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Home My WebLink About01-6844MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 c/o Moss, Codilis Stawiarski, Morris, Schneider, & Prior, LLP P.O. Box 24737 West Palm Beach, FL 33416-4737 : Plaintiff ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS i CIVIL DIVISION o Cumberland County Vo Kenneth R. Steiner Sun Cha Steiner [NO. 0t~-' ll04 Floribunda Ln. : Mechanicsburg, PA 17055 Defendant(s) 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 OR CARNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 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. Mace falta ascentar una comparencia escrita o en persona o con un abo~ado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UNABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PA~AR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERI~UAR DONDE SE PUEDE CONSE~UIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. 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. LAW OFFICES OF MARK J. UDREN Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill: NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Ameriquest Mortgage Company Assignee: First Union National Bank, As Trustee For Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BCl Recording Date: 3/9/01 Book: 688 Page: 845 Assignor: First Union National Bank, As Trustee For Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Assignee: Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Recording Date: Lodged For Recording 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 1104 Floribunda Ln MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Upper Allen COUNTY: Cumberland DATE EXECUTED: 6/25/98 DATE RECORDED: 7/9/98 BOOK: 1467 PAGE: 44 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/2/01: Principal of debt due and unpaid Interest at 10.75% from 4/01/01 to 11/02/01 (the per diem interest accruing on this debt is $28.45 and that sum should be added each day after 11/02/01) Title Report $96,386.53 6,313.09 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $391.59 and that sum should be added on the first of each month after 11/02/01) 391.59 Late Charges (monthly late charge of $65.33 should be added on the fifteenth of each month after 11/02/01) 184.65 Prepayment Penalty Fees Billed Payoff Quote Fee Satisfaction Fee 4,478.31 134.69 10.00 48.00 Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $113,296.19 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. W~EREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $113,296.19 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren,~ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF ERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHEEN LINE OF FLORIBUNDA LANE (50 FEET WIDE) WHICH SAID POINT IS IN THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE NORTHEP. N LINE OF FLORIBUNDA LANE IN AN EASTWARDLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE RIGHT, SAID CIRCLE HAVING A I~DIUS OF 200 FEET, THE ARC DISTANCE OF 34.91 FEET TO A POINT MARKED BY A MONUMENT; THENCE CONTINUING ALONG THE NORTHERN LINE OF FLORIBUNDA LANE, SOUTH 74 DEGREES 25 MINUTES 33 SECONDS EAST 35.75 FEET TO A POINT AT CORNER OF LOT NO. 19 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 19 AND 20 ON SAID PLAN, NORTH 15 DEGREES 34 MInuTES 27 SECONDS EAST 131.18 FEET TO A POINT AT CORNER OF LOT NO. 15 ON THE HEREINAFTER MENTIONED PLA/~ OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 15 AND LOTS NOS. 20 AND 14 ON SAID PLAN, NORTH 77 DEGREES 09 MINUTES 21 SECONDS NEST 100.0 FEET TO A POINT AT CORNER OF LOT NO. 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON SAID PLAN, SOUTH 02 DEGREES 46 MINUTES 37 SECONDS WEST 132.76 FEET TO A POINT IN THE NORTHERN LINE OF FLORIBUNDA LANE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 20, BLOCK "B" ON THE PLAN OF SECTION i OF ROSEGAP. DEN, WHICH SAID PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECO~.DER'S OFFICE IN PLAN BOOK 27, PAGE 16. HAVING THEREON ERECTED AN ALUMINUM AND BEICK COLONIAL BI-LEVEL HOUSE WITH TWO-CAR GARAGE. OCWEN October 01, 2001 *0000717779* Kenneth R. Steiner 1104 Flori Bnnda Lane Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see ifHEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired heating can call 717-780-1869). La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamandoesta .... aganc~a (Peunsylvan~a Honsmg Finance Agency) sin cargos al numero mencionado ardba. Puedes ser elegible para un pl'estamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT CURRENT SERVICER Kenneth R. Steiner 1104 Flori Bunda Lane Mechanicsburg, PA 17055-0000. 30580120 Ocwen Federal Bank FSB You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, 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. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days fi'om the date ofthln Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies lisLed at the end of this Notice. Thi~ meeting must occur~vithin the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Page two 30580120 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the fight to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. 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 you application. During that additional 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 Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILIN~OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE 1S 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 CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 1104 Flori Bunda Lane Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following mounts are now past due: (a) 5 Payments (b) Late charge(s): (c) Other charge(s): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 09/29/2001: $6,311.54 $123.10 $130.40 $.00 $6,565.04 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $6,565.04, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 30580120 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exemise its rieht to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full pasmaent of the amount of default is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged property Will be sold by the Sheriffto pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period, you will not be required to pay attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total mount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fred out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number: (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriff's sale, a lawsuit to remove you and your furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT To sell the property to obtain money to pay offthe mortgage debt, or borrower 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. (However, you are not entitled to this right more than three times in a 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. Pager our 30580120 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writing at the below~address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Ocwen Federal Bank FSB, P.O. Box 24737, West Palm Beach, FL 33416 Phone (800} 746-2936 OCWEN October 01, 2001 *0000717780* Sun Cha Steiner I 104 Flori Bunda Ln Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose, about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR Specific information The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see ifHEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of thi~ Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing can call 71%780-1869). La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando es~a agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes set elegible para un p~estamo pot el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): Sun Cha Steiner PROPERTY ADDRESS: 1104 Flori Bunda Lane Mechanicsburg, PA 17055-0000 LOAN ACCOUNT 30580120 CURRENT SERVICER Ocwen Federal Bank FSB You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, 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. