50) degrees fifty-seven (57) minutes zero (DO) seconds West, two hundred forty- seven and fifteen-hundredths (247- .I .15) feet to an iron pin; thence along said proposed fifty [50) foot private right-of-way. along a curve to the right designated as Curve "eM. hav- ing a chord bearing of North eighty- four (84) degrees three (03) minutes zero (00) seconds West. one hun- dred seventy-six and seventy-eight hundredths (176.78) feet, a radius of one hundred twenty-five and zero-hundredths (125.00) feet. and an arc length of one hundred ninety- six and thirty-five hundredths (196.35) feet to an iron pin; thence along said proposed fifty (50) foot private right-of-way, North thirty- nine (39) degrees three (03) minutes zero (00) seconds West. four hun- dred fifty-seven and fifty-eight hun- dredths {457.58) feet to an iron pin at the comer of Lot No. lIon the aforesaid Subdivision Plan; thence along said Lot No. 11. North fifty- five (55) degrees zero (00) minutes forty-two (42j seconds East. one hundred thirty-six and twenty-nine hundredths (136.29) feet to an iron pin; thence along said Lot No. 11. North thirty-nine (39) degrees three (03) minutes twenty-seven (27) sec- onds West. four hundred thirty-one and eighty-six hundredths (431.86) feet to a railroad spike in Legisla- tive Route 21006. known as McCul- loch Road. the place of BEGINNING. CONTAINING 6.14 acres pursuant to the aforesaid Subdivision Plan. SUBJECT TO a twenty-flve (25) foot dedicated right-of~way from the centerline of Legislative Route #21006. as shown on the aforesaid Subdivision Plan. BEING KNOWN AS: 470 McCul- loch Road. (Southampton Twp) Ship- pensburg. PA 17257. PROPERTY ID NO.: 39-15-0177- 048. TITLE TO SAlD PREMISES IS VESTED IN Barbara E. Trinde] by deed from H T Properties, a part- nership composed of J. Michael HilI. James R. Hill. Donald E. Thrush. and Lane 1. Thrush dated 07/22/93 recorded 05/03/94 in Deed Book 104 Page 998.