Loading...
HomeMy WebLinkAbout09-4311 A UDREN LAW OFFICES, P.C. ATTORNEY FOR MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION 961 Weigel Drive Elmhurst, IL 60126 :Cumberland County Plaintiff V. Bradley S. Heichel Kristi L. Heichel E NO. 11311 118 Milkyway Cumberland, PA 17257 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against t set forth in the following pages, you must take action within tv days after this Complaint and Notice are served, by entering appearance personally or by attorney and filing in writing with your defenses or objections to the claims set forth against you warned that if you fail to do so the case may proceed without judgment may be entered against you by the Court without furth for any money claimed in the Complaint or for any other claim requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS C PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANE TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH IN ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERK REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 IFF ji.vm ie claims ?nty (20) written ,he Court You are rou and a ?r notice )r relief or other NOT HAVE FFICE CAN OT AFFORD FORMATION ONS AT A AVISO Le han demandado a usted en la Corte. Si usted quiere de de estas demandas expuestas en las paginas siguientes, ust veinte (20) dias de plazo al partir de la fecha de la demz notificacion. Hace falta ascentar una comparencia escr persona o con un abogado y entregar a la Corte en forma es( defensas o sus objeciones a las demandas en contra de su Sea avisado que si usted no se dafiende, la Corte tomara r puede continuar la demanda en contra suya sin previo notificacion. Ademas, la Corte puede decidir a fz demandante y requiere que usted cumpla con todas las provi! esta demanda. Usted puede perder dinero o sus propiedade: derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIEN: O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 fenderse ed tiene .nda y la ita o en !rita sus persona. ;edidas y aviso o .vor del ;iones de u otros ABOGADO VAYA EN :ION SE NSEGUIR I 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 notiO us within 30 days after receipt of this Notice and the attached document that the validity ¢f the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If y¢u 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 period, we will provide you with the name and address of the original creditor if the current creditor. If you notify us in writing within the 30 day period as stated above, we will of your debt, or any disputed portion of it, until we obtain the information and mail it to you. Once we have mailed to you the required information, continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached an attempt to collect a debt, and any information obtained will be used for that UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 the 30 day ferent from e collection is required e will then ocument is s ? 1. Plaintiff is the Corporation designated as such caption on a preceding page. If Plaintiff is an assignee is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A in the then it 2. Defendant (s) is the individual designated as su h on the caption on a preceding page, whose last known address i 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 Defe dant (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: 118 Milkyway MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township COUNTY: Cumberland DATE EXECUTED: 8/26/06 DATE RECORDED: 8/30/06 BOOK: 1964 PAGE: 988 The legal description of the mortgaged premises is at and made part hereof. 4. Said Mortgage is in default because the required have not been made as set forth below, and by its tei breach and failure to cure said breach after notice, secured by said Mortgage, together with other charges auth, said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to refuses to comply with the terms of the Mortgage as folk d hereto payments as, upon ill sums rized by fail or WS: 0 (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, indicated below. 6. The following amounts are due on the said Mortg 5/12/09: Principal of debt due Unpaid Interest at 10.950 from 10/1/08 to 5/12/09 (the per diem interest accruing on this debt is $57.00 and that sum should be added each day after 5/12/09) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $91.14 should be added in accordance with the terms of the note each month after 5/12/09) Attorneys Fees (anticipated and actual 0 325.00 280.00 637.98 to 596 of principal) 9,500.42 TOTAL $213,519.86 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 prov sions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 9 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular ail, in accordance with the requirements of those acts, on he date appearing on the copy attached hereto as Exhibit "A", and made part if any, e as of $110,008.46 2,768.00 hereof, and defendant (s) have failed to proceed within he time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, the Defendant(s) herein in the sum of $213,519.86 plus costs and attorneys fees as more fully set forth in the and for foreclosure and sale of the Mortgaged premises. CES, P against terest, laint, BY: C_ 3y Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE `LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 0 ALL that certain tract of real estate situate in Southampton Township, Cumberland County, Pennsylvania, bounded and dascn'bed as follows: BEGDDZNG at an iron pin to be set at the northwestern comer of Lot No. 28; theucc along iht common line of Lot No. 30 and Lot No. 31 North 49 degrees 36 minutes 01 seoon,ds Eas4 101 Att feet to an iron pin to o set at the northeastern comer of Lot No. 30; thence along Wky Way, South 38 degrees 46 minutes 47 seeoads East, 106.03 feet to an hart pin to be sec at the southcastem corner of Lot No. 30; thence continuing along Milky Way and onto Barnhill Dive along the arc of a circle bearing to th o right having a delta angle of 88 degrees 22 minutes 48 saa=ds having a radius of 35.00 feet, an arc distance of 53.95 (the chord of said arc extending South 05 degrees 24 minuxs 37 seconds West 48.99 feet) to an iron pin to be set; tbonce along Lot 30 and Barnhill Drive South 49 degrees 36 minutes 01 seconds West, 53.53 feet to an iron pin to he set; thence along the common line of Lot No. 30 and Lot No. 53 North 40 degrees i 1 minutes 2 seconds West, 140.00 feet to am iron pin to be set, being the point and place of BEG1ldMLNG. COXTAP%BNG 13,553 schuss feet and being Lot 30 pursuant to the Harttpton F3it1s, Phase I Final Si"vision Plan, dated February 2, 1996, and revised March 1, 1999, prepared by Martin and Martin, Inc., recorded on October S, 2001 in the Office of the Register & Recorder of Deeds of Cumberland County, Pennsylvania, at VdI une 84, Page 14. SUBJECT to all rights-of-way, restaictions, easetztents, conditions, and set bade lines of record, including but not limited to those stated in the aforementioned subdivision plan. ?i i i :I i it ' i M ay 20, 2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in defau t and the, t mdrx , intends to foreclose- Specefle jnfornjn?on nhout the nature of the default is pro, 4ded in the attached pages- The HOMFOWNFROS MORTGAGF ASSISTANCE PROGRAM ( HEMAP) i riny be able to help to save your home, This Notice explains how the progrAm wor - To see of HEMAP enn help, yoji must MEET WITH A CONSUMER CR j& Ma COUNSELING A HIN 30 DAYS OF THE DATE OF THIS N 1CF- Take this Notice with you when yon meet with the Counseling Agency, The name, nddreqzs and phone number of Consumer Credit Counsefing A. ing - your County are lostt-A at & t-nd of this Notice- If yon have any glije%tions you ma3: call the , hearing can call (717)- This Notice contains important legal information. If you have an representatives at the Consumer Credit Counseling Agency may be able to he questions, explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES FECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMP NDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA T UCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIB . PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM1 LAMADO 1 EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A RIE DIMIR SU HIPOTECA. Page I of 1 F-XH1B1T : v r HOMEOWNER'S NAME(S): Bradley S. Heichel PROPERTY ADDRESS: 118 Milkyway LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE HELP YOU MAKE. FUTURE MORTGAGE, PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOM OWNERGS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEY ND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO AY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLIS D BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF,MPORARV STAY OF FORECLOSURE -- Under the Act, you are entitled t a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice During that time you must arrange and attend a Oface-to-faced meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN CONSITMF.R CREDIT COUNSELING AGENCIES -- If you meet with one of he consumer credit counseling agencies listed at the end of this notice, the lender may NOT take ction against you for thirty (30) days after the date of this meeting. The names, addresges, and tel one number.