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notipe.x This meeting must occur within the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Page two 30580120 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the fight to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. 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 you application. During that additional 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 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 SHOULI~ 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 CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 1104 Flori Bunda Lane Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) 5 Payments (b) Late charge(s): (c) Other charge(s): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 09/29/2001: $6,311.54 $123.10 $130.40 $.00 $6,565.04 · YOU HAVE FAILED TO TAKE THE FOLLOWTNG ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOLrNT PAST DUE TO LENDER, WHICH IS $6,565.04, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 30580120 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of&fault is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged property will be sold by the Sheriffto pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period, you will not be required to pay attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is ~stimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months fi.om 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 CONTACT THE LENDER Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number: (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriff's sale will e/~d 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale ~/nd that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT To sell the property to obtain money to pay off the mortgage debt, or borrower money fi.om another lending institution to pay offthis 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. (However, you are not entitled to this right more than three times in a 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. Pager our 30580120 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writing at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Oewen Federal Bank FSB, P.O, Box 24737, West Palm Beach, FL 33416 Phone (800) 746-2936 VERIFICATION 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 4904 relating to unsworn falsification to Pa.C.S. Section authorities. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY I-IILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil 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 service of the Complaint in Mortgage Foreclosure upon Defendant(s), Kenneth R. Steiner and Sun Cha Steiner by regular mail and certified mail 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 1104 Floribunda Lane, Mechanicsburg, PA 17055, 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 attached 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), Kenneth R. Steiner and Sun Cha Steiner. MARK J. UDREN & ASSOCIATES By' '"'~'Udr~en, E Mirk J. squire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil Kenneth R. Steiner : Sun Cha Steiner : Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable nde 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. ~, 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. AdogtiOlLOL3~alk~, 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 A, 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. MARK J. UDREN & ASSOCIATES By: ~ Mar squire Attorney for Plaintiff SHERIFF'S RETURN CASE NO: 2001-06844 P COMMONWEALTH OF PENNSYLV~2qIA COUNTY OF CUMBERLAND - NOT FOUND BANK ONE NA VS STEINER KENNETH R ET AL R. Thomas Kline duly sworn according to law, says, that inquiry for the within named defendant, STEINER KENNETH R ,Sheriff or Deputy Sheriff, who being he made a diligent search and DEFENDANT but was unable to locate Him in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the the within named DEFENDANT , NOT FOUND , as to , STEINER KENNETH R PER NEIGHBOR, THEY HAVE NOT LIVED THERE FOR 3 MONT BUT THEY COME AND PICK UP THE MAIL ONCE PER WEEK. Sheriff's Costs: Docketing 18.00 Service 6.50 Not Found 5.00 Surcharge 10.00 .00 39.50 So ans~s~' Rz' Thomas Kline Sheriff of Cumberland County MARK UDREN 12/20/2001 Sworn and subscribed to before me this day of A.D. Prothonotary XHIB TA SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-06844 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK ONE NA VS STEINER KENNETH R ET~AL R. Thomas Kline duly sworn according to law, inquiry for the within named ~efendant, STEINER SUN CHA ,Sheriff or Deputy Sheriff, says, that he made a diligent DEFENDANT unable to locate Her in his bailiwick. COMPLAINT - MORT FORE , He therefore who being search and but was returns the , NOT FOUND , as to the within named DEFENDANT , STEINER SUN CHA PER NEIGHBOR, HAS NOT LIVED THERE FOR 3 MONTHS. THEY PICK UP THE MAIL THERE ONCE PER WEEK. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 R. Th6m&s K~l~e~ Sheriff of cumberland County MARK UDREN 12/20/2001 Sworn and subscribed to before me this day of A.D. Prothonotary EXHIBITA PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 0129008 Attorney Firm: MARK J UDREN & A~SOCIATES Case Number: SubJeCt: KENNETH R & SUN CHA STEINER A.K A KENNETH STEINER, BUNCHA BTEINER Last Known Address: 1t04 FLORIBUNDA LANE MECHANICgBURG, PA 17055 Last Know~ Number ( ) Michael K Gross, being duly sworn ar. con:ling to law, deposes and says I I am employed in the capacity Of President for Players National Locator. 