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HomeMy WebLinkAbout09-4985r_ f 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 pleadings@udren.com Taylor, Bean & Whitaker Mortgage :COURT OF COMMON PLEAS Corp :CIVIL DIVISION 13820 Old St. Augustine Road Suite 113-518 :Cumberland County Jacksonville, FL 32258 Plaintiff V. Rodger L. Alfano, Jr. _ Rachel A. Alfano NO. © g (_f 9 4184 Kittatinny Drive ?? / Mechanisburg, PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 e AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Taylor, Bean & Whitaker Mortgage Corp Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 4184 Kittatinny Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Hampden Township COUNTY: Cumberland DATE EXECUTED: 4/14/06 DATE RECORDED: 4/18/06 BOOK: 1947 PAGE: 304 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: I- (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 6/8/09: Principal of debt due $104,094.16 Unpaid Interest at 6.0% from 2/1/09 to 6/8/09 (the per diem interest accruing on this debt is $17.03 and that sum should be added each day after 6/8/09) 2,197.26 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $138.16 and that sum should be added on the first of each month after 6/8/09) (420.88) Late Charges (monthlyy late charge of $25.90 should be added in accordance with the terms of the note each month after 6/8/09) 161.90 Suspense Balance (469.32) Attorne s Fees (anticipated and actual y to 50 o principal) 5,204.71 TOTAL $111,372.83 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program,. Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant (s) herein in the sum of $111,372.83 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY :? A W [ (aI/?./CJVI/'I U17 l L(11J 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 ALL THAT CERTAIN tat or tract of land situate in IlamPden Township, C"nberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit. B.EaBVhVG at a point on the northern right-of-way line of Kttatimry Drive (6' wide private). at the dividing line of Lot #73 and Lot # 74; said point. also being located 72" 2& feet west of the northwest corner of Ktttatirmy Drive and Tussey Court k.. THENCE by the northern right-of-way line of Klttatirary Drive North SZ degrees 02 Minutes 02 seconds West 20.00 fear to a point,' THENCE by line 010t 975 and Passing through center of a partition wall North 07 degrees 57 minutes 58 seconds E2 m100. inutes eer 02 sto a econds point, 7W EN 00 by line of land now or formerly of J P. Roth, South 82 degrees partition wall feet to a point; THENCE by line of Lor 073 and paining through the center of a par South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right--of-wary line of Kittatinny Drive, the place of BEGINNING. CONTAIN3NG 2,000 square feet BEING Lot # 74 an Final Subdivision Plan of AdOw9dn VL-w VMage Phase ly Recorded in Plan Book 60, Page 87B_ Taylor, Bean & Whitaker Mortgage Corp. 1417 N Magnolia Ave Ocala, FL 34475-9078 f g _ 3 UA4AyR60 1 7113 1953 0020 0089 5022 Ms RACHEL ALFANO 4184 Kittatinny Drive Mechanicsburg, PA 17050 Act 91 Notice Take Action To Save Your Home From Foreclosure April 30, 2009 Loan Number: 1036364 Property Address: 4184 Kittatinny Drive Dear Ms RACHEL ALFANO This notice is sent to you in an attempt to collect the indebtedness referred to herein and any information obtained from you will be used for that purpose. If you have previously received a discharge in Bankruptcy, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The Homeowner's Mortgage Assistance Program (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must meet with a Consumer Credit Counseling Agency within thirty (30) days of the date of this notice. Take this notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869). This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion que antecede es de suma importancia y puede afectar el derecho a continuar viviendo en su casa. Si no comprende el contenido de la misma, obtenga una traduccion inmediatamente llamando sin costo alguno a (Pennsylvania Housing Finance Agency) al numero arriba indicado. Podrias ser elegible para. un prestamo a traves del programa llamado "Homeowners Emergency Mortgage Assistance Program", el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. EXHIBIT-A- - - Act 91 - Save Your Home From Foreclosure -Page 2- Statement of Policy: Homeowner's Name(s): Ms RACHEL ALFANO Property Address: 4184 Kittatinny Drive Mechanicsburg, PA 17050 Loan Number: 1036364 Original Lender: Broker Current Lender/Servicer: Taylor, Bean & Whitaker Mortgage Corp. Homeowner's Emergency Mortgage Assistance Program: You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments. If you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (The "Act"), you may be eligible for Emergency Mortgage Assistance. ¦ If default has been caused by circumstances beyond your control ¦ If a reasonable prospect of being able to pay the mortgage payments, and ¦ If you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency Temporary Stay of Foreclosure: Under the Act, you are entitled to a Temporary Stay of Foreclosure on your mortgage for thirty-three (33) days from the date of this notice. During that time you must arrange and attend a face-to-face meeting with one of the Consumer Credit Counseling Agencies listed at the end of this notice. This meeting must occur within the next thirty-three (33) days. If you do not apply for Emergency Mortgage Assistance, you must bring your mortgage account current. The part of this notice called "How To Cure Your Mortgage Default" explains how to bring your mortgage account current. Consumer Credit Counseling Agencies: If you meet with one of the Consumer Credit Counseling Agencies listed at the end of this notice, the lender may not take action against your for thirty (30) days after the date of this meeting. The names, address and telephone numbers of designated Consumer Credit Counseling Agencies for the County in which the property is located are set forth at the end of this notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. Application For Mortgage Assistance: Your mortgage is in default for the reasons set forth later in this notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program application with one of the designated Consumer Credit Counseling Agencies listed at the end of this notice. Only Consumer Credit Counseling Agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. Ddl(PA)v2.2s Act 91 - Save Your Home From Foreclosure -Page 3- 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 notice, foreclosure may proceed against your home immediately and your application for Mortgage Assistance will be denied. Agency Action: Available funds for Emergency Mortgage Assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. Note: If you are currently protected by the filing of petition in Bankruptcy, the following part of this notice is for information purposes only and should not be considered as an attempt to collect the debt. (If you have filed Bankruptcy you can still apply for Emergency Mortgage Assistance) How To Cure Your Mortgage Default - Bring Your Account Current Nature of the Default: The mortgage debt held by the above lender on your property located at 4184 Kittatinny Drive Mechanicsburg, PA 17050, is seriously in default because: ¦ You have not made monthly mortgage payments for the following months and the following amounts are now past due. You are currently due for 03/01/2009. The amount requested below must be remitted within 33 days of the date of this letter. Monthly payments plus late charges accrued: $1,765.62 NSF: $.00 Other: $.00 (Suspense): $469.32 Total Amount To Cure Default: $1,296.30 How To Cure The Default: You may cure the default within thirty-three (33) days of the date of this notice by paying the total amount past due to the lender, which is $1,296.30, plus any mortgage payments and late charges which become due during this thirty-three (33) day period. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Taylor, Bean & Whitaker Mortgage Corp. 1417 North Magnolia Avenue Ocala, FL 34475-9078 Attn: Foreclosure Department You can cure any other default by taking the following action within thirty-three (33) days of the date of this notice. Ddl(PA)v2.2s Act 91 - Save Your Home From Foreclosure -Page 4- If You Do Not Cure The Default: If you do not cure the default within thirty-three (33) days of the date of this notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within thirty-three (33) days, the lender also intends to instruct its attorney to start legal action to foreclose on your mortgage property. If The MortLyaLwe Is Foreclosed Upon: The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorney's, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount due to the lender, which may also include other reasonable costs. If you cure the default within the thirty-three (33) day period, you will not be required to pay attorney's fees. Other Lender Remedies: The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. Right To Cure The Default Prior To Sheriffs Sale: If you have not cured the default within the thirty-three (33) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs sale. You may do so by paying the total amount past due, plus any late or other charges due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. Earliest Possible Sheriffs Sale Date: It is estimated that the earliest date that such a Sheriffs sale of the mortgage property could be held would be approximately six (6) months from the date of this notice. A notice of the actual date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. How To Contact The Lender: Taylor, Bean & Whitaker Mortgage Corp. 1417 North Magnolia Avenue Ocala, FL 34475-9078 Attn: Foreclosure Department 1-800-530-2602 Ddl(PA)v2.2s Act 91 - Save Your Home From Foreclosure -Page 5- Effect of Sheriff's