-, are set forth at the end of this Notice. It is only necessary to schedule one face-to- ace meeting. Advise your lender immediatelT of your intentions. APPLICATION FOR MORTGAGE, ASSISTANCE, -- Your mortgage is in d fault 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 len er, you have the right to apply for financial assistance from the Homeowner's Emergency Mortga e Assistance Program. To do so, you must fill out, sign and file a completed Homeowner' Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsyl ania Housing Page 2 of 2 1 Finance Agency. Your application MUST be filed or postmarked within thirty (30) ays 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. AG,F,NCY ACTION - Available funds for emergency mortgage assistance are very limit d. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. Du ' g that time, no foreclosure proceedings will be pursued against you if you have met the time require ents set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PET ION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFO ATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEM T TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 118 Milkyway Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following onths and the following amounts are now past due: Monthly Pa ments.._of..$1822.96._for._.N....ovember._ 112008._through _May 1.,._2009.....,.=..._$.1....2.._60_.7.................................... Monthly..Late„ Ch.a...rges.._of.,$91,14,_for._NOyember._l,._2008._thr.o...ugh_May._1.,.2009......._._$_........7 98 ....................................... Other charges (explain/itemize) Uncollected Fee's Receivahl'e _ $12,50.......... , ......... ..................... . TOTAL AMOUNT PAST DUE: _-- %J 34J J.1.0..... B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (loo not use if not applicable): NA HOW TO CURE THF. DF.FAITI,T -- You may cure the default within THIRTY (30) DAY of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 513411.20- PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa=ents must be made either by cash, cashier's rherk certified rheck or money o -r made, payable and cent to* Udren Law Offices, P_C_ Wooderest Corporate Center 111 Wooderest Road_ Suite 200 Cherry Hill, NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAY of the date of this letter: (Do net use if not applicable-): NA Pane 3 of 3 IF YOU DO NOT CURE THE, DEFAULT -- If you do not cure the default within THIRT (30) DAYS of the date of this Notice, the lender intend% to exercise its rights 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 total amount ast due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start 1 gal action to foreclose upon your mortgaged property, IF THE MORTGAGE, IS FORECLOSED UPON -- The mortgaged property will be sold y the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are tarted against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even f they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may als include other reasonable costs. If you cure the default within the TRMTY (30) DAY period, you will not he re sired to pav a . orney's fees. OTHER LENDER RE,MFDiF.S -- The lender may also sue you personally for the un aid principal balance and all other sums due under the mortgage. If your debt has been discharged in banla ptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CURF. THE. DEFAULT PRIOR TO SHFRIFF'S SAI.F. -- If you have not c ed the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, • ht? in writing by the lender and haperforming 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 POSS11BLE SHERIFF'S SALF. DATE -- It is estimated that the earliest d e that such a Sheriff s Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you efore the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may rind out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person: 961 Weigel Drive EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your mortgaged property and your right to occupy it. If you continue to live in the property a'. Sale, a lawsuit to remove you and your furnishings and other belongings could be started any time. ASSUMPTION OF MORTGAGE -- You transfer your home to a buyer or transferee who will assume the mortgage debt, pro outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale requirements of the mortgage are satisfied. Lership of the the Sheriff s the lender at not I that all the that the other Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name o 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 he 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 311 day period, we will provide you with the name and address of the original creditor if diffe nt from the current creditor. If you notify us in writing within the 30 day period as stated above, we will ce se 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 UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 YOU MAY ALSO HAVE. THE. RIGHT* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PA OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YO BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF N DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIME'S IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE ORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO S CH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Page 6 of 6 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10115/2007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 t m r J] ` p? - `? p Y r t p p 0 O .?y d 1•?COa? ??OD c ? ? 1 00 Er Er - `o co , Lr] Ln m m -n ,n fU tti Postage $ I- Certified Fee 0 r-3 C3 p r-3 C3 (EndorsReturn e n q Guiredj p 0 Restricted Delivery Fee (Endorsement Required) rq r r-I Total Postage & Fees _---? ? - --? p ? Sent To p \ C3 p 8lreef, Apt-No ; -- I . or PO Box No. 1 Vi 3 ....... *? tD G I 1 CD c r ?rviceTll POstma Here ------------------------- ?. (mil] --, i) C13 0 W OD N Q w N O A ru CD Z a3 3 Cr m m 0 n 3 1 § A 2 m 13 n ?i iD D a - C 6 v ?i ?? _(D N 13 C3 o b3 k 3 b6 ?. m ¦ ¦ ¦ O Do 'v=0 off (1) 0 w av ? E C m w 0 C) 0 N (0n N. tea' (0p(A f/1 O ,..' 7 a mm's°N m w 0 ° (D a 3 0 0 m? w ;gEL rp > So = 0 O N O rL (A 3c o m @ w. ¢? ? m m c0i m m O m a m m CD CD N -Z fD CL CL Cl m CL N fA m 3 F 3 ?? o m N P3 X ? m 2 0 ?0 a 19 O a C m CD L406-000-Z0-06SL NSd (asJanarl) 900Z 1sn6nN'O( I ue 6u1AEw uagm 31 Wasald pup Idi8321 SIM apes :1? pew pue a6elsod qAm lagel!lle Pue ,loelaP 'paPaau 1ou woo 314 uoJeuJlso d e }i `bu!slJewlsod lot } ao!llooo ?!Jeu uasaJd aseal `pansap s! }d!aoaJ Wen Pa!}!1JaO 6L41 u Aanllat7 Pato!JJSGH^ lua4 ao ua e P 2}! ;oglne sip a!dl!eW aql NJ,2W JO ?Jajo aql as!nPV ; {,ew Uan!!ap auoil!P[ 3JPne aql of palO!J}saJ aq "OA ,JO .yJewlsod ®SJEM e '1dlaOaJ uJnlaJ e ,)IN, aa} I!eW e Pa!1RJaan!aoaJO Jn "O AalsanbaU ld!aoeb nJnlay„ aoa!d!!ew as. Jo of a6elsod a!geolldde Ppe Pue a!n!lJe G1.11 of 4 Los elgo e lle Due alaldwoo aseald 'ao!nJas ld!aoad uJnlal3 goe i a}:,!noJd o} paisanbw aq Aew;d!aoaLI IJJn?aV e aa} leuo!1!I peW A ,jals!68b JO poinsul JGP!suo0 sinld evl pa!