2. On 111'1212001, I conducted an investigation into the whereabouts of the above named defendant(s) The results of my investigation ere as follows: CREDIT INFORMATION - A SOCIAL SECURITY NUMBER' 19t-40.8121 2t34)4-1288 B EMPLOYMENT SEARCH; Unable to locate a good employer for Kenneth and Sun. C INQUIRYOF CREDITORS: Credltoru Indicated that Kenneth and Sun ere using 1104 Flodbunda Lane, Mechanlceburg, Pa. t?0S5 with no valid home phone number. Kenneth filed chapter 7 bankruptcy In June 2001 with attorney Jamee M Bach. Cass ti 0t4)3395 with a release date of October 2001. INQUIRY' OF TELEPHONE COMPANY - A DIRECTORY ASSISTANCE SEARCH: DireCtory aaststance has no II~ttng for Kenneth and Butt Stolner, INQUIRY OF NEIGHBORS - We contacted 717-7U-1481 registered at 110S FIoHhunda Lane and spoke with a neighbor who stated he thinks Kenneth and Sun 8talner hsve moved from the last known eddteas and did not have e forwarding eddreas, INQUIRY OF POST OFFICE - A NATIONAL ADDRESS UPDATE, A~ of November 10, 2001 the National Change of Add~ (NCOA) has no change for Kenneth and Sun from the last known address. MOTOR VEHICLE REGISTRATION - A MOTOR VEHICLE & DMV OFFICE. The Pennsylvania Depmtmsnt of Drlvem Llcaaslng has Kenneth and Bun listed at the last known addras~. OTHER INQUIRIES- A DEATH RECORDS- As of November t0, 2001 the Social Security Administration has no death recon~s on file for Kenneth R and Sun Cha Steiner and or a.k.a.'~ under their social security numbers. EXHIBIT IIL=~ 60/PO'd 916=L 89900EZ$;9 KOI£VIOO$$V $~;A¥qd-mOi~ adO0:lO IO=l~=OeO B. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC ): None Found C. COUNTY VOTER REGISTRATION: The Cumberland County Votem Registration Office has Kenneth and Sun listed at the last known. ADDITIONAL INFORMATION ON SUBJECT - A, DATE OF BIRTH: KennMtl 07148 Sun 011/45 AFFIA ichael K Gross Sub: ~/ecl an~ st~orn to be,for~me/~n 12/31//~0, Ple~rs Ne~onel L~a~r ~ f3 Old Sta~ Road, Sui~ 104 St. Lou~s, MO 63021 Phone' (636) 23~9922 Fa~: (636) 23~558 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 4904 relating to unswom falsification to authorities. MARK J. UDREN & ASSOCIATES M~, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION i Cumberland County 2 : · NO. 01-6844 Civil .- .- -. CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served tree 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: Kenneth R. Steiner and Sun Cha Steiner 1104 Floribunda Lane Mecbanicsburg, PA 17055 MARK J. UDREN & ASSOCIATES Mar Esquire Attorney for Plaintiff SHERIFF'S RETURN CASE NO: 2001-06844 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND BANK ONE NA VS STEINER KENNETH R ET AL Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named ~efendant, DEFENDANT STEINER SUN CHA ,Sheriff or Deputy Sheriff, who being search and but was unable to locate Her in his bailiwick. COMPLAINT - MORT FORE He therefore returns the the within named DEFENDANT , STEINER SUN CHA , NOT FOUND as to PER NEIGHBOR, HAS NOT LIVED THERE FOR 3 MONTHS. THEY PICK UP THE MAIL THERE ONCE PER WEEK. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sheriff of Cumberland County MARK UDREN 12/20/2001 Sworn and subscribed to before me this ? ~ day of~ ~.~ A.D. Pro~hfDno~ary ' ~ SHERIFF'S RETURN CASE NO: 2001-06844 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND BANK ONE NA VS STEINER KENNETH R ET AL Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named defendant, DEFENDANT STEINER KENNETH R unable to locate Him COMPLAINT - MORT FORE ,Sheriff or Deputy Sheriff, who being search and in his bailiwick. He therefore returns but was the the within named DEFENDANT , NOT FOUND , as to , STEINER KENNETH R PER NEIGHBOR, THEY HAVE NOT LIVED THERE FOR 3 MONT BUT THEY COME AND PICK UP THE MAIL ONCE PER WEEK. Sheriff's Costs: Docketing 18.00 Service 6.50 Not Found 5.00 Surcharge 10.00 .00 39.50 So answ~e~rsY: ~ ~' R/ Thomas Kline Sheriff of Cumberland County MARK UDREN 12/20/2001 Sworn and subscribed to before me this '7~ day of ~ ~ 0-o D~ A.D. Pro~h6not ary t · ,.lAN 0 8 230 MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION ! Cumberland County .- · NO. 01-6844 Civil Kenneth R. Steiner : Sun Cha Steiner : Defendant(s) -. AND NOW, this 16,' day of C/a.., ,,~-~ ,200 ~- , upon consideration of PlaintiWs Motion and the 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), Kenneth R. Steiner and Sun Cha Steiner, shall be complete when Plaintiff or its counsel or agent has mailed true and cctrrect 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), Kenneth R. Steiner and Sun Cha Steiner at 1104 Floribunda Lane, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 1104 Floribunda Lane, Mechanicsburg, PA 17055. BY THE COURT: MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil PRAECIPE TO REIN~TAT~ TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: January 22, 2002 ATTORNEY FOR PLAINTIFF ESQUIRE MARK J. UDREN & ASSOCIATES BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATFORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County .- i NO. 01-6844 Civil .- .- . .- VERIFICATION OF SERVICE BY CERTIFIED MAII. AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaimiff in the above case and that pursuant to the Court order issued in this matter he mailed a tree 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: DATE MAILED: Kenneth R. Steiner and Sun Cha Steiner 1104 Floribunda Lane Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: MARK J. UDREN & ASSOCIATES Mark J. U~:~n,'Esquire Attorney for Plaintiff SHERIFF' S RETURN CASE NO: 2001-06844 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NA VS STEINER KENNETH R ET AL - REGULAR BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINER KENNETH R AND STEINER SUN CHA the DEFENDANT , at 0935:00 HOURS, at 1104 FLORI BUNDA LANE MECHANICSBURG, PA 17055 POSTED PROPERTY AT 1104 on the 30th day of January , 2002 by handing to FLORIBUNDA LANE MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Posting 6.00 Surcharge 10.00 .00 40.90 Sworn and Subscribed to before me this ~/~ day of / I ProEhonotary So Answers: R. Thomas Kline 01/31/2002 MARK UDREN By: Deput~herif fv MA~K J. UDREN & ASSOCIATES BY= Mark J. Udren a Associates, ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 Plaintiff Esquire ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-684.4 Civil Kenneth R. Steiner Sun Cha Steiner Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: March 5, 2002 y& ASSOCIATES BM~k~J. ~dren ~&~Associates, Attorney for Plaintiff Esquire ~E R I F I CAT I ON The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer Corporation which is the servicing agent of Plaintiff, authorized to make this verification on behalf of the of the and being Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that subject to the penalties of 18 Pa. C.S. unsworn falsification to authorities. this statement is made Section 4904 relating to Date: MAR/( J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 De f endant ( s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil 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 Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: March 18, 2002 Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 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: March 21, 2002 MARK J. UDREN & ASSOCIATES Mark J. Udren & Associates, Esquire (3 0 luoseJd pue ldBeoeJ s?q~ OAeS :IN¥/liOdlAI :sop!AoJd I!ekq PoII!PoO 0 · ~zm0 F~ ~ I Rmum Reoept Fee OFFICIAL US S!QI OAgS :lNVJ. l'lOdiAII Ile&M PoIJ!:I,IO0 JAN 0 L, J. UDREN & ASSOCIATES ~y: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/Fda The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION ~ Cumberland County : ' NO. 01-6844 Civil . .