Sale: You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other possess ions could be started by the lender at any time. Assumption of Mortgage: You may or may not (check one) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and cost are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. You may also have the right: ¦ To sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. ¦ To have this default cured by any third party acting on your behalf. ¦ To have the Mortgage restored to the same position as if no default had occurred, if you cure the default. (However, you will not have the right to cure your default more than three (3) times in any calendar year). ¦ To assert the non-existence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents. ¦ To assert any other defense you believe you may have to such action by the lender. ¦ To seek protection under the Federal Bankruptcy Law. A list of Consumer Credit Counseling Agencies serving your County is attached. If you would like to discuss options which may be available to assist you please contact Taylor, Bean & Whitaker's Loss Mitigation Department at 1-800-530-2602. Counselors are available Monday through Friday from 9:00 a.m. until 8:00 p.m. EST. You may also contact the National Foreclosure Prevention Hotline at 1-888-995-HOPE (4673). Sincerely, Default Management Taylor, Bean & Whitaker Mortgage Corp. Mailed by 1st Class mail and Certified Mail Attachment: Counseling Agencies for your County Dd](PA)v2.2s r V June 19, 2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMFOWNE,ROS MORTGAGE ARSISTANC'E PROGRAM (HFMAPI may he able. to help to cave your home- This Notice explains how the pragr2m works This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of 1 t HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Rachel A Alfano Rodger L. Alfano._Jr.._ 4184 Kittatinny Drive Mechanicsbure. PA 17050 0001036364.....--- -- Taylor,Bean ..&.,Whitaker .Mortgage Corporation Federal ._Home _Loan_Mortga2e Conmration__............... _ HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RF, ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE, YOUR HOME. FROM FORECLOSURE AND HELP YOU MAKF, FUTURE, MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS WETiNG MUST OC'C'UR WITHIN NOTICE CAT LET) DHOW TO C1 IRE YOUR MORTGAGE DE-EAT TT TQ? EXPLAINS 14OW To BRING YOT TR MORTGAGF T TP TO DATE CONSUMER CREDIT COUNSELING AGENCIES _ If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telMhone numbers are set torth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelT of your intentions. APPLICATION FOR MORT(t'AC_F. ASSiSTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Page 2 of 2 • Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THF, DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 4184 Kittatinny Drive Mechanicsburg, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthl?Payments of_5785.67 fo_r__March__1,?2009 throngh._June_. _ZM. =._$3142.68..._...._-_......... _ _Monthl?_Late Charges of $25.90_for March_ -, 2009 through_June 1 2009103 60 Other charges (explain/itemize): Uncollected Late Charges = $58.30 __Susense_Balance =..(.5469.32)..._.__..___.__....... --------- ------------ ---------- --...-...-----._..... _TOTAL_AMOLTNT PAST_DUE:._...... ...._._...----------............ - --............. -........... _ ....-.----.-............ -?2i3_- B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if'not ai In iahle.): WA HOW TO CURE. THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 12$-15-26, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P_a=ents must he made either by cash, cashier's check, certified heel, or money order made payable and sent to* You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (De not use if not applieahle ): NA Page 3 of 3 t IF YOTJ DO NOT CURE TAR DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt- This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged prnncM- IF TRKMORTGAGE. IS FORF,CT.OSF.D UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYperiod, you will not he re,uired to pay attorney's fees- OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CURE. THE, DEFAULT PRIOR TO SHERIFF'S SALE. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to nsyLg the total amount then past due, phis ic any late or ether charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as ?_c feed in writing by the lender and haperforming any other requirements under the mortgage. usage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F.ARLIF.ST POSSIBLE SHF.RTFF'S SALE DATE. - It is estimated that the earliest date 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 Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: Taylor. Bean & Whitaker Mortg tg Corporation._ Address: 13820 Old St. Augustine Road Suite 113-518 Jacksonvil e, FL 32258 Phone Number: 866-456-8889 Fax Number: 866-641-6075 Contact Person: _Loss_Mitiation EFFECT OF SHERIFF'S SALF. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGF. -- You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 4 . NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 1 i • • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Page 6 of 6 % . f HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/1512007 10:03:08 AM mudms vounry mterrann 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 Derry 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 r N I, If G? CP r i a G tv 0 Q 0 p y Postal Er ru Er ru CERTIFIED (Domestic Mail Only MAIL, RECEIPT ; No insurance Coverage Provided) _a Ln _U Ln OFF , ICIAL 7USE -o ru -A fU Postage $ cci Certified Fee _ C3 C3 O O C3 Return Receipt Fee (Endorsement Required) Here ^ Postmark CP 20 -? 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H« aoaidl!ew a siopu opu3 •aa{ 19AO3 of abulsod algeoydde ppo pue alo!ue 841 04 ( i WE wood Sd) ld!eoeH 19H a yoelle pue ale!dwoo eseeld 'aouues idieoeH wnleH welgo of fJ6A1!8P oaad aP!Aad of pelsenbei eq Aew;dreoay iun;aye 'ae; !euo!3!pple ue JoH a •!pVy paiels!6eH jo paansul jap!suoo aseeld `s9!genjeA !!eA Pe131.1Ja0 Qm a301AOWd S! 3JHH3A00 30N` unSN! ON ¦ 'pew leu0!lewelu!;o sse!o Aue jo; o1gel!ene;ou sr y8W P913!1a90 ¦ A ,(luoud ao QNgH sse10-lsa!d yl!nn pou!gwo3 aq KINO /Caw AA Pe!43Ja0 ¦ :slapurluat{;ua;lod-j SMOA onnl aol ao!AiaS !elsod eyl-iq idaN NeA!!ep {a Pio3ei V .m eo9!dp9w inoA jol aa!43uep! anb!un V m id!eoaj Bu!1!ew y ¦ :sapiAOad 11eW p81111J83 N 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 so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because 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 knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: L I UU U1,Ll(2?WV1W I UL-, Att rneys 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 (ID OF F1LE?;? 2039 JUL 23 CUPS - ,. 7 9-, .s0 A -#, "re t 5:260 ? 93 • , f ?I Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OFpICF. ':,c t F :RIFF ?^ FILED-=?;'' tar Hr 211119 ': ?$ PM12= 2 Edward L Schorpp Solicitor Taylor Bean & Whitaker Mortgage Corp. Case Number 2009-4985 vs. Rodger L. Alfano, Jr. SHERIFF'S RETURN OF SERVICE 07/24/2009 07:56 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 1956 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rodger L. Alfano Jr., by making known unto himself personally, defendant at 4184 Kittatinny Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 07/24/2009 07:56 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 1956 hours, he served a true copy of the within Complaint in Mortgage: Foreclosure, upon the within named defendant, to wit: Rachel A. Alfano, by making known unto Rodger Alfano, husband of defendant at 4184 Kittatinny Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $53.00 SO ANSWERS, R THOMAS KLINE, SHERIFF July 27, 2009 4eu Sher i f f 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County V. Rodger L. Alfano, Jr. ::NO. 09-4985 civil Rachel A. Alfano 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: August 25, 2009 UDREN LAW FEZCES.L P.C. ! BY : Attorneys for P intiff MARK J. UDREN, UIRE 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. Date '? 2-001 -o;; I ?-- ?' - Name : Mark D. VVilki "M Title: vice Predda t Company : Tayw'sMA Whet Rodger L. Alfano, Jr. Rachel A. Alfano Loan #0001036364 MJU #09060289-1 2H9 AUG 25 AM I I : (118 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp CIVIL DIVISION 13820 Old St. Augustine Road ::Cumberland County Suite 113-518 Jacksonville, FL 32258 :MORTGAGE FORECLOSURE Plaintiff V. Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 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) Rodger L. Alfano, Jr. and Rachel A. Alfano for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 6/9/09 to 8/25/09 Late charges per Complaint From 6/9/09 to 8/25/09 Escrow payment per Complaint From 6/9/09 to 8/25/09 $111,372.83 1,328.34 77.70 276.32 TOTAL $113,055.19 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. W OFFI P. C. Attorneys -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 INDICA DATE : ( .Gj, v Js, o Q PRO O H 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. ARKENA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID,#200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings®ad.ren.com ?a C7 Taylor, Bean & Whitaker Mortgage € COURT OF COMMON PLEAS ; w Corp E CIVIL DIVISION s; 13820 Old St. Augustine Road Suite 113-518 :Cumberland County ' N Jacksonville, FL 32258 Plaintiff .a-z+-r` p V. Rodger L. Alfano, Jr. Rachel A. Alfano . NO. 4184 Kittatinny Drive 7 Mechanisburg, PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 t; Sheriffs Office of Cumberland County R Thomas Kline Sher Ronny R Anderson 0`t Chief Deputy Jody S Smith Civil Process Sergeant OrPIC$ nF F}+, $Rz_RjFF Edward L Schorpp Solicitor Taylor Bean & Whitaker Mortgage Corp, Case Number vs. Rodger L. Alfano, Jr. 20094985 SHERIFF'S RETURN OF SERVICE 07/24/2009 07:56 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 1956 