}l3aaO Lipm (13QIAObd SI 3JHde IeOne lou S! i!e q,aw !euo!leuJalu! }o "Selo Aue Jol alg I. AeS! Ile kl loll'} Jo ` VIN SSeIO-lsn3 qpm paulgwoo aq VINO law saeaA oml Jo} ao!nJaB Ielsod aql Aq 1dON AJan!Iap aoa!d1!ew JnoAao} Ja!}!luE ld!ao :sap!noad III g wJO? 3d ld!aoaJ le a!o Sod p }I ¦ )sJopue 3saJPpe Ue Job 3 oaJinbei togdnp e pua aa} i ldla0GH AJanpaP IL ue JOa 9 1SN1 ON 13 j P®1}gla;,3 V pa!m-1- ld;uepodiu! o pJOOaJ b Jw anb!un y ¦ u 6ug!ew V IN PawIJ83 I Y . a CIIII Q" Ln m ti O O O O r? rZI CO 0 0 r- O ?oyz xdo? 00 n ? .. , Ln u, _n -a - ??. m m ..D .A Postage $ rU ru Certified Fee O _ f3 O O Return Receipt Fee (Endorsement Required) O C3 Restricted Delivery Fee C3 C:j (Endorsement Required) ra r-I Total Postage & Fees •??? rl rl E oe - - - o o l t, F 1-3 M ?r We Apf No.: N f%- p Box No. t 1 rii r? tpg H A2eg. Al D? pp'' l; wf iMwY? \) ?.( n L "i ;t 4> "' !7t -a f c? J .. . v O 3 W co _L (o v c N O A N 7 m 2 3 0 g n CD j- a P F s n t" -J O 1*1? Oy 9 O sr w.z A? S 0?m oC', tea'.3 F-' w y OM ? Pl N 1 v ca- mm wCDW m?(OTama 0,0- N 4 w __.!;La Ul aA k to ? O = aap O ? m m 0 ci m m Li?06-000-70-OE9L NSd (asranat/) 900Z;sn H'0096 w'o3 Sd ibui ue 6upow uagm 11 juasaid pug ldiam sigl ane UNVIHOM *I!ew pue abelsod q;!m !agel x!142 pue 4o23ap 'papaou nu s! ;d!aoej ell!uaO a4l uo ?jew;sod 2;I '6ui4jLw;sod aol ao!llo is d a43 ;2 alo gi;uasaid asea!d 'paa!sap s!;d!aoai i!2!N pa!;!1iaO a43 uo iew;sod 2;1 a m oaaAlmw 94; )111ew Jo NA910 e43 GS!, >seappe aq; of paloplsaj aq Aew oa.i Imn pe!l!l eo anoA uo )!jewlsod GSdsn e 'ld!aaaa uanl p !eM aa; e aAls0el os •„palsonbad ld!aoaH uan;aa„ aoa!dlpw b od Sao of a als a!geoydde ppe pue a!o!lae aql of (L l86 wao: 13 ? - m m Go I ,' 4aelle pue ala!dwoo esua!d 'ao!njas ld!aoeli uanlaH upp id apinoa of a senbaa A d - I w m a ? 2 p l aq ew; iaoay bin;ay a eel leui f $ .I!eyv p9a9ls!6oH ao painsul iap!suoo ase; I -? (N !eAJ Pall!UaO 43!M (J3alAOHd SI 3OVH3AO0 30N o Q pew !2uo!leuialu!;o ssep ,tut col a1ge1!ene;0b sl m m < Sluou ao 6?!2yy ss2!0-Isa!:j 43!M pau!quloa aq KINO A2w m _a : slapu) ? ? ro =U 4 saaaA oMl ao; aa!nuag a23sod a4; Aq ldaN ,Gangs ' p CL CL Z ` aoa!d!!ew moA ao; jet i p 3 3 m . ld!a m r :Sa?11A0,1d l'1 f 3 P 3 p ? 1311 m 1113 Z aroD CL CD ppe tie Jod a paainbei ra aleo!!dnp e asjopu3 aa; Sd) idleoaa 0 0l AJOA!!ap !l!pp2 U2 Jod a !d 'salgenleA tunSNI ON A LIN pa!pUaO la ew Pa!;!laaO 2 uay juepodaul );o paooej y a ap! anb!un y ¦ aaa 6u!I!2w b a ?w PaIMP83 A . . • V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to take this Verification and does s because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and becau e he/she 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/her k owledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The un ersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN CES, P. J. BY : G' Attorneys for Plaintiff MARK J. UDREN, ESQUIR STUART WINNEG, ESQUIR LORRAINE DOYLE, ESQUI E ALAN M. MINATO, ESQUI E CHANDRA M. ARKEMA, ES UIRE .LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 74" ITARY 2009 JUN 26 rj'l ! "a Ct13 .J, ? ? J; Y l?? )3? r3s Sheriffs Office of Cumberland County R Thomas Kline 1tit, 4 Edward L s q? Schor PP Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy - - ?? Civil Process Sergeant Household Finance Consumer Discount Co. vs. Case Number Bradley S. Heichel 2009-4311 SHERIFF'S RETURN OF SERVICE 06/27/2009 01:51 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 27, 2009 at 1351 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradley S. Heichel, by making known unto Kris,it Heichel, wife of defendan at 118 Milky Way Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. 06/27/2009 01:51 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 27, 2009 at 1351 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Krisit L. Heichel, by making known unto herself personally, defendant at 118 Milky Way Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $62.00 SO ANSWERS, June 29, 2009 R THOMAS KLINES4'00?' , Deputy Sheriff C3 te r . UDREN LAW OFFICES, P.C. -MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION 961 Weigel Drive :Cumberland County Elmhurst, IL 60126 Plaintiff :MORTGAGE FORECLOSURE V. s Bradley S. Heichel :NO. 09-4311 Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Bradley S. Heichel and Kristi L. Heichel 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 $213,519.86 Interest Per Complaint 4,560.00 From 5/13/09 to 7/31/09 Late charges per Complaint 273.42 From 5/13/09 to 7/31/09 TOTAL $218,353.28 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY PJVMAd Att`61- ney6--for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS I:0M I ED DATE : fldlkI 4 14 HY O "r " OFp' BS t FA'G':.. .. 1?R" C3 $OR YIiAI ' ' ':. r-'.•$g4QIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKINA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER" 111.WOODCREST ROAD, SUITE 200 c CHBRRY HILL, NJ 08003-3620 •- 856-669-5400 ? plsadingoeudron.com ?.. PJ Household Finance Consumer :COURT OF COMMON PLEAS Discount Company CIVIL DIVISION 961 Weigel Drive l - q E mhurst, IL 60126 ; Cumber land county co ? Plaintiff { V. Bradley S. Heichel Kristi L. Heichel 118 Milkyway Cumberland, PA 17257 Defendant(s) NO. 49' ?3// d1U11 7-Itm COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 /? . 717-249-3166 800-990-9108 C3 L70s"di -?' Sheriffs Office of Cumberland County R Thomas Kline 4'som, of cftk4 4 Edward L Schorpp Sheriff X Solicitor Ronny R Anderson' Jody S Smith Chief Deputy om Civil Process Sergeant Household Finance Consumer Discount Co. Cass Number VS Bradley S. Heichel 2009-4311 SHERIFF'S RETURN OF SERVICE 06127/2009 01:51 PM - Michelle Gutshafl, Deputy Sheriff, who being duly swom according to law, states that on June 27, 2009 at 1351 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradley S. Heichel, by making known unto Krisit Heichel, wife of defendan at 118 Milky Way Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. 06/27/2009 01:51 PM - Michelle Gutshall, Deputy Sheriff, who being duly swom according to law, states that on June 27, 2009 at 1351 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Krisit L. Heichel, by making known unto herself personalty, defendant at 118 Milky Way Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $62.00 June 29, 2009 SO ANSWERS, +??+IlARK .rl?r. R THOMAS KLINE S RIFF Deputy Sheriff UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 nle? aiii nQs??dren _ c?em Household Finance Consumer Discount Company Plaintiff V. Bradley S. Heichel Kristi L. Heichel Defendant(s) TO: Kristi L. Heichel 118 Milkyway Cumberland, PA 17257 Date of Notice: July 20, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4311 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAf OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION RE UIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL 9ERVICI0 VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA EkRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND TH IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED°FB " _PURPOSE. STUARF WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE rLOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Corporate Suite 200 Cherry Hill, New Jersey 08003-3620 UbREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQIIIRE- ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ? ? adi nQs?+dren _ eom Household Finance Consumer Discount Company Plaintiff V. Bradley S. Heichel Kristi L. Heichel Defendant(s) TO: Bradleyy S. Heichel 118 Milkyway Cumberland, PA 17257 Date of Notice: July 20, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4311 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOU{t PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT RK' OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION RE UIRIDA 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 IbICTAR SENTENCIA EN SU DEBE CONTRA A UN PERDER ABOGADO N OTROS E SI O USTED P NO TTIENE . ABOGADO LL 0 SI ESTA NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO VAYA EN PERSONA 0 LLAME POR tELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND.-?S I? ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USXD FOR URPOSE. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Household Finance Consumer Discount Company 961 Weigel Drive Elmhurst, IL 60126 Plaintiff V. Bradley S. Heichel Kristi L. Heichel 1118 Milkyway Cumberland, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. L°I _ k43 I 1 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Bradley S. Heichel Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Kristi L. Heichel Age: Over 18 Residence: As captioned above Employment: Unknown a Ti e. Sworn to and subscribed Com ny: Household Finance onsumer before me this _;:0 day Discount Company o° f ota is _..i;r RU r=fL r Tyr 1', ?"Ply ttMj" 2003 ka 10 F 1 2. 13 tei? # Alq-ed #? nl? iassul 2?C? ?1a?a?s ?c? Vf't?cG.o? le, UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company =CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Bradley S. Heichel NO. 09-4311 Kristi L. Heichel Defendant(s) TO: Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 NOTICE Pursuant to Rule 236 of the Supreme Court of Pe ylvania, ou are hereby notified that a Judgment has been enter ga' in the above proceeding as indicated below. rot ry 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, Esquire At this telephone number: 856-669-5400 olUmy R UDREN LAW OFFICES, P. C. MARK J. UDREN, ESQUIRE - ID #04302 SWART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION 961 Weigel Drive =Cumberland County Elmhurst, IL 60126 Plaintiff :MORTGAGE FORECLOSURE V. Bradley S. Heichel :NO. 09-4311 Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES As set forth in Complaint Interest Per Complaint From 5/13/09 to 7/31/09 Late charges per Complaint From 5/13/09 to 7/31/09 $213,519.86 4,560.00 273.42 TOTAL $218,353.28 TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Bradley S. Heichel and Kristi L. Heichel 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: I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY U Att net's for 1a- in-MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES QARE /HEREBY ASSESSED AS INDI ED DATE : 300 PROTHY UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU; - ID #04302 - ID #45362 - ID #34576 - ID #75860 LRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsOudren.com Household Finance Consumer Discount Company Plaintiff V. Bradley S. Heichel Kristi L. Heichel Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-4311 PRAECIPL FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 8/1/09 to Date of Sale December 9, 2009 Ongoing Per Diem of 57.00 to actual date of sale including if sale is held at a later date (Costs to be added) $218,353.28 7,467.00 UDR JVULAW O?F/F/I?CESES/, P .C. BY !/A U[L /l/IiY/l/ Attorneys for Plafritiff- - MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -t , Ca U? Ct UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer €COURT OF COMMON PLEAS Discount Company =CIVIL DIVISION Plaintiff ":Cumberland County V. Bradley S. Heichel =NO. 09-4311 Kristi L. Heichel 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: July 31, 2009 UDREN LAW OFFICES, P.C. BYcmmj,q 01hip Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -I- it Date: Bradley S. Heichel Kristi L. Heichel Loan #0015328370 MJU #09050172-1 6E : Company: Household inance Consumer Discount Company F' 2 0 0 9 t1i? ? 0 F ' 2: 13 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinga@udren.com Household Finance Consumer =COURT OF COMMON PLEAS Discount Company ;CIVIL DIVISION Plaintiff €Cumberland County V. :MORTGAGE FORECLOSURE Bradley S. Heichel :NO. 09-4311 Kristi L. Heichel Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDR N? L?AWnO/jF/FI?CyE/S?,r BY /? /A /, At5orneys for Flizrintif f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE FILL' 2003 AW"i 11 0 Pi ?? ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff =Cumberland County V. ?MORTGAGE FORECLOSURE Bradley S. Heichel NO. 09-4311 Kristi L. Heichel Defendant(s) C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to, the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDR LAW OFFICES, P.C. BY Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE FILE: C N ^= oTl?qy 2'1 ?9AUNG ?0 Pr 2- I V UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE'CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com Household Finance Consumer ;COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff €:Cumberland County V. :MORTGAGE FORECLOSURE Bradley S. Heichel NO. 09-4311 Kristi L. Heichel Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Household Finance Consumer Discount Company, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 118 Milky Way, Cumberland, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Bradley S. Heichel 118 Milky Way Cumberland, PA 17257 Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 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 Household Finance 961 Weigel Drive Consumer Discount Company Elmhurst, IL 60126 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 Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 118 Milky Way Cumberland, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 31, 2009 UD NSVJY" . LAWOFFICE ESS/, P ..C .. BY1. A/?,k Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ?i} C ,1- ?r, ,rya ?t r??" ?;;,:, .. ., /[( ? J?... RJR ii,rM 1 ???? 1?3'^ .A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Bradley S. Heichel :NO. 09-4311 Kristi L. Heichel Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 Your house (real estate) at 118 Milky Way (Southampton Township)Cumberland, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $218,353.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE'YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU ATTORNEY FOR PLAINTIFF - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer Discount Company Plaintiff V. Bradley S. Heichel Kristi L. Heichel Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4311 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Bradley S. Heichel and Kristi L. Heichel PROPERTY: 118 Milky Way, Cumberland, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 9, 2009, 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. ALL THAT CERTAIN TRACT OF REAL ESTATE SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN TO BE SET AT THE NORTHWESTERN CORNER OF LOT NO. 28; THENCE ALONG COMMON LINE OF LOT NO. 30 AND LOT NO.31 NORTH 49 DEGREES 36 MINUTES 01 SECONDS EAST, 101.00 FEET TO AN IRON PIN TO BE SET AT THE NORTHEASTERN CORNER OF LOT NO. 30; THENCE ALONG MILKY WAY, SOUTH 38 DEGREES 46 MINUTES 47 SECONDS EAST, 106.03 FEET TO AN IRON PIN TO BE SET AT THE SOUTHEASTERN CORNER OF LOT NO. 30; THENCE CONTINUING ALONG MILKY WAY AND ONTO BARNHILL DRIVE ALONG THE ARC OF A CIRCLE BEARING TO THE RIGHT HAVING A DELTA ANGLE OF 88 DEGREES 22 MINUTES 48 SECONDS HAVING A RADIUS OF 35.00 FEET, AND ARC DISTANCE OF 53.99 (THE CHORD OF SAID ARC EXTENDING SOUTH 05 DEGREES 24 MINUTES 37 SECONDS WEST 48.79 FEET)TO AN IRON PIN TO BE SET; THENCE ALONG LOT 30 AND BARNHILL DRIVE SOUTH 49 DEGREES 36 MINUTES 01 SECONDS WEST, 63.53 FEET TO AN IRON PIN TO BE SET; THENCE ALONG THE COMMON LINE OF LOT NO. 30 AND LOT NO. 53 NORTH 40 DEGREES 11 MINUTES 22 SECONDS WEST, 140.00 FEET TO AN IRON PIN TO BE SET, BEING THE POINT AND PLACE OF BEGINNING. CONTAINING 13,653 SQUARE FEET AND BEING LOT 30 PURSUANT TO THE HAMPTON HILLS, PHASE I FINAL SUBDIVISION PLAN, DATED FEBRUARY 2, 1996, AND REVISED MARCH 1, 1999, PREPARED BY MARTIN AND MARTIN, INC. RECORDED ON OCTOBER 5, 2001 IN THE OFFICE OF THE REGISTER & RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA AT VOLUME 84, PAGE 14. SUBJECT TO ALL RIGHTS-OF-WAY, RESTRICTIONS, EASEMENTS, CONDITIONS, AND SET BANK LINES OF RECORD, INCLUDING BUT NOT LIMITED TO THOSE STATED IN THE AFOREMENTIONED SUBDIVISION PLAN. BEING KNOWN AS: 118 Milky Way, Cumberland, PA 17257 PROPERTY ID NO.: 39-14-0169-097 TITLE TO SAID PREMISES IS VESTED IN BRADLEY S. HEICHEL AND KRISTI L. HEICHEL, HUSBAND AND WIFE BY DEED FROM HAMPTON HILLS DEVELOPMENT COMPANY, A PARTNERSHIP DATED 12/30/02 RECORDED 01/07/03 IN DEED BOOK 255 PAGE 1210. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N0094311 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff (s) From BRADLEY S. HEICHEL KRISTI L. HEICHEL (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $218,353.28 L.L. $.50 Interest FROM 8/1/09 TO DATE OF SALE DECEMBER 9, 2009 ONGOING PER DIEM OF $57.00 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $7,467.00 Atty's Comm % Atty Paid $181.00 Plaintiff Paid Date: 08/10/2009 (Seal) REQUESTING PARTY: Name: CHANDRA M. ARKEMA, ESQ Address: UDREN LAW OFFICES WOODCREST CORPORATE CENTER 111 WOODCRST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTFF Telephone: 856-669-5400 Supreme Court ID No. 203437 Due Prothy $2.00 Other Costs TO BE ADDED Curtis R. Long on By: Deputy OFFICES P C ATTORNEY FOR PLAINTIFF UDREN LAW . . MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Household Finance Consumer '-'COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. Bradley S. Heiche Kristi L. -Heichel -- NO -09-43-11 Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an order directing service of the Notice of Sale upon Defendant(s), Bradley S. Heichel -and Kristi L. Heichel, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant (s) at 118 Milkyway, Cumberland, PA 17257, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 2. Process was unable to be served at the forwarding address provided by the Sheriff at P.O. Box 72, Smoke Run, PA 16681, as service cannot be attempt(d at such an address. 3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit B. 4. Said investigation was unable to determine an alternate address for said Defendant(s). 5. 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 Notice of Sale by regular mail and certified mail, and by posting the mortgaged premises upon said Defendant(s), Bradley S. Heichel and Kristi L. Heichel. UDR9 T LMr-aPhICES , P. C. BY: ' Attorne s for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ` LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -LOUIS A. SIMONI, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-54QO, pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County V. Bradley S. Heichel Kristi L. Heichel NO. 09-4313 Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant (s) has been made as evidenced by the attached Af f idavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN ES, P.C. BY: Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -"LOUIS A. SIMONI, ESQUIRV' r Sheriffs Office of Cumberland County R Thomas Kline Sheriffo?u?r Qt«mbe f? Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OF THE `,ERIFF Edward L Schorpp Solicitor Household Finance Consumer Discount Co. vs. Bradley S. Heichel Case Number 2009-4311 SHERIFF'S RETURN OF SERVICE 09/25/2009 04:10 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09/25/09 at 1610 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Bradley S. Heichel and Kristi L. Heichel, located at, 118 Milky Way, Shippensburg, Cumberland County, Pennsylvania according to law. 09/25%2009 0410 --PM-- R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Bradley S. Heichel, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Bradley S. Heichel, property address is vacant, defendant left a forwarding of P.O. Box 72, Smoke Run, PA 16681, but no physical street address for service. 09/25/2009 04:10 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kristi L. Heichel, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Kristi L. Heichel, property address is vacant, defendant left a forwarding of P.O. Box 72, Smoke Run, PA 16681, but no physical street address for service. r EXHIBIT A Page 1 of 2 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 09050172-1 Attorney Firm: Mark J Udren & Associates Case Number: Subject: Bradley S Heichel and Kristi L Heichel AXA• Brad Heichel, Bradley Heichel, Bradley Scott Heichel, Christy L Michaels, ' Kristi L Michaels Last Known Address: 118 Milky Way Shippensburg, PA 17257 Sandra Krekeler, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of Location Specialist for Players National Locator. 2. On October 22, 2009 I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION A. SOCIAL SECURITY NUMBER(S): 174-66-xxxx 186-58-xxxx B. EMPLOYMENT SEARCH: We were unable to verify current employment for Bradley S Heichel and Kristi L Heichel. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Bradley S Heichel and Kristi L Heichel is 118 Milky Way, Shippensburg, PA 17257 with no valid home number. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing for Bradley S Heichel and Kristi L Heichel. We called (717) 477-0829 and spoke with a relative who stated Bradley S Heichel and Kristi L Heichel have moved from 118 Milky Way, Shippensburg, PA 17257 but refused to release any other information. We called (717) 477-8750 and spoke to a relative who stated Bradley S Heichel and Kristi L Heichel moved from 118 Milky Way, Shippensburg, PA 17257 but refused to release any other information. INQUIRY OF NEIGHBORS We were unabkm to contact any neighbors to confirm any other information for Bradley S Heichel and Kristi L Heichel. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE: EXHIBIT B Page 2 of 2 As of October 19, 2009, the National Change of Address (NCOA) has no change for Bradley S Heichel and Kristi L Heichel from 118 Milky Way, Shippensburg, PA 17257. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license information for Bradley S Heichel and Kristi L Heichel. OTHER INQUIRIES A. DEATH RECORDS: As of October 19, 2009, the Social Security Administration has no death record on file for Bradley S Heichel and Kristi L Heichel and/or A.K.A.s under the social security number(s) provided. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None found. C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT A. DATE OF BIRTH: Bradley - July 1970 Kristi - September 1973 AFFIANT Sandra Krekeler S and sw4fi to before o c 22, 2009 • NOTIE?-L Kristine M. Sary Public St. Louis Couf Missouri My Commiss9!2!2010 Commissio8428885 Y PUBLIC Players National Locator, 14444 Manchester Road, Manchester, MO 63011 Phone: (636) 230-9922 Fax: (636) 230-0558 r, VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make 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/her 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 unsworn falsification to authorities. Date: November 2, 2009 UDRE T:4 ES, P.C. BY: Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -LOUIS A. SIMONI, ESQUIRE r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company ?CIVIL DIVISION Plaintiff :Cumberland County V. Bradley S. Heichel Krist L Fieichel---- - -- - -NO. 09-4311 Defendant(s) CERTIFICATE OF SERVICE I, hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: X Regular First Class Mail Date Served: November 2,.2009 TO: Bradley S. Heichel Kristi L. Heichel 118 Milkyway Cumberland, PA 17257 P.O. Box 72 Smoke Run, PA 16681 UDR OF ICES, P.C. BY: Attorne for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE --LOUIS A. SIMONI, ESQUIRE +?F ' Hr: F 0T F'-')x,,X)TA?RY 2009 NOY -3 AM 1 i * S? 4 Cuav,L.; ,,. a NOV 0 4 20091 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Household Finance Consumer Discount Company Plaintiff V. NO. 09-4311 Bradley S. Heichel Kristi L. Heichel Defendant (s) O R D E R AND NOW this `'l , day of Aja.c..Gcf- , 2009, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of --the Not-ice- of--Sale-- ane3A a-11 SU Sequent- p-leadings on Defendant (s) , Bradley S. Heichel and Kristi L. Heichel, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known addresses of Defendant(s), Bradley S. Heichel and Kristi L. Heichel, at 118 Milkyway, Cumberland, PA 17257 and P.O. Box 72, Smoke Run, PA 16681 and by posting the mortgaged premised located at 118 Milkyway (Southampton Township), Cumberland, PA 17257. BY THE COURT: J. r FUa--ut Hu`E THr I rent! IA Y 2009 NOV -S AN 11: 10, SPY e"LLECL A - -Y ?. • Ti r'YlIAJI ' UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff ':Cumberland County