- : .- ORDER AND NOW, this I L~ day of ~ 0.~IAO-~_~ , 200;l , upon consideration of Plaintiff's Motion and the 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), Kenneth R. Steiner and Sun Cha Steiner, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copras of the Complaint in Mortgage Foreclosure and all subsequent pleadings by Certified mail ai~d regular mail to the last known address of Defendant(s), Kenneth R. Steiner and Sun Cha Steiner at 1104 Floribunda Lane, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 1104 Floribunda Lane, Mechanicsburg, PA 17055. BY THE COURT: MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION · Cumberland County : MORTGAGE FORECLOSURE ;NO. 01-6844 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/3/01 to 3/5/02 Late charges per Complaint From 11/3/01 to 3/5/02 Escrow payment per Complaint From 11/3/01 to 3/5/02 TOTAL $113,296.19 3,499.35 261.32 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. ~& ASSOCIATES ~ M~r~ J. U~ren~& AssOciates, ESQUIRE ~ ~ttorney for P~.~ntiff DAMAGES ARE HEREBY ASSESS~-~S INE~ICATED _ /~ ' - '~ ~ ~ PRO PROTHY - - v ~ _~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINaS HIaHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 BankOn. National Association, As Trusteeef/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Co.rporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Ve Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTOI~NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil DATED: TO: February 22, 2002 Kenneth R. Steiner 1104 Floribunda Lane Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENTMAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PurPOSE. ~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHE~RY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil DATED: TO: February 22, 2002 Sun Cha Steiner 1104 Floribunda Lane Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU RAVE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANT~ USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY= Mark J. Udren a Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-6844 Civil AFFIDAVIT OF NON-MILITARY SERVICE StArE OF C0 ¥ OF : SS : Defendant: Sun Cha Steiner Age: Over 18 Residence: As captioned abo~e Employment: Unknown -~/~~/~ Name: Sworn to and subseri~ C~~"~ o~~ , 2 0 ~ ~,~m ~.~o. Defendant: Age: Residence: Employment: Kenneth R. Steiner Over 18 As captioned above Unknown 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: .HARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, Esquire ATTY I.D. NO. 0%302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION -Cumberland County i MORTGAGE FORECLOSURE :NO. 01-6844 C±vil TO: Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 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. Judgment by Default ~a~. ~ Money Judgment JUdgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren & Associates, Esquire At this telephone number: 856-482-6900 '~ARK J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION · Cumberland County i MORTGAGE FORECLOSURE 'NO. 01-6844 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per COmplaint From 11/3/01 to 3/5/02 Late charges per Complaint From 11/3/01 to 3/5/02 Escrow payment per Complaint From 11/3/01 to 3/5/02 TOTAL $113,296.19 3,499.3~ 261.32 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. .~~& ASSOCIATES ~ ~ar~ J. u~ren~& AssOciates, ESQUIRE DAMAGESAREHEREBYASSESSED~~AS~;~E~°rp~ntlff- .-, · 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm BeaCh Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant (s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS :CIVIL DIVISION -Cumberland County :MORTGAGE FORECLOSURE 'NO. 01-6844 Civil TO: Kenneth R. Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 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% X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren & Associates~ Esquire At this telephone number: 856-482-6900 Prothonotary_ -'MARK J. UDREN & ASSOCIATES BY= Mark J. Udren a Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 -856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County ! MORTGAGE FORECLOSURE : : :NO, 01-6844 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGE~ TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/3/01 to 3/5/02 Late charges per Complaint From 11/3/01 to 3/5/02 Escrow payment per Complaint From 11/3/01 to 3/5/02 TOTAL $113,296.19 3,499.3~ 261.32 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. & ASSOCIATES ~ ~r~ J. ~dren~& AssOciates, ESQUIRE ~ ~ttorney for P]~.~ntiff DAMAGES ARE HEREBY ASSESSED~ INDICATED /~ '' -- PRO PROTHY ..... ~ MARK J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS ~CIVIL DIVISION -Cumberland County i MORTGAGE FORECLOSURE 'NO. 01-6844 Civil PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter:' Amount due Interest From ~ to Date of Sale Per diem ~$28.45 (Costs to be added) Mark J. Udren & Associates, ESQUIRE ~ ATTORNEY FOR PLAINTIFF ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCHIBED AS FOLLOWS, TO WITs BEGINNING AT A POINT IN THE NORTHERN LINE OF FLORIBUNDA LANE (50 FEET WIDE) WHICH SAID POINT IS IN THE DIVISION LINE BETWEEN LOTS NOS? 20 A~D 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE NORTHERN LINE OF FLORIBUNDA LANE IN AN EASTWARDLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE RIGHT, SAID CIRCLE HAVING A RADIUS OF 200 FEET, THE ARC DISTANCE OF 34.91 FEET TO A POINT MARKED BY A MONI~MENT; THENCE CONTINUING ALONG THE NOHTHERN LINE OF FLOBIBUNDA LANE, SOUTH 74 DEGREES 25 MINUTES 33 SECONDS EAST 35.75 FEET TO A POINT AT CORNER OF LOT NO. 19 ON THE HEREINAFTEH MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 19 AND 20 ON SAID PLAN, NORTH 15 DEGREES 34 MINUTES 27 SECONDS EAST 131.18 FEET TO A POINT AT CORNER OF LOT NO. 15 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 15 AND LOTS NOS. 20 AND 14 ON SAID PLAN, NORTH 77 DEGHEES 09 MINUTES 21 SECONDS WEST 100.0 FEET TO A POINT AT CORNER OF LOT NO. 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON SAID PLAN, SOUTH 02 DEGREES 46 MINUTES 37 SECONDS WEST 132.76 FEET TO A POINT IN THE NORTHERN LINE OF FLOHIBUNDA LANE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 20, BLOCK "B" ON THE PLAN OF SECTION i OF ROSEGANDEN, WHICH SAID PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDEH'S OFFICE IN P~AN BOOK 27, PAGE 16. HAVING THEREON ERECTED AN ALUMINUM AND BEIC~ COLONIAL BI-LEVEL HOUSE WITH TWO-CAH GARAGE. BEING KNOWN AS 1104 FLORI BUNDA LANE, MECHANICSBURG, PA 17055 PROPERTY TAX PARCEL NO.: 42-31-2153-027 TITLE TO SAID PREMISES IS VESTED IN KENNETH R. STEINER AND SUN CHA STEINER, HIS WIFE, BY DEED FROM RICHARD A. WALKER, A SINGLE MAN, DATED 7/29/86, RECORDED 7/30/86, IN DEED BOOK B-32, PAGE 480. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren a Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSHRE : 'NO. 01-6844 CERTIFICATE Mark J. Udren & Associates, 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: ( ) ( ) ( ) (x) ( ) An FHA insured mortgage Non-owner occupied Vacant 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 & ASSOCIATES & Associates, ATTORNEY FO~,~ PLAINTIFF ESQUIRE MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage -MORTGAGE FORECLOSURE Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. : West Palm Beach, FL 33401 : Plaintiff : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) : 'NO. 01-6844 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1, Plaintiff in the above action, by its attorney, Mark J. Udren & Associates, 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: 1104 Flori Bunda Ln, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Kenneth R. Steiner 1104 Flori Bunda Ln., Mechanicsburg, PA 17055 Sun Cha Steiner 1104 Flori Bunda Ln., Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address Same as #1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage Of record: Name Address Plaintiff herein. Bank One, NA See Caption above. 10300 Kincaid Drive, IN1-9030, Fishers, IN 46038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlise, PA 17013 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 1104 Flori Bunda Ln, Mechanicsburg, PA 17055 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. ~J.~REN & ASSOCIATES DATED: March 5, 2002 [' // ~~ \ JM~rk J. Udren~& Associates, ESQ. ~/Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSURE : :NO. 01-6844 Civil o Defendant (s) ' : N 0 T/~CEO ' OF REAL_RROPERT%~ TO .' Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Your house (real estate) at 1104 Flori Bunda Ln, Mechanicsbur~, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $118,623.22, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTI~ OF O36~ER'S R~HT~ YOU MAY BE ABLE TO--VENT THIS SHERIFF'~u_SAI~E To prevent this Sheriff's Sale, you must take The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: - - 0. 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. 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.) Y~ ABLE~IO ~D_UR P3~O~RERTY AND Y~OU HAV~O~THER PJ~HT~ ESLEN IF TF~F~?J~E~F~F~LS SALF~DQE~ TAKF~RLAC~E~ 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to'set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. iF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant ( s ) Esquire ATTORNEY FOR PLAINTIFF :COURT- OF COMMON PLEAS i CIVIL DIVISION : Cumberland County - MORTGAGE FORECLOSURE 'NO. 01-6844 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kenneth R. Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Your house (real estate) at 1104 Flori Bunda Ln, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $118,623.22, 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 RI~HT~ YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, Costs and reasonable attorney's fees. To find out how much you must pay, you may call: ~- 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. 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 RI~HT~ EVEN IF THE SHERIFF'S SAL~ DOES TAK~ PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten '(10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFOP, D ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN OHT LEOAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, ATTY I.D. NO. 04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-%82-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BCl The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Esquire ATTOP, NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil Kenneth R. Steiner Sun Cha Steiner : 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) : ~LE pROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. MARK J. UDREN & ASSOCIATES Date: April 4, 2002 Mark J. Udren & Associates,ESQUIRE Attorney for Plaintiff Bank One, National Association, as trustee, et. al., Pla~tiff(s) VS. Steiner, et. al., Defendant(s) MARK J. UDREN Ms. Cara Stears 1040 North Kings Highway Suite 500 Cherry Hill, NJ 08034 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Kenneth R. Steiner, by posting Court Case No. 01-6844 State of: ~ ~ ~ \ 0~./~ ~'c~ )ss. Countyof: OJo. v~.'~r Io._~J ) Name of Se~er: ~,~0~ ~ ~* ~ ~ ,undersi~ed, being duly swom, deposes and says that at ~e time of semite, s~e was ~ver ~e age of ~en~-one, was not a pa~ to this action; Date~imeofSe~ice: thaton~e ~dayof ~C~ ,20 0'~ ,at ~'.0~ o'clock ~ M Place of Service: at 1104 Flori Bunda Lane , city of _Mechanicsburg ., state of PA Documents Served: the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property and Order ~./Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Kenneth R. Steiner, by posting Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: [] By personally delivering them into the hands of the person to be served. ~ By delivering them into the hands of , a person of suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is The person receiving documents is described as follows: Sex ; Skin Color ; Hair Color ; Facial Hair Approx. Age ; Approx. Height ; Approx. Weight [~ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury Subscribed and sworn to before me this th~t,~e foregoing isArue and correct. _0~t~.day of _/L~ o~rr ~` ,20 o~. Signatur~ofServcr' ' (~(~--- d (Date) No~[yPublic ~ (CofflmissionEp') APS International, Ltd. APS File #: 051917-0001 l J~ank One, National Association, as trustee, et. al., Plaintiff(s) VS. Steiner, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7500 Glenroy Rd. Minneapolis, MN 554139-;3122 MARK J. UDREN Ms. Cara Stears 1040 North Kings Highway Suite 500 Cherry Hill, NJ 080;334 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Sun Cha Steiner, by posting Court Case No. 01-6844 Stateof: ~0-%~ )O~_~tct )ss. Name o Se.er= ' ¥' , undersigned, being duly sworu, deposes =d ays that at the time of service, s/he was'over the age of twenty-one, was not a party to this action; Dateffime of Service: thatonthe c~V~4dayof ~¥c3,r,~ ,20 09. ,at 20'-~ o'clock~-~ M Place of Service: at 1104 Flori Bunda Lane ., city of ..~Mechanicsbur_g~, state of PA Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property and Order -~ Service and correct of the aforesaid document(s) was served on: of Process A true copy Sun Cha Steiner, by posting Person Served, and Method of Service: ~ By personally delivering them into the hands of the person to be served. By delivering them into the hands of suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is , a person of Description of Person Receiving Documents: Signature of Server: The person receiving documents is described as follows: Sex ; Skin Color ; Hair Color ; Facial Hair Approx. Age ; Approx. Height ; Approx. Weight ~ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that.~e foregoing is true and correct. ~igna~ure of Serve~ ' ' '~,/(J ~ (Date) APS International, Ltd. APS File #: 05191%0001 Subscribed and sworn to before me this Not~y Public [ (Commission Expires) MA/%K J. UDREN & ASSOCIATES BY= Mark J. Udren a Associates ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bund& Ln. Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF SERVICE ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION . Cumberland County NO. 01-6844 Civil PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren & Associates, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". Ail Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of relating to unsworn falsification to authorities. Dated: April 5, 2002 18 Pa.C.S. Section 4904 I~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) Esquire ATTOP/FEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil DATE: March 18, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OWNER(S): KENNETH R. STEINER & SUN CMA STEINER PROPERTY: 1104 Flori Bunda Ln, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the F~ County Sheriff's Sale on Jla, at 10:00 A.M., at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A MARK J. UDREN & ASSOCIATES BY= Mark J. Udren & Associates, ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Vo Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) Esquire ATTOPd~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-6844 Civil V~RIFICATION OF SERVICE BY CERTIFIED ~4AIL AND REGLrLAiqMAIL 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 Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: March 18, 2002 Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 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: March 21, 2002 MARK J. UDREN & ASSOCIATES Mark J. Udren ~ Associates, Esmu~_=e~:-. EXHIBIT J. UDREN & ASSOCIATES ~BY: MARK J. UDREN, ESQUIRE ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chmago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 Plaintiff Kenneth R. Steiner Sun Cha Steiner Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION i Cumberland County : · NO. 01-6844 Civil .- . .- ORDF. R AND NOW. this . 200 , pon consideration of Plaintiff's Motion and the 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), Kenneth R. Steiner and Sun Cha Steiner, shall be complete when Plaintiff ot its .counsel or agent has mailed tree and correct copies of the Complaint in Mortgage Foreclosure and all subsequem pleadings by certified mail ahd regular mail to the last known address of Defendant(s), Kenneth R. Steiner and Sun Cha Steiner at 1104 Floribunda Lane, Mechanicsburg, PA 17055 and by posting the mortgaged premtses located at 1104 Floribunda Lane, Mechanicsburg, PA 17055. BY THE COURT: / J. -EXHIBIT L USE[ !! ~e §u!:lem uaq~', I! ~uasa~d pue ld!aoa~ s!ql a~e$ :INVlBOd~I :sap!Ao~l I!elAI Pau!Pao z~mo ~m~Zm OFF]C]AL US Cllqem u~q~A 11 luasgJd ;!ql aAe$ :INVIBOdLMI ·" :1 lleL~ poll. Po3 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, ATTY I.D. NO. 04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 0803% 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO FILE Esquire ATTOP/FEY FOR PLAINTIFF COURT OF COMMON PLEAS i CIVIL DIVISION Cumberland County ~NO. 01-6844 Civil PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. MARK J. UDREN & ASSOCIATES Date: April 4, 2002 BY: Mark J. Udren & Associates,ESQUIRE Attorney for Plaintiff EXHIBIT Bank One, National Association, as trustee, et. al., Plaintiff(s) Steiner, et. al., Defendant(s) MARK J. UDREN Ms. Cara Stears 1040 North Kings Highway Suite 500 Cherry Hill, NJ 08034 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MIV 55439-3122 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Kenneth R. Steiner, by posting Court Case No. 01-6844 State of: ~ c~ ~ O~ c~ ~/r-c )ss. Connty of: OX,~ w~-~' {CL. ~ d~ } Name of Se~er: ~n~,'0J ~ ~ ~ ,undersi~ed, being duly swom, deposes ~d says · at at the time of se~ice, s~e was ~ver the age of ~enW-one, w~ not a p~ to ~is action; Dat~imeofSe~ice: ~aton~e ~dayof ~F~ ,200~ ,at~- ~oclock ~M Place of Service: at 11o4 Flori Bunda Lane , city of Mechanicsburg , state of PA_..~_. Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property and Order ~ervice of Process On: Person Served, and A true and correct copy of the aforesaid document(s) was served on: Kenneth R. Steiner, by posting Method of Service: Description of Person Receiving Documents: Signature of Server: [] By personally delivering them into the hands of the person to be served. [] By delivering them into the hands of , a person of suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is The person receiving documents is described as follows: Sex ; Skin Color ; Hair Color ; Facial Hair Approx. Age ; Approx. Height ; Approx. Weight [] To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury Subscribed and sworn to before me this t~ foregoing isfi;[ue~and correct. . APS International, Ltd. APS Flla #: 051917-0001 EXHIBIT Bank One, National Association, as trustee, et. al., Plaiet fi(s) Stelner, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, M_N 55439-3122 MARK J. UDREN Ms. Cara Stears 1040 North Kings Highway Suite 500 Cherry Hill, NJ 08034 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Sun Cha Steiner, by posting Court Case No. 01-6844 Stateof: ~.t. lx~.%,~ IOm~,a }ss. Name of Se~er: /<~ , =dersi~ed, being duly sworn, deposes .d Says that at the time of se~ice, s/he was'over ~e age of ~enW-one, w~ not a p~ to this action; Dat~imeofSe~ice: ~atonthe ~gMdayof '~% ,20 o2 ,at 30~ o'clock~ M Place of Service: at 1'104 Flori Bunds Lane , city of Meehanicsburg , state of PA__.~_ Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property and Order J~Service of Process on: Person Served, and A true and correct copy of the aforesaid document(s) was served on: Sun Cha Steiner, by posting Method of Service: Description of Person Receiving Documents: Signature of Server: [] By personally delivering them into the hands of the person to be served. [] By delivering them into the hands of , a person of suitable age and discretion residing at the Place of Service, whose relationship to the person to be served is The person receiving documents is described as follows: Sex ; Skin Color ; Hair Color ; Facial Hair Approx. Age. .; Approx. Height ; Approx. Weight [] To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury Subscribed and sworn to before me this /~O_~_~ t::~nn~,-.~f°reg°ing is' tree and correct. ~ _~. ~4'Ntay of//L{~ v.. t.~ ,20 ~ ~.. ~igna~ure ofServe~ ' ' ~/-J ~ (Date) Not~yPublic [ (Commission Expires) APS International, Ltd. APS File #: 051917-0001 EXHIBIT E COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which _~ is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2002, under and by virtue ora writ Execution issued on the 12th day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 6844, at the suit of Bank One N A Tr against Kenneth R Steiner & Sun Cha is duly recorded in Sheriff's Deed Book No. 253, Page 828. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /~ day of % A.D. 200~. ~x~ i(~, ~ ~ecorderofDeeds Bank One, N.A., as Trustee f/kda The In The Court of Common Pleas of First National Bank of Chicago, as Trustee Cumberland County, Pennsylvania For Structured Asset Securities Corporation Writ No. 2001-6844 Civil Term Mortgage Pass-Through Certificates, Series 1999-BC1 VS Kenneth R. Steiner and Sun Cha Steiner Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2002 at 7:53 o'clock p.m., EST, he served the within Real Estate Writ, Notice and Description upon the within named defendants, to wit: Kenneth R. Steiner and Sun Cha Steiner, by posting the premises located at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania pursuant to a court order. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on April 5, 2002 at 9:22 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kenneth R. Steiner and Sun Chas Steiner located at 1104 Flori Bunda Lane, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Kenneth R. Steiner, by regular mail to his last known address of 1104 Floribunda Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Sun Cha Steiner, by regular mail to her last known address of 1104 Floribunda Lane, Mechanicsburg, PA 17055. This letter was mailed nnder the date of April 04, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5' 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for Bank One N.A., f/k/a The First National Bank of Chicago, as Trustee for the Structured Asset Securities Corporation Mortgage Pass- Through Certificates series 1999-BC1; Aurora Loan Services, Inc. Amresco Residential Mortgage Corporation. It being the highest bid and best price received for the same, Bank One N.A., f/k/a The First National Bank of Chicago, as Trustee for the Structured Asset Securities Corporation Mortgage Pass-Through Certificates series 1999-BC 1; Aurora Loan Services, Inc. Amresco Residential Mortgage Corporation of 12650 Ingenuity Drive, Orlando, FL 32826, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $948.48, it being costs. Sherifffs Costs: Docketing $30.00 Poundage 18.60 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Service 13.80 Certified Mail 2.43 Levy 15.00 Surcharge 30.00 Posting (pursuant to 12.00 Court Order) Law Journal 404.90 Patriot News 270.55 Share of Bills 25.20 Distribution of Proceeds Sheriff's Deed 25.00 29.50 $948.48 paid by attorney 08/07/02 Sworn and subscribed to before me So Answers: This o%0 L"dayof ~,~t- ~;;~"~ j/~ - d R. Thomas Kline, Sheriff Real Estat~ Deputy Ck.. 37779~ SOCrATeS ' ~ U-D~N ~ A~ = ~ssoC&ateS' ATTY ~.D. NO. · K~NGS ~G~WA~, SU~T~ 500 10&0.N , _ Nj 08034 C~RRy ~Lb, ~ : CouRT oF COMMON pLEAS cc iaticn, ~af~ruStej'f/k/a The First cumberland county National Bank of ChiCago, As Trustee for structured Asset · corporatiOn Mortgage Securities certificateS' pass-Thr°ugh series 1999-BC1 Floor The ForUm, Tower B, 7th 1665 palm BeaCh Lakes Blvd. West palm BeaCh, FL 33401 plaintiff · MORTGAGE FORECLOSURE : NO. 01-6844 civil : Kenneth R. steiner sun Cha steiner ~104 Flori Bunda Ln. Mechanicsburg' PA 17055 Defendant[s) AFFIDAVIT puRSUANT TO RULE 3129.1 ' st National B~n~ =;~;a The F~r . _ corDorat~°~ ~e ChicagO, ~wou~h Ceru~=~ ~ark J' ~- ~-a~e pass-~ .~ attorney, "'= w the wrlu u~ ~ locate~ ~' Moru9 ~ctiOn, by lU°~he praecipe ~[e real properu~ above _ ~ the dat~ u _~merning tOZ~" . ~nformau~ PA 17055 follOWing Flori Bunda Ln, Mechanicsburg' reputed owner(S): Address 1. Name and addreSS of owner{S) or Name 1104 FlOri Bunda Ln., MechanicsbUr' Kenneth R. steiner 1104 Flori Bunda Ln., MechaniCSb Sun Cha Steiner ~s) in the judgment: ~. Name and addreSS of DefendantAddreSS Name same aS ~l above 3. Name and addreSS o~ every judgment creditor whose AddreSS lien on the real property to be sold: Name None 4. Name and address of the last recorded holder record: Name Address of every mortgage Of Plaintiff herein. See Caption above. Bank One, NA 10300 Kincaid Drive, IN1-9030, Fishers, IN 46038 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlise, 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 1104 Flori Bunda Ln, Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to a~thorities. & ASSOCIATES DATED: March 5, 2002 /M~rk J. Udre~'& Associates, ESQ. ~/Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Associates, ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Plaintiff Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Defendant (s) Esquire ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSURE : :NO. 01-6844 Civil NQT/~C ~0 F~ E R/~ F!S~ E ~F~ A L_ RROp~E p~T y TO .' Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Your house (real estate) at 1104 Flori Bunda Ln, Mechanicsbur~, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $118,623.22, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~O~TI~E QF O~EI~GHT~ Y~O33~BLE~R E~V~ENT~HI~ ~RI ,~AL E TO prevent this Sheriff's Sale, you must take imme.di&t~e_a~onl 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorne~,s fees. To find out how much you must pay, you may call: JJL%6_)-482-69Qg~ 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.) IlO U~y~ T_ILk_B E_ABL E ~ S AV~E ~QUR ~OP~RT~_O/L j/A ~ L~ ~XH E ~ i GHT~ F~E ~L~IF~X3~S HER ~A L ~ ~D_OF~u~TAK F~pj~A CE ._ 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFOP. D 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 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN LOT OF GROUND EITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND A~D STATE OF PENNSYLVA/~IA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHERN LINE OF FLOEIBUNDA LANE (50 FEET WIDE} WHICH SAID POINT IS IN THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE NORTHERN LINE OF FLOHIBUNDA LANE IN AN EASTWARDLY DIRECTION BY THE ARC OF A CIHCLE CURVING TO THE HIGHT, SAID CIRCLE HAVING A H~DIUS OF 200 FEET, THE ARC DISTANCE OF 34.91 FEET TO A POINT MARKED BY A MONUMENT; THENCE CONTINUING ALONG THE NORTHERN LINE OF FLOHIBUNDA LANE, SOUTH 74 DEGREES 25 MINUTES 33 SECONDS EAST 35.75 FEET TO A POINT AT CORNER OF LOT NO. 19 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 19 AND 20 ON SAID PLAN, NORTH 15 DEGREES 34 MINUTES 27 SECONDS EAST 131.18 FEET TO A POINT AT CORNER OF LOT NO. 15 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 15 AND LOTS NOS. 28 AND 14 ON SAID PLAN, NORTH 77 DEGREES 09 MINUTES 21 SECONDS WEST 100.0 FEET TO A POINT AT CORNER OF LOT NO. 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON SAID PLAN, SOUTH 02 DEGREES 46 MINUTES 37 SECONDS WEST 132.76 FEET TO A POINT IN THE NORTHERN LINE OF FLOHIBUNDA LANE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 20, BLOCK "B" ON THE PLAN OF SECTION i OF ROSEGARDEN, WHICH SAID PLAN IS RECORDED IN THE CUMBERLAND COUNTY EECOHDER~S OFFICE IN PLAN BOOK 27, PAGE 16. HAVING THEREON ERECTED AN ALUMINUM AND BEICK COLONIAL BI-LEVEL HOUSE WITH TWO-CAR GARAGE. BEING KNOWN AS 1104 FLORI BUNDA LANE, MECHANICSBURG, PA 17055 PROPERTY TAX PARCEL NO.: 42-31-2153-027 TITLE TO SAID PREMISES IS VESTED IN KENNETH R. STEINER AND SUN CHA STEINER, HIS WIFE, BY DEED FROM RICHARD A. WALKER, A SINGLE MAN, DATED 7/29/86, RECORDED 7/30/86, IN DEED BOOK B-32, PAGE 480. ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTy OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHERN LINE OF FLORIBUNDA LANE (50 FEET WIDE} WHICH SAID POINT IS IN THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE NORTHERN LINE OF FLORIBUNDA LANE IN AN EASTWARDLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE RIGHT, SAID CIRCLE HAVING A RADIUS OF 200 FEET, THE ANC DISTANCE OF 34.91 FEET TO A POINT MARKED BY A MON~3MENT; TNENCE CONTINUING ALONG THE NORTHERN LINE OF FLOEIBUNDA LANE, SOUTH 74 DEGREES 25 MINUTES 33 SECONDS EAST 35.75 FEET TO A POINT AT CORNER OF LOT NO. 19 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 19 AND 20 ON SAID PLAN, NORTH 15 DEGREES 34 MINUTES 27 SECONDS EAST 131.18 FEET TO A POINT AT CORNER OF LOT NO. 15 ON THE HEREINAFTEH MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 15 AND LOTS NOS. 20 AND 14 ON SAID PLAN, NORTH 77 DEGREES 09 MINUTES 21 SECONDS WEST 100.0 FEET TO A POINT AT CORNER OF LOT NO. 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG THE DIVISION LINE BETWEEN LOTS NOS. 20 AND 21 ON SAID PLAN, SOUTH 02 DEGREES 46 MINUTES 37 SECONDS WEST 132.76 FEET TO A POINT IN THE NORTHERN LINE OF FLORIBUNDA LANE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 20, BLOCK "B" ON THE PLAN OF SECTION I OF HOSEGAHDEN, WHICH SAID PLAN IS RECORDED IN THE CUMBERLAND COUNTY HECORDER'S OFFICE IN PLAN BOOK 27, PAGE 16. HAVING THEREON EHECTED AN ALUMINUM AND BEICK COLONIAL BI-LEVEL HOUSE WITH TWO-CAR GARAGE. BEING KNOWN AS 1104 FLORI BUNDA L/LNE, MECHANICSBURG, PA 17055 PROPERTY TAX PARCEL NO.: 42-31-2153-027 TITLE TO SAID PREMISES IS VESTED IN KENNETH R. STEINER AND SUN CHA STEINER, HIS WIFE, BY DEED FROM RICHARD A. WALKER, A SINGLE MAN, DATED 7/29/86, RECORDED 7/30/86, IN DEED BOOK B-32, PAGE 480. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren & Asso=iates, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Bank One, National Association, As Trustee f/k/a The First National Bank of Chicago, As Trustee for structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999-BC1 The Forum, Tower B, 7th Floor 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION :Cumberland County : -MORTGAGE FORECLOSURE Plaintiff v. Kenneth R. Steiner Sun Cha Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 : NO. : : 01-6844 Civil Defendant(s) : TO: N 0/L/~CF~DF~ HERI~ FLS~ALE~ F~ A L~p~ ORE~T~y Kenneth R. Steiner 1104 Flori Bunda Ln. Mechanicsburg, PA 17055 Your house (real estate) at 1104 Flori Bunda Ln, Mechanicsbur~, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $118,623.22, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~Q// MAY~BE~~ S_ S3tE R~FE/~_S A L E To prevent this Sheriff's Sale, you must take 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney,s fees. TO find out how much you must pay, you may call: 18~ 4~2-69~ 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.) Y~OU~¥~TILL_BE_ABLE_~SAVE · YD33~P~OP~ERTY~AND~_OU~V~THER RIGHT~ F~V~E~_~E S/{ ER IF~ ' S~ A L ~D_OES~KE~AC EJ. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. iF YOU DO NOT HAVE A LAWYER OR CA~NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER EEFERHAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: NO 01-6844 Civil CIVIL ACTION - LAW To satisfy the debt, interest and costs due BANK ONE, NATIONAL ASSOCIATION, AS TRUSTEE F/KdA THE FIRST NATIONAL BANK OF CHICAGO, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 1999-BCI, Plaintiff(s) From KENNETH R. STEINER AND SUN CHA STEINER, 1104 FLORI BUNDA LN, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account 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 garmshee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $118,623.22 L.L. $.50 Interest FROM 3/6/02 TO DATE OF SALE 6/5/02 PER DIEM ~ $28.45 - $2,617.40 Atty's Comm % Due Prothy $1.00 AttyPaid $168.40 Other Costs Plaintiff Paid Date: MARCH 12, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: MARK J. UDREN & ASSOCIATES 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale #56 On March 15, 2002 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA known and numbered as 1104 Floribunda Lane, Mechanicsburg and more fully described on Exhibit "A" flied with this writ and by this reference incorporated herein. Date: March 15, 2002 Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of ~ and The ~ newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COPY i E::'cm tc :.'~d :'-'bc?r!b,~d ~,~,~ ,pje~b~s 17th dayp~lav/2~02 A.D Harrisburg, Daupnirl Cou~lly I NO'I~RY PUBLIC My Commission Expires Jurie 6, 2002 [ly commission expires June 6, 2002 Mern~er, PennsyNanla Association of Nolerfes CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 268.80 $ 1.75 $ 270.55 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patr'ot-News and The u d Patri t-New , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : $$. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 26, MAY 3, 10, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not imerested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to *~rr ~ ~ and character of publication are tree. SWORN TO AND SUBSCRIBED before me this 10 .day of MAY, 2002 REAL E~TATE SALE NO. 56 Writ No. 2001-6844 Civil Bank One, N.~, as Trustee. f/k/a The First National Bank of Chicago, as Trustee for Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 1999 BC1 VS. Kermeth R. Steiner and Sun Cba Steiner Atty.: Mark J. Udren ALL THAT CERTAIN lot of ground situate in the Township of Upper Alien, County of Cumberland and State of permsylvania, bounded and described as follows, to wit: BEGINNING at a point in the northern line of Floribunda Lane (50 feet wide) which said point is in the division line between Lots Nos. 20 and 21 on the hereinafter mentioned plan of Lots; thence extendix~g along the northern line of Floribtmda Lane in an eastwardly direction by the arc of a circle curving to the right. said circle having a radia~ of 200 feet. the arc distance of 34.91 feet to a point marked by a monument; thence continuing along the north- em line of Floribunda Lane. South 74 degrees 25 minutes 33 seconds East 35.75 feet to a point at corner of LOt No. 19 on the hereinafter men- tloned plan of Lots: thence extend- lng along the division line between Lots Nos. 19 and 20 on said plan, North 15 degrees 34 minutes 27 seconds Bast 131.18 feet to a point at comer of LOt No. 15 on the here inafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 20 and 15 and Lots Nos. 20 and 14 on said plan, North 77 degrees 09 minutes 21 seconds West 100.0 feet to a point at comer of LOt No. 21 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 20 mad 21 on said plan. South 02 degrees 46 minutes 37 seconds West 132.76 feet to a point in the northern line of Floribunda Lane, aforementioned, at the point and place of beginning. BEING Lot No. 20, Block 'B' on the Plan of Section 1 of Rosegarden, which said plan is recorded in the Cumberland County Recorder's Of- fice in Plan Book 27, page 16, HAVING thereon erected an alu mlnum and brick colonial bi-level house with two car garage. BEING KNOWN AS 1104 Flort Bunda Lane, Mechautcsburg, PA 17055. PROPERTY TAX pARCEL NO.: 42-31-2153 027. TITLE TO SAID PREMISES IS VESTED IN Kenneth R. Steiner aI~d Sun Cha Steiner, his wife. by deed from Richard A. Walker, a single man. dated 7/29/86, recorded 7/30/86, in Deed Book B 32, Page 480.