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rodger L. Alfano Jr., by making known unto himself personally, defendant at 4184 Kittatinny Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 07/2412009 07:56 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 1956 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rachel A. Alfano, by making known unto Rodger Alfano, husband of defendant at 4184 Kittatinny Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same, SHERIFF COST: $53.00 July 27, 2009 SO ANSWERS, P 4Nw R THOMAS KLINE, SHERIFF Sheriff /e/5/112yn UDREN LAW OFFICES, P.C. 4UU K 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 PlpadinQs +dr n om Taylor, Bean & Whitaker Mortgage Corp Plaintiff V. Roder L. Alfano, Jr. Racgel A. Alfano Defendant(s) TO: Rodger L. Alfano, Jr. 4184 Kittatinny Drive Mechanisburg, PA 17050 Date of Notice: August 14, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4985 civil 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 AGENHES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO?, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O 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 ANP. IS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE UPID ''THAT PURPOSE. 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. 4VARK 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 n1 pdi no mmudr n nnm Taylor, Bean & Whitaker Mortgage Corp Plaintiff V. Rodqqer L. Alfano, Jr. Rachel A. Alfano Defendant(s) TO: Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 Date of Notice: August 14, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4985 civil YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO?, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED "FOR.=?AT PURPOSE. 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 Taylor, Sean & Whitaker Mortgage Corp 13820 Old St. Augustine Road Suite 113-518 Jacksonville, FL 32258 Plaintiff V. Rodger L. Alfano, Jr. Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 Def endant (s) STATE OF Florida ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO.M _9411 c'Iv( AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF DUVII SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Rodger L. Alfano, Jr. Over 18 As captioned above Unknown Rachel A. Alfano Over 18 As captioned Unknown Sworn to and subscribed before me this,l-7*V-day of SV \? 20 Notar Public above a - Mark nsae Title : Vic Pr idot Company: T Hers&TAh* t HN, S N NUAER MMISSION N DD 899100 MY CO EXPIRES: June 15, 2013 ?' lff? geode! TMu Notary Pubk Undenwftrs 2 A U G 25 Ali l i : 03 4O' ??LS ,_ ;0 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 Taylor, Bean & Whitaker !COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. Rachel A. Alfano :NO. 09-4985 civil Defendant(s) TO: Rodger L. Alfano, Jr. 4184 Kittatinny Drive Mechanisburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of Pen ylvania, ou are hereby notified that a Judgment has been entere a' in the above proceeding as indicated below. of o a y x Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict 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 J UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 7 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant(s) TO: Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of Penn ylvani you are hereby notified that a Judgment has been enter?rotho g u in the above proceeding as indicated below. ry x Judgment by Default Money Ju, Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict 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 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, LSQU' - 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 Taylor, Bean & Whitaker Mortgage Corp Plaintiff V. Rodger L. Alfano, Jr. Rachel A. Alfano Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-4985 civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue writ of Execution in the above matter: Amount due Interest From 8/26/09 to Date of Sale December 9, 2009 Ongoing Per Diem of 17.03 to actual date of sale including if sale is held at a later date (Costs to be added) $113,055.19 1,805.18 UDREN _LAW Attorneys_.f-or--P ntiff MARK J. UDREN, E E. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE FLEI THE ?7 2059 AUG 25 Ali 11: 09 ?iy e? f" ohs ?r '?y 5 b A Q ?L r? ,? b ALL THAT CERTAIN LOT OR TRACT OF LAND SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF KITTATINNY DRIVE (64'WIDE PRIVATE) , AT THE DIVIDING LINE OF LOT #73 AND #74, SAID POINT ALSO BEING LOCATED 721.28 FEET WEST OF THE NORTHWEST CORNER OF KITTATINNY DRIVE AND TUSSEY COURT: THENCE BY THE NORTHERN RIGHT-OF-WAY LINE OF KITTATINNY DRIVE NORTH 82 DEGREES 02 MINUTES 02 SECONDS WEST 20.00 FEET TO A POINT; THENCE BY LINE OF LOT #75 AND PASSING THROUGH THE CENTER OF A PARTITION WALL NORTH 07 DEGREES 57 MINUTES 58 SECONDS EAST 100.00 FEET TO A POINT; THENCE BY LINE OF LAND NOW OR FORMERLY OF J.P. ROTH, SOUTH 82 DEGREES 02 MINUTES 02 SECONDS EAST 20.00 FEET TO A POINT; THENCE BY LINE OF LOT #73 AND PASSING THROUGH THE CENTER OF A PARTITION WALL SOUTH 07 DEGREES 57 MINUTES 58 SECONDS WEST 100.00 FEET TO A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF KITTATINNY DRIVE, THE PLACE OF BEGINNING. CONTAINING 2,000 SQUARE FEET. BEING LOT #74 ON FINAL SUBDIVISION PLAN OF MOUNTAIN VIEW VILLAGE PHASE IV RECORDED IN PLAN BOOK 60, PAGE 87B BEING KNOWN AS: 4184 Kittatinny Drive, Mechanisburg, PA 17050 PROPERTY ID NO.: 10-15-1285-124 TITLE TO SAID PREMISES IS VESTED IN RODGER L. ALFANO, JR. AND RACHEL A. ALFANO, HUSBAND AND WIFE BY DEED FROM MARK W. NAVARRO AND MARY ANN NAVARRO AND MARY ANN NAVARRO, HUSBAND AND WIFE DATED 4/14/2006 RECORDED 4/18/2006 IN DEED BOOK 274 PAGE 198. 