V. Bradley S. Heichel Kristi L. Heichel ::NO. 09-4311 Defendant(s) 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: November 10, 2009 Bradley S. Heichel Kristi L. Heichel 118 Milkyway P.O. Box 72 Cumberland, PA 17257 Smoke Run, PA 16681 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: November 11, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys ;efr'Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE NOV P70090 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Household Finance Consumer Discount Company Plaintiff v. NO. 09-4311 Bradley S. Heichel Kristi L..Heichel Defendant(s) O R D E R AND NOW, this '7 ` - day of NQVF rrti Fl2,__ 2 0 0 9 , upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of - - - --- the Not-i-ce-of-Sale--- ands-&14---subsequ-ent-p3-eadings on Defendant (s) , Bradley S. Heichel and Kristi L. Heichel, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known addresses of Defendant(s), Bradley S. Heichel and Kristi L. Heichel, at 118 Milkyway, Cumberland, PA 17257 and P.O. Box 72, Smoke Run, PA 16681 and by posting the mortgaged premised located at 118 Milkyway (Southampton Township), Cumberland, PA.17257. BY THE COURT: J. .. r s iws it, Caus.;62 pa f H O Ff . " P, o p fD ct W FJ- 5°e r N x old p. rn M 0) F-' ao H O O M to =c°1°Jo p O ?J F N 0 A 111M - -------- Z .n -0 . o P- D- r-I r r-I?a Er Q' m m Postage $ N ° M ° cermw Fee - Postmerh C -3 p p (Endo?semerd ReQuirod) . Here C3 0 Restricted Delivery Fee _a ..a pxWesment Rsq ArsM r-I rl n r1 r-l Total Postage & Fees p p o ° ° r? r? ; ----- Krlsti L. Heichel --- - ' Box No. Z P.O. Box 72 -..----- ; ziP+a stm Smoke Run, PA 16681 Hasler T 8 L n Q1 N1 p tp ? ?fl i © N ? p ?i p mw ,fa N n? O W jD L 8N A ' 1 C iLr Q' a a a ru w I:-j Lnn 0' s? '2Odd PUB 80dV 01 PessOAPPe 118w u0 elgellese IOU 31 u0lj9wruWl IVseilsp 013393381euulul •AiInbul ue Oul4ow uega 111ussimpun idiom sl4l 9A88 :1NY1110dnl 'llew PUB e0eleod tMm lum)gp Pue 4=M 'Pepeeu Wu 91 idpow 1-lire oto POW ese?d esa?ald Poj% s1dic a PeNN+?e'J , %o ? o N ¦ eta Utah eogdllew w4 Wew ro Wep e4t esIAPV*Pe=I+o?¦ A ro eeemppe e4t of pea wager eq rtew r(r= 'get RUOWPe pueeq Al ¦ nbei sl 1dlem IIeW peWso inoA uo Weugsod •Sdsn e'idleow wtgeu a rb ee rol AARM a%a "Isow of i?eMor?ell goelcillow eet "rel w of o6spuoed ggwlddee?sppe pue epN? 941 of (tt96 ? sci) to e d W poperilm eq ??H 4190rd WPM Muq Pe Lm jo.1 ¦ Ad 'ileW PowlsJ 411a3 SI 39vd aowuml ON ¦ q # - IF" Pe9PW9 ¦ ®IIeW eqA'N0 ereeA oep rot emAms mmd sLa Rq idsq Am m to Pme v ¦ eoeldllew moR J(4 nWgm q enqun v ¦ PS Form 3800, June 2002 Arrow) 40m BUIPW v ¦ :39PMad 118N PMIJ93 wf 1.4 14 O O K o Nt OD A) V m 1-1 p- (D D L< J !A? x r- t n N ? r J m 1 N Fl U1 J H r I? rn O O C :r -& ?ZAIAZ 0? T 3i wOmC") " I us F ) s ccl 00 ..n ..G rA m,m s C M CwWad Fee Z P o * 3 O1 O o na I C3 a Figsbfc d DeRvery Fee - .01-0 (EmW emm,c awns! rl r-l r-q r-9 $ Postage & Few TOW Ln Cl C3 C3 a SwW TO aradiey S. Helchel ----------------------- P Box.W ` 118 M ky way crr; s z,R+a Cumberland PA 17257 C ? O N 0 i? LA ? C. D ao m w c? 1p ? 0 Wrobi X a w (D v 0 *C N M Fe rn ? 01 (D Oo F-' N O _ O -4z mA 13 '0 rm?? Z- U-4) 6 a; to C) m'm i PT CERTIFIED ?JA ? 'J3 ! -0 ?..... . a ; -0 [`- f r- . -?_ ! . Q-, ' c- r--? MI m ! postage r ? ru O O a;rs M ! C3 Here (ErK Rlorssnis?t Requhed) C3 I o aew?ciea Fae ? ,? , ..o FFrMorssmeM Requlredl ? .?.....?. rl r-i r-9 r-1 Total Postage & Fees $ --?? m Ln o Cal 0 Bradley S. Helchel .---------------- ----- - ?` Box 72 --- - P O - - - - - I' & . . o.POeoxnw. 5i §ffi4 ---- Smoke Run, PA 16681 -- ------- - ----------- r]??Vr Hasler C t EaH ? - , o ? ` Q rn ? (A 0 3 N ! o ? 4 ? $ to I C) mw N rn a ,. ? W O m 0 x to ?J C to Lr Ir C C C M LL -9 Q LL 'sOdd PUB sadv of Pass llew us 9lgelleAe lou sl uolll2WJOluI OA119P 93 229392 391 •tilnbul us bulgew usgtA 31 luesad pus ld193w slgl 9Ae8 :1NVld 'Ilw pug aBaPod WM legel )qP pus tioupp'pepeeu jou el idle IIBW Polifli etp uo s N '?Pl+ewieod col eolpo leod 6yl 3e --wa GUA luese?d `pe,reep sl ydlaoe? lls1A1 peypie0 eyi UV W o 9yi UAM aoeldllow eyi K+ew jo Sta L'We= # 8.089 1 jo eesmppe eyi o; peyw>w eq Aw AmNlep 19% ppe si idiom IIBW pellluwo jm A uo vvinead ftdSil s 'ldlem wnw eu?ldn J(4 jewm 0% a 6400 gL *.Pwnbed ytMe Q W eoeldllw MUOPU3 eyi SAW q oftpwd elgeopdds PPa pue apple eyi of (lt9E ujoA-Sd) ids wniey a y0ape eieldwoo eeaad ' aoay wnley MW of *AA&, lo;oaid epu peisenbeJ eq = maiey a eel Ruamppe us. 'IRW jod 'tmw pepe0 mm 0301 S1 3gvH3Aoo 3oNVW $N1 si PAR Jou 91 on POW ?!aW A1N0 w s MW . 7 SAGA Oft xl GOINGS Ind wa Aq ideal Am"op to pmoe eoeldllew jnM jcq Jeululapl enblw PS For, 3000, June 2002 McMw) HOW A U :sSnAaa H O OD P- m 3 rrr n ?• N- H F P) 7C r a P) m F-' m N N (ri C.) C9 -- Cv = 7D m w* Nz E.Dc 0 $ n ¦ -- o!a -0 ; -0 r?- r- i ir E m;m Postage s ru ! ru 0 1 O Cerftd Fee - C3 (M ?? ¦? O 1 O RetumReceiptFee Posbnark (Endoreemsnt Required) Here -- ? i C3 ReatrkXed DeRYery Fse r: I r :l (Endoreerrrent Requred) r? I rl Total Postage & Fees ?s¦? Ln Ln C3 C3 o ° ! ° KrhM L. Heichtal N %ipi7c?6:: _ -------------- orPOSkixAb. 118 Mllkyway 15W-sr?re WA.. Cumberland, PA 17257 ---------------, r Hasler c E to C) Cc) (D 0 CJI N 3 q (? a 03 m w rn 4 N 4 C.0 OD I ..A ? j N 3 ?I a C C Lr Q' C C C C n U J 1 Q 1 c : pus sodr 01 pesse# llew UO elQellsAS;OU Sl U0l eUUO{U? aAllop 0{ $Sasse leui •tilnbul US Oul?lew uegm 11 Wosew? pus ldlesei 311111 MS :1NY180 'flew pus ofteod WIM legal xy#e pus 4oaieP -woou #ou 91 idloo !!lam 0444 lu2e?d?eseoue ?I?ew#sod a #I 'QuPNauAaod ?W eo11W isod e4l Pi e augsad a la Pejlsep 011dleos? IIaW Pe?,0,0?Jue4?# uo VWGWGWOPL 04# 44M eoeldliew e4i 4ew jo )pep "A. ea1A Vow Pezl?otp a a PI J0 sesmppe eta of Pelomw eq 6ew Amwlep 'ee# leuoplppe us( x s! idiom lion mweo inert uo veugaod eSSn B idiom w? SMIMP JC4 Jen1aM Del a eel0ow ol',Paoenbea 4904U- =z eoe1d11ew eoropu3.0 a4i Je? ay eBelsod elge*ft ppe peue?e?MM 49C wmJ Sd) 94M wnl s 4090 pus GPO= sobs to Toof ad ePlwojd W Pelsen be? e4 Aew #aiwe us x ld ?y e ? ppps( JoA 'lion Pe81Ueo 411 AoUd S1 ao d o3 ns?o 'I o IBAa #OV & flan PeUMe '®I!Bn Aw p???A? ? #eelx sweA 0*4 X4 GOINGS laleod eta kl ldq AjoNlep #0 px>ve? eoeldliew most xu jeypuepl enblun PS Form ww, dune mm (Revelers) ;38PtAaidiom 1119911 ? 1. ? N ? W r o cr 'F' O K ..n N co _ ?o 2 tv N • ? W 0 t I Z W o c W n ?. C m -I A 0 O i N ? W .p. A co 0 ° Z ' ?K O ' 3 D " o p7 0 (D 3Oci o Qrs?rm"c a = VC CA `° ° r- 7o0 N Z 01 Z m 7? w1 N = 4 Sr t0?i mcn < c? -v y ? a OD c 3 r a a m ?a5 +. 016H26519216 ? J L $01.680- 1: 4-?V, }tltySa Mailed From 08003 US poSTAGE 0 n, ?3'o m w $m m m ?p K N N ? ? ; C ? m O O ? m c 0 0 ? m c 2s p ? 7 m N N G n F'a % ??Gm can ?a ao"Hm TDoT?3 N ? ? ,? n W v3°°yGW r ? o a v c ? ? W n41 m m.H? ?x 3?3 `"? m m a W ? <l ? K ?N W ? O ?a UN a tD ?' 7 N N y C 0070 m ?mZ OD 7-om ANN I w ? C. d 0 Q Q? n N m -o N Q ? ? N rn?m3 Tp 3 N G w fl??3oj c c a o c c G n F a m coo C N C 6 ?: C? co S• =? N O(p 3 m aCD 0 N (?Q a 3 R 0--C W Co t' T 73 N 0 W N O S SIR N N N co v T N N =' N ;n N 115 C ?;," wy vM UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Household Finance Consumer :COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION ,Cumberland County Plaintiff V. NO. 09-4311 Bradley S. Heichel Kristi L. Heichel Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 17, 2009 UDREN LAW-,OFFICES, P/. C . BY: ?'?1761-7,& )f Attorneys for Plaintvf MARK J. UDREN, ESQ E STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE NOV O d 20091 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Household Finance Consumer biscount Company Plaintiff v. `N0. 09-4311 Bradley S. Heichel Kristi L. Heichel. Defendant (s) O R D E R AND NOW, this q44- day of Node---n i s"ZI , 2 0 0 9 , upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of - ------ the-33eti-ce-ot--Sale-- and-al-l-subsequent-p-l-eadings on Def-endant (s) , Bradley S. Heichel and Kristi L. Heichel, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known addresses of Defendant (s), Bradley S. Heichel and Kristi L. Heichel, at 118 Milkyway, Cumberland, PA 17257 and P.O. Box 72, Smoke Run, PA 16681 and by posting the mortgaged premiset located at 118 Milkyway (Southampton Township), Cumberland, PA 17257. BY THE COURT: I ZU 4Z-4c?s d .,r ?