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp ;CIVIL DIVISION Plaintiff =Cumberland County V. ;MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano 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: UDREA- - OFFICES , . C. Attorney-8--for..Plaalitif f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE FILE, ` ? I J TIDE,:, , ^. ?Y 2C-09 AUG 25 AID I I : Ci 9 V V I`;? ti'`f z yt 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County v. `:MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. €NO. 09-4985 civil Rachel A. Alfano 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. UDREN LAW..-OFFT C. Attorneys .for Plai ti f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r,r 2C09AUG 25 A li: 09 GG't° ?`t;PVi Y f 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Taylor, Bean & Whitaker Mortgage Corp, 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: 4184 Kittatinny Drive, Mechanisburg, PA 17050 1. Name and address of owner(s) or reputed owner(s): Name Address Rodger L. Alfano, Jr. Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 4184 Kittatinny Drive Mechanisburg, PA 17050 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 of record: Name Taylor, Bean & Whitaker Mortgage Corp the last recorded holder of every mortgage Address 13820 Old St. Augustine Road Suite 113-518, Jacksonville, FL 32258 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 4184 Kittatinny Drive Mechanisburg, PA 17050 Mountain View Village Phase IV, PUD Address to follow 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: August 25, 2009 UDREN_-i?,W -OFFICES , P ?Y Attorneys for Plaiht-lNff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE OF TH 2009 AUG 25 Ali 11: 69 J* Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp =CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant(s) 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 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 Your house (real estate) at 4184 Kittatinny Drive, (Hampden Township) Mechanisburg, PA 17050 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 $113,055.19, 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.) I 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 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 2009 AUG 25 Am 11: 10 1`, ii; •!r?;JYU.,;ANI.,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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff €Cumberland County V. :MORTGAGE FORECLOSURE Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rodger L. Alfano, Jr. 4184 Kittatinny Drive Mechanisburg, PA 17050 Your house (real estate) at 4184 Kittatinny Drive(Hampden Township) Mechanisburg, PA 17050 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 $113,055.19, 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.) i 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 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 FILED s; I -,! OF THE P 2009 AUG 25 A,M (1: 10 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 Taylor, Bean & Whitaker =COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION Plaintiff :Cumberland County V. Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant (s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Rodger L. Alfano, Jr. and Rachel A. Alfano PROPERTY: 4184 Kittatinny Drive, Mechanisburg, PA 17050 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. OF THE 2009 AUG e Art I I: 10 4. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-4985 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TAYLOR, BEAN & WHITAKER MORTGAGE CORP Plaintiff (s) From RODGER L. ALFANO, JR. AND RACHEL A. ALFANO (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named 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$113,055.19 L13.50 Interest FROM 8/26/09 TO DATE OF SALE DECEMBER 9, 2009 - ONGOING PER DIEM OF $17.03 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $1,805.18 Atty's Comm % Due Prothy $2.00 Atty Paid $172.00 Other Costs- TO BE ADDED Plaintiff Paid Date: August 25, 2009 Cu is . Long, P3 tary (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C., WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 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 Taylor, Bean & Whitaker :COURT OF COMMON PLEAS Mortgage Corp :CIVIL DIVISION 12650 Ingenuity Drive, :Cumberland County Orlando, FL 32826 Plaintiff NO. 09-4985 civil v. Rodger L. Alfano, Jr. Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 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 4, 2009 OFFICES, BY:--/ Attb e fo P iritfff MARK R QUIRE STUAR INN G, ESQUIRE LORRAINE DO , ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Taylor, Beare & Whitaker Mortgage Corp,, et. al., Plaintiff(s) rts, ° lt(ltlger L..itfano, jr., et, al., Defendantis) SCI'N f" e ?,?f process by A PS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Clenrov Rif. minnaflo?is. tNIN 5:5434-3122 APS File 4- 09964-5-oool I DRLN LAW OFFICES Ms. Kristen Pluck 1 l l Wooderest Rd. Ste 200 Cherry Hill. NJ 08003.3620 State of., c?l? yr ? _? ?) s AFFIDAVIT OF SERVICE -- individual Service of Process on. --Rodger L. Alfano, Jr. Court Case iNo. 09498 civil F County to Name of Server: lltldcr1 igncd. being duly ."ivvorn. lcj- c,; and say'`"« that at the time of service, he tti a . l(-.sal age and .::. a party to tl;is actior: DatelTinte of Service: that on the day of 20 o'clock M -_ r Place of Service Documents Served: Service of Process on, Person Served, and Method of Service- Description of Person Receiving Documents: at 4194 Kittatinny Drive in Mechanicsburg, PA 17050 the undersigned served the docu nenv, de,cribcd as: Notice of Sheriff's Sale of Heal Property A true and correct copy of the aforesaid document(s) "as served on: Rodger L. Alfano, Jr. By per iialty delivering them into the 1,, Edi, of the person t- By delivering them into the hands of _ a person of suitable age, who verified, or who upon questioning stated, /'sat he/she resides with Rodger L. Alfano, Jr. at the place of service, and whose relationship to the person is: The per on re ek iitg doennilms is described as foil S,:.. Skit) olor Hair Color ,`? l?aii.Elliair "Vz?a Approx. A_!e Approx. Height pprox, Wcight / 5 /5- To the 1,est._)f my ktiowledge and belief, said person was not engaged in the US Military at the tifmL of ser~v{ice, signature of Server: 1.indersig n?;d clecl.tres tlndrr pe tatty of perjur, that the t?Yc teii7 ,is taj: and c-rr-t. !` OFF .,,/ :BPS International, Ltd. rIPENNSYLVAMA ?x s ?, ..j 2 :-,, r! 2': -, ?, " 13 It 5 111' i 3 i 1-,: . L ?j 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 Taylor, Bean & Whitaker Mortgage Corp Plaintiff V. Rodger L. Alfano, Jr. Rachel A. Alfano Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4985 civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B" 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 4, 2009 UDRE FIC P.C. BY: Attorney fof"intiff 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 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 pleadings@udren.com Taylor, Bean & Whitaker =COURT OF COMMON PLEAS Mortgage Corp CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE. Rodger L. Alfano, Jr. :NO. 09-4985 civil Rachel A. Alfano Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Taylor, Bean & Whitaker Mortgage Corp, 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: 4184 Kittatinny Drive, Mechanisburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Rodger L. Alfano, Jr. Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 4184 Kittatinny Drive Mechanisburg, PA 17050 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 of record: Name Taylor, Bean & Whitaker Mortgage Corp 5. Name and address of on the property: Name None the last recorded holder of every mortgage Address 13820 Old St. Augustine Road Suite 113-518, Jacksonville, FL 32258 every other person who has any record lien 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 1 Courthouse Sq., Carlisle, PA 17013 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 Mountain View Village PUD/HOA/Condo Association 4184 Kittatinny Drive Mechanisburg, PA 17050 Kittatinny Drive Mechanicsburg, PA 17050 Route 611, PO Box 6 Bartonsville, PA 18321 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: November 4, 2009 UDRE LAW F ` P.C. BY: Attorn s f aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ,o,rOUIS A. SIMONI:, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Taylor, Bean & Whitaker Mortgage Corp Plaintiff V. Rodger L. Alfano, Jr. Rachel A. Alfano Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4985 civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Rodger L. Alfano, Jr. & Rachel A. Alfano PROPERTY: 4184 Kittatinny Drive (Hampden Township) Mechanisburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs 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 than 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. E XX a) 0 0 ?/Q^? mJ W CD (D Dr 00 C O' C) rn 0 N 00 CD c cr CD v a V cn -n O 3 W 00 V V T CD CS c 41 CD 0 o' O c H Q' CD 0 O a G yr a 7 O TW V 7 3 r rn o CJ1 A W N .... -? O CO O -4 CA CT A W N r Z CL cr CD 3 cn ? CD CD 0) A CD Cr Z 1 > CL C) N Q O.O N 3n c (D m CD CD ? wp C7??7 ?_?? m ? cog O D 0)OCD - • CD: " M =3'AD vOmO K 3 c 0 2. E, C s c co Wm o 00 aQ 3 n O - ' r CD =? SNCO n ?OZ ? - O U D • = OomC CL Z n (D X D < CD Dy C C - i •O - < ? M ,0 ° 4 CD w CD 4 0) ? , 0,? n _ yo"'°,ODm CD D X =y? 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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 Taylor, Bean & Whitaker Mortgage Corp 12650 Ingenuity Drive, Orlando, FL 32826 Plaintiff V. Rodger L. Alfano, Jr. Rachel A. Alfano 4184 Kittatinny Drive Mechanisburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4985 civil PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 4, 2009 UDRFIjn;IAW OFFICES, _P,,C. BY:-/// .?l C / At t6 e f0 P nt f MARK R QUIRE STUAR INN UG,ESQUIRE LORRAINE DO ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE fa lair f3?r;ir+ Whit3kcr lliyrtgal;e Corp., et, al., Pfuintitlis) Uod''r 1., aif;Jnf+..(r., et. aaf.. Defendantm t_`l'?t2EN LANK <,}t:i ICE_'S 'sl . Kristen Phick t 1 t tS oadcrest R 'l, Ste -of) t_,'hvm f-lilt, NJ ilS0113-36.t F `date ut: - ) sS. C;ountr \ amc of ??t' r'. Dale'"finic +al' ` t:rviee t'Iaeo of tiera icc: f)ocumeitts sereed: `+< rt iiC of Process on 11t'vitojl `5t't'\a(f_,Ind N)ihod t)t .` vri icc: Dv,.crip ittn of ?!'erson Week illD oejmle'llt4: Srr? a,:c c+F.Fr rtec:5 tt t' APS International, Ltd. 1-800-328-7171 at 1 ti II t3a.a7tfiNai'? BPS biternliorial 7800 GlenroY Rd. Minneapolis, ,NIN ^55434-3122) APS lilt' 9.. 119964-oooi AFFI.DAV14, OF SERVICE - Individual Seri ice of Pritccss tact: -f"tt>dyer L. Alfanrt, Jr. ouri C"tase O. 09-4985 cit if - _..?.._ ...??_ _ . undo°rs€?rae,c:. f?`iJta?° duly vT:?+rfl d`po:??<; rttlcf aav- ih,ii at the time o s+-rvic lt,'#ti oi'l .:l a'gc itIId %t,Is not a lio ' .ills 9c al`?j.; } , t!t;1[ t)t ilic '3\' (tf, f) ,it ic)irck -_"M l 4184 K tt itinns° Drive it t6ech:,nicrbu?. f 1 1 (1?6? the undersigned s r%ed the a oc'umeilt:s Jc>crtberl as: Notice of Sheriff's Site of Beal Proper A true and correct copy of the afore-,tilt El:_?c ttilterit(s) \\ `'4 Served oll ltodgrer L. Alfano. Jr. By Gil'-%(malk dc'[1wrlnLv Ij1:131 i1110 till` tIre 111,V l}I1 tO % 'J? a f ci'S( 1 [1 r±\ deli e ":il- 111c111 lili+t Tile flailds of l liEt<lilfi t',t. Mil,) ik J'1)tet . m \'tli? tlpt3n questioning stated, tl :Ll heis11e re ides `,s'ith Roder L. Alfanta. Dlr. at the place of service, and %-,how relxiolit z tip to the person n,: lilt person receiving, d('il:tiYTl :tli,+ is dL`+'..1ibCd t7ti i'C)llil`.t Skin Cc for f l it' ?ALtt ? Frac?al } hair 11p1'ti* .. -.t Approx f-ici4gllt -i Approx. ? tL?lit a l l;) the beet of,111% lii1C)wted-gc and behe:f" s7 iid persurl "k;i* not e ;t„`.cd In tilt: (.' Nlilil:?rs at the Iitl e o t' Set vice. `,ign tture (it l tide rsi-twd tleclaI:: Itlld-' pellttlt\ Of PtrlttC\ that .91? C QN)l1l'' LS tri;.' Wd t t wrect. APS, International, Ltd. 3 ? rte.. I do lor- Bt%tn k tt llitakrr Nlorta.are COT.- et. at.. Plainlifftst Rodger f._ 111mlo,.f1 ., et. - Dcfendanlt_sj I. DREN LAW OFFICES Nk. Kri tern Pluck I I $ k%umicrest ktt. Ste 200 (. hem, Hill. NJ 08003-3t,20 SVINice ofPrrrceis bN - AP`s; International. Ltd. _ • __ ?__ _ 1-800-328-7171 arst'?'tV"tt>>iIONAPShilernation:all'laj,a '800 Gicuro4 Rd. Njinfieapolis '1i,\ X47-3122 A PS File x: 099644-0001 AI* FIDAN! r OF SERVICE -- Individual Sen'ire of Process tin. --Rachel A. Alfanci Court Case <N'o, 09-495.5 c•i% it State of: SS. f rilrrltt of., - -- ?) t.arrtr c:f en ce: - tI]Idersig nee. being du IN, t:j;11 ..?:, that at °hc tulle of E:'tvice - "1t -Is i -,` leaaj age and '\as not x p??!rt ° to tliis 1itlonT J>:lic l rnte. of '-?ertlc? '„1 a on tllc ? r n<a o r'lacc ol`Scr?ice. 4184 Kittation?C3risc? in t'lechanicsliur?, P1 T-ii5+) Doctrnlcnts 4erv'cd: id1C under,igned sepwed 1fic CIr>tiL1ITlCtt't5 tir cri$ t iI a "entice of Sheriffs S.-ale of Real Promi-tv s rs ic'i' of Prti s on. A tFUC 1t1G1 correct. copy of the <I oresaitl %I(t :l:lnlc;latf `+} ;: is se rv l (vli Rachel A. Alf Ano ' PJrc°tCS?rirn rrc ccl and of 'iclti ice: 11" rcr,"Onall"" delik exit - tflem into, tit: Iriands of the t erSo r w. hr_ SeIA'>:'J. - 11% rcliverin- t:hetll into [lie hands of, o ? it p rsc?n siduible a ke, who verified, or who t pc)n questioning slated. that he'she resides ? Ith Rachel A. Alralno at the place of and :ehosc r l.aiion-'hlp to the person is: N) Scriptiwl of person I lie person receivinr_ Au,. itnl,`11;' +i described a i.)lliil} ; fCt't'{`t4in?? l)C'iP1rlrCr?t5, 'i ,. ,".? z.e Skin Color ? Flajr t.: gilt -r Facial (-lair ,t,j)r0.ti.. 'At'C ?? Approx. 1 ltisuht _ Approx. WeiSMlat Fo th bc'.i -$ 111% •NIlOt`, ild Mid, 5t:ti (?t;t'•on N% as :Tint engaged iii the 1_S NIilttar% ill the tim C[ _. vice. r ' Sit;nmure of Scn er: L-ndersilancd de,:Iiarls under penalty of per'Jltr, , Stlh; jb!Likil' ff 5WiOrll '.'> f?( #?.•r??{? hiS t1mr thk nett'"(-Yfvt' is talc mid c rn c1. ll, Alit i er moist l'.tlSbc T ccr n d?: 1?itetii AP`> Internittion. 1..td. OFNNSYLVAMA :.,.rq 1( I:y G J Fi ` ?l r i '77 T! t'.., 1--, , 1 ?. 1 a t L i l1 ? l