•l ?% 34'.{?'?h?i ?1:..=.'-..:.? r??1t9?('* +?...:. st.? !. °IY R AQU Of S&ld COT jaX--QCaNs.;e, P& Household Finance Consumer Discount Company, et. al., Plaintiff(s) VS. Bradley S. Heichel, et. al.. Defendant(s) UDREN LAW OFFICES Ms. Henn! Crommarty 1 I I Wooderest Rd. Ste 200 Cherry Hill, ltiJ 08003-3620 Service of Process by APS International, Ltd. 1-804-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, NIN 45439-3122 APS Pile #: 10033641001 AFFIDAVIT OF SERN71CE -- Individual Service of Process on: Kristi L. Heichel, by posting Court Case No. 09-4311 State of. t-?5 'V 24y, ) ss. County of. I tj Name of Server: ' _;1 K- Vert undersigned. being dull sworn, deposes and says that at the time of service. s!h was of legal age and was not a party to this action-, Date/Time of Service: that on the 10 day of ?Ct' - 20 0. at r` o'clock AM i Place of Service: at 118 Milky Way (Southampton Twp) -,in Cumberland, PA L7257 Documents Served: the undersigned served the documents described as: Notice of Sheriff s Sale of Real Prop", wd Order (2 copies) Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Kristi L. Heichel, by posting Person Served, and Method of Service: -. B personally delivering theist into the hands of the person to be served. By delivering there into the hands of a person of Suitable age, who verified, or who upon questioning stated, that helshe resides with Kristi L. Heichel, by posting t j `_ M K_ at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving; Documents: Sex - Skin Color hair Color. FFacial Hair Approx. Age. Approx...Heighi ::approx. Weight To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares uncjer pen tkof perjur4? Subscribed and sworn to before me this t that fi e zoing is u o rrec day of 20 0 L Si?*??atearr of Server tioian Public (Cornrnission Expires) d APS International, .Ltd. SEAL TY LIN COUNTY ov 1Q, 2011 Houscholti Finance Consumer Discount Company, et. at- Plaintiff(s) v$. Bradiev S. Heichel, et, at.. Defendant(s) UDREN LANV OFF1CF S Nis. Henni Crommarty l! t Woodcrest Rd, Ste 1.00 Cherry [fill. ltiJ 08003-3620 a Service of Process by APS International, Ltd. 1--800-328-7171 .BPS International Plaza 7800 Glenroy Rd. ;Minneapolis, NIN =5439-3122 APS File #: 100336-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Bradley S. Heichel, by posting Court Case No. 09-4311 State of t ajY ss. i C ounn L& a { ?v Name of Server: ? L, uatdersi"ed, being duly sworn, deposes and saes that at the time of sFrvicc. s/he was of legal age and was not a party to this action; f^e Datcll'ime of Service: that oil the l 0_k day of kye k- r(_ 20 at ` o'clock A-'vl ['lace of Service: Document 'served: Service of Process on: at t 18 ttilkv Way (Southampton Twp) -in Cumberland, PA 17357 the ut.aersagned served the documents described as: Notice of Sheriffs Sale of [teal Property Ar/ Order (2 copies) A true and correct copy of tl«• aforesaid document(s) was served oil: Bradley S. Heichel, by posting Person. Served. and By personally delivering them into the hands of the person to be served, metitod of Service: B delivering theta into the hands of a person of suitable a?c, who verified, or who upon questioning stated, that lic'she resides with Bradley S. Heichel, by posting 6- at the place of service, and whose reialion;hip to the person is: Description of Person The per-,on receiving documents is descrih d a follows- Receiving Documents: c , . Skin Color Ht i! Color. Facial Hair. ;npr ,. -,e Approx. l-i-."i' Appr}t.''tt'ei?- I ?the best. ofnty hit;,,? i ?ge and beli,-I'..?aid person was not et3?t cd in the US Military at the time of sere ice. Signature of Server- C;nder,?i,!iicd declares under penalty- of perjury Subscribed and svyorn to before me this r teal tlte,fo -gettng k? taste ;tttd ct. - ' Mkt--,^°* v c a ^ Y (? - r , r ------------ i .«_ of Serter l r, Public ; t animts iasn l:?nirc i .-\ TS International, Ltd. NOtApIAL SEAT. LUCIL LE Hf CARTY tlataty Pub'lac LETTERKEP It,dY rvr"r. FiTANKLIN COUNTY MY omt tls i. -, . xp res NOv 70. 2011 FILED-i;,?,"ICE TpE '12.57 Zd 9 N?? Q pm cl ae ,l?`riLZF v?tt SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff '~tk ~~ ._ _ _.__ _ . _t-, , - -Fr.r ,, . L. _ , - , . . Jody S Smith Chief Deputy Edward L Schorpp Solicitor Household Finance Consumer Discount Co. Case Number vs. Bradley S. Heichel 2009-4311 SHERIFF'S RETURN OF SERVICE 09/25/2009 04:10 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09/25/09 at 1610 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Bradley S. Heichel and Kristi L. Heichel, located at, 118 Milky Way, Shippensburg, Cumberland County, Pennsylvania according to law. 09/25/2009 04:10 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Bradley S. Heichel, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Bradley S. Heichel, property address is vacant, defendant left a forwarding of P.O. Box 72, Smoke Run, PA 16681, but no physical street address for service. 09/25/2009 04:10 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kristi L. Heichel, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Kristi L. Heichel, property address is vacant, defendant left a forwarding of P.O. Box 72, Smoke Run, PA 16681, but no physical street address for service. 11/16/2009 Property sale postponed to 1/6/2010. 01/06/2010 Property Sold to Mortgage Company for 1.00 on 1/6/10 01/11/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 9, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Chandra Arkema, on behalf of Household Finance Consumer Discount Company, 961 Weigel Drive, Elmhurst, IL 60126, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ SHERIFF COST: $969.61 January 11, 2010 SO AE ,~;~~ ,Ts~.`.,~,-~ . R(~p~'NY R ANDERSON, SHERIFF ~ y `~ ~0 ~~ ~~~~ ~,~,oD Co L ATTORNEY FOR PLAINTIFF UDREN iaAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com Household Finance Consumer :COURT OF COMMON PLEAS Discount Company =CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Bradley S. Heichel NO. 09-4311 Kristi L. Heichel Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Household Finance Consumer Discount Company, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 118 Milky Way, Cumberland, PA 17257 ~~~~ 1. Name and address of Owner(s) or reputed Owner(s): Name Address Bradley S. Heichel Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 118 Milky Way Cumberland, PA 17257 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 Household Finance 961 Weigel Drive Consumer Discount Company Elmhurst, IL 60126 ~ r ~ 5. Name and address on the property: Name None Address 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 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants Address 118 Milky Way Cumberland, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 31, 2009 UDR. N LAW OFFICES,, P . C . Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE of every other person who has any record lien 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(~udren.com Household Finance Consumer .COURT OF COMMON PLEAS Discount Company =CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Bradley S. Heichel NO. 09-4311 Kristi L. Heichel Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bradley S. Heichel 118 Milky Way Cumberland, PA 17257 Your house (real estate) at 118 Milky Way (Southampton Township)Cumberland, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $218,353.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN~LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Household Finance Consumer =COURT OF COMMON PLEAS Discount Company :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Bradley S. Heichel €NO. 09-4311 Kristi L. Heichel Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kristi L. Heichel 118 Milky Way Cumberland, PA 17257 Your house (real estate) at 118 Milky Way (Southampton Township)Cumberland, PA 17257 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $218,353.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MPaY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS'EVEN~IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF REAL ESTATE SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS BEGINNING AT AN IRON PIN TO BE SET AT THE NORTHWESTERN CORNER OF LOT NO. 28; THENCE ALONG COMMON LINE OF LOT NO. 30 AND LOT N0.31 NORTH 49 DEGREES 36 MINUTES Ol SECONDS EAST, 101.00 FEET TO AN IRON PIN TO BE SET AT THE NORTHEASTERN CORNER OF LOT NO. 30; THENCE ALONG MILKY WAY, SOUTH 38 DEGREES 46 MINUTES 47 SECONDS EAST, 106.03 FEET TO AN IRON PIN TO BE SET AT THE SOUTHEASTERN CORNER OF LOT NO . 3 0 ; THENCE CONTINUING ALONG MILKY WAY AND ONTO BARNHILL DRIVE ALONG THE ARC OF A CIRCLE BEARING TO THE RIGHT HAVING A DELTA ANGLE OF 88 DEGREES 22 MINUTES 48 SECONDS HAVING A RADIUS OF 35.00 FEET, AND ARC DISTANCE OF 53.99 (THE CHORD OF SAID ARC EXTENDING SOUTH 05 DEGREES 24 MINUTES 37 SECONDS WEST 48.79 FEET)TO AN IRON PIN TO BE SET; THENCE ALONG LOT 30 AND BARNHILL DRIVE SOUTH 49 DEGREES 36 MINUTES Ol SECONDS WEST, 63.53 FEET TO AN IRON PIN TO BE SET; THENCE ALONG. THE COMMON LINE OF LOT NO. 30 AND LOT NO. 53 NORTH 40 DEGREES 11 MINUTES 22 SECONDS WEST, 140.00 FEET TO AN IRON PIN TO BE SET, BEING THE POINT AND PLACE OF BEGINNING. CONTAINING 13,653 SQUARE FEET AND BEING LOT 30 PURSUANT TO THE HAMPTON HILLS, PHASE I FINAL SUBDIVISION PLAN, DATED FEBRUARY 2, 1996, AND REVISED MARCH 1, 1999, PREPARED BY MARTIN AND MARTIN, INC. RECORDED ON OCTOBER 5, 2001 IN THE OFFICE OF THE REGISTER & RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA AT VOLUME 84, PAGE 14. SUBJECT TO ALL RIGHTS-OF-WAY, RESTRICTIONS, EASEMENTS, CONDITIONS, AND SET BANK LINES OF RECORD, INCLUDING BUT NOT LIMITED TO THOSE STATED IN THE AFOREMENTIONED SUBDIVISION PLAN. BEING KNOWN AS: 118 Milky Way, Cumberland, PA 17257 ~Y~i. PROPERTY ID NO.: 39=14-019-097 TITLE TO SAID PREMISES IS VESTED IN BRADLEY S. HEICHEL AND KRISTI L. HEICHEL, HUSBAND AND WIFE BY DEED FROM HAMPTON HILLS DEVELOPMENT COMPANY, A PARTNERSHIP DATED 12/30/02 RECORDED 01/07/03 IN DEED BOOK 255 PAGE 1210. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N009-4311 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff (s) From BRADLEY S. HEICHEL KRISTI L. HEICHEL (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $218,353.28 L.L. $.50 Interest FROM 8/1/09 TO DATE OF SALE DECEMBER 9, 2009 ONGOING PER DIEM OF $57.00 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $7,467.00 Atty's Comm Atty Paid $181.00 Plaintiff Paid Date: 08/10/2009 (Seal) REQUESTING PARTY: Name: CHANDRA M. ARKEMA, ESQ Address: UDREN LAW OFFICES WOODCREST CORPORATE CENTER 111 WOODCRST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTFF Telephone: 856-669-5400 Supreme Court ID No. 203437 Due Prothy $2.00 Other Costs TO BE ADDED Curtis R. Lo roth ota By: Deputy Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA Known and numbered as, 118 Milky Way, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: y ~ / ~ ~ ~~~ Real Estate Coordinator ~~~,~-~~i ;, ~ , n ' 4 ~:_ ° s "~:~1 .y ., C ~~ ~~ The Patriot-News Co. '812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e~lahiot-News NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she 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 she 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. PUBLICATION COPY This ad ran on the date(s) shown below: 10/23/09 10/30/09 11/06/09 Sworn to,ahd subscribed before me is da of November, 2009 A.D. Notary Public COMMONyyEALTH OF PENNSYLVANIA Not2eial Seal Sheer L. Kisner, Notary Public C~J' OI Ma-risburg, Dauphin County My Camfnissioro Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries WrIE 1~.1E10Y•4i11 GwN Y~ BrtdlyG S. ff~idlsl KHIf:U L. HNC~1 ,, Atty: ChMdn I-rlcNna ALL THAT CBRTAOA'TRACT OF .REAL. BSTATE STTUATE IN SOt~THAMP'TON TOWNSHIP, ,CUMBERLAND ,COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FALLOW5: , BEGD!iNING AT, AN IRON PIN T?0 BE ,SET AT THE IVORTH9rPSTERN CORNER .OF LOT N0. 28; THENCE ALONG COMMON LINE.DF ,LOT N0. 3Q;AND LGT N0.31 NORTH 49 DEGREES 36 h1INIUTeS Ol SECONDS EAST, 101.00 F~E'PO AN ]ICON PIN TO $E SET AT THE IJURTHBA$ CORNER OF LOT,NO.30; THEATCE ALONG MII.KY' WAY, ,SOUTH 38..DEGREFS ,46 MIlVU'I'ES 47 5ECONDS EAST, 106.03 FEET TO AN IRON ~ TO BE SET.. AT THE SOUTHEASTERN CO)}l~(ER OF LOT N0.30; THENCE CON'TtNUING ALONG MILKY WAY AND ONTO , BARNHII.L DRNE ALONG, THE ARG OF A CIRCLE BEARING' TO THE RIGHT:HAVINGA DELTA,ANGLE OF 88 DEGRfiES 22 MIINUTES,48 SECONDS HAVING A RADNS OF 33.00 FEET, AND ARC DISTANCE OF 53.99 (THE CHORD OF SAID ARC EXTENDING ;SOUTH OS DEGREE9IA MW.tFI'ES 37 SECONDS WEST 48.79 FEET)TO AN IItQN PIN TO $E SET; THENCE ALONGLOT. 30 AND $ARNHII.L DRTyE SOUTH 44 pEG1~AS 36 MINUTES 01 SECONDS: WEST,, 63.53> PEST TO AN IItQN PIN TO BE SE'f;,THENCE ALONG THE COMMON 1.~E OF LU!1' N0.30AND LOT ,NO. °33 N RTH 40 DEGRIsES .11 MIIIUT,ES 21 SLICONDS WEST, 140.00 FEET TO AN IRON:'PIN TO: B$ SET; $EMG THE POINTAND PLACEO'F BBGIIJFIING. ` CONTADtIIIVG 13,653;SQUARE PEEP AND BEING IO'1' 30 PURSUANT. TO. THE HAMPTON `HILLS, PHi~SE I FIIVAL SUBDIVISION PLAN, DATED FEBRUARY 2, 1996; AND REYLSED MARCH. 1; 1999, PREPARED BY MARTIN AND MARTIN, INC. RECORDED ON OCTOBER 5, 2001 IN THE: OFFICE OF THE ' REGISTER RECORDBR OF DEI#DS OF CUMBERLAND COt~JNTx FENNSYLVANU- AT VOLUME 84, PAGE14. StIB]EC'T TG ALL RIGHTS-ORWAY, ~E'9fRICTION&, EASEMENTS, CONDITIONS ANQ SET BANK LIr1ES OF REC6RD, ~ICLUUIING~ $U'I" NOT ~M1TED TO THOSE STATED IN THE AFO1T10~ 8L19DIVLSiON A~.AN: PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 23, October 30 and November 6, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SW6RN TO AND SUBSCRIBED before me this _...6 day of November//, 2009 ~. Notary ._.~ NOTARIAL SEAL DE80RAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Writ No. 2009-4311 Civil Household Finance Consumer Discount Company vs. Bradley S. Heichel Kristi L. Heichel Atty: Chandra Arkema ALL THAT CERTAIN tract of real estate situate in Southampton Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEGINNING at an iron pin to be set at the northwestern comer of Lot No. 28; Thence along common line of Lot No. 30 and Lot No.31 North 49 degrees 36 minutes O 1 seconds East, 101.00 feet to an iron pin to be set at the northeastern corner of Lot No. 30; Thence along Milky Way, South 38 degrees 46 minutes 47 seconds East, 106.03 feet to an iron pin to be set at the southeastern corner of Lot No. 30; Thence continuing along Milky Way and onto Barnhill Drive along the arc of a circle bearing to the right having a delta angle of 88 degrees 22 minutes 48 seconds having a radius of 35.00 feet, and arc distance of 53.99 (the chord of said arc extend- ing South 05 degrees 24 minutes 37 seconds West 48.79 feet)to an iron pin to be set; Thence along Lot 30 and Barnhill Drive South 49 degrees 36 minutes O1 seconds West, 63.53 feet to an iron pin to be set; Thence along the common line of Lot No. 30 and Lot No. 53 North 40 degrees 11 minutes 22 seconds West, 140.00 feet to an iron pin to be set, being the point and place of BEGINNING. CONTAINING 13,653 square feet and being Lot 30 pursuant to the Hampton Hills, Phase I Final Subdi- vision Plan, dated February 2, 1996, and revised March 1, 1999, prepared by Martin and Martin, Inc. recorded on October 5, 2001 in the Office of the Register & Recorder of Deeds of Cumberland County, Pennsylvania at Volume 84, Page 14. SUBJECT to all rights-of-way, restrictions, easements, conditions, and set bank lines of record, includ- ing but not limited to those stated in the aforementioned subdivision plan. 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 HOUSEHOLD FIN C D C is the grantee the same having been sold to said grantee on the 9TH day of DEC A.D., 2009, under and by virtue of a writ Execution issued on the 10 day of AUG, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 4311, at the suit of HOUSEHOLD FIN C D C against BRADLEY S HEICHEL & KRISTI L is duly recorded as Instrument Number 201002433. IN TESTIMONY WHEREOF, I have hereunto set my hand an seal of said office this p2~ day of /~ ,A.D.o?0/(~ Ruder of Deeds riCii ~~ ":,. C a~i•~~~ r 4.1}x, i~.,ali:a~i. F'fi ~y Ca ~ ~ Ezy~~a ~~a Fw-2; r,~;;ay of Jan. 201'