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Home My WebLink About04-2321 STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 ADAM L. KAYES, ESQUIRE ATTORNEY I.D. NO. 86408 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, f-r- PLAINTIFF, NO: CJ4- ~3;tl {}iOLL 'E1L~ v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, . DEFENDANT. COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE 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: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717) 249-3166 (800) 990-9108 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. 51 USTED QUI ERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE 51 USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALlVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO 0 SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717) 249-3166 (800) 990-9108 STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY 1.0. NO. 66287 ADAM L. KAYES, ESQUIRE ATTORNEY 1.0. NO. 86408 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, NO: v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff hereby complains against Defendants as follows: 1. Plaintiff is LaSalle Bank National Association, as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9, ("Plaintiff"), with an address in care of Wilshire Credit Corporation, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Plaintiff is the current holder of the mortgage described below (the "Mortgage"): (a) Parties to Mortgaqe: Mortqaaee: Wilmington Finance, Inc. Mortaagor: Todd A. Perry Carrie Perry (b) Date of Mortqaqe: 4/25/03 (c) Place and Date of Record of Mortqaqe: Recorder of Deeds Cumberland County Mortgage Book: 1809 Date: 5/2/03 Page: 2388 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No.1019 (g). (d) Assiqnment: Assignor: Assignee: Wilmington Finance, Inc. LaSalle Bank National Association as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 Date of Assignment: As Recorded Recording Date: As Recorded Book: As Recorded Page: As Recorded 3. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment. 4. Contemporaneous with execution of the Mortgage, Defendants executed a Note (the "Note"). 5. The real property which is subject to the Mortgage is generally known as 5008 Greenwood Circle, Enola, Pennsylvania, 17025. 6. The name and mailing address of Defendants is: Todd A. & Carrie Perry, 5008 Greenwood Circle, Enola, Pennsylvania, 17025. 7. The interest of Defendants is as Mortgagor, Real Owner, or both. 8. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of December 1, 2003, and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 9. The following amounts are due as of May 21, 2004: Principal of Mortgage debt due and unpaid $397,999.96 Interest currently due and owing at 6.99% per annum calculated from 11/1/03, currently at $76.22 each day Escrow Overdraft $15,396.39 $764.72 $8.50 Property Inspections Late Charges at $132.93 and for each month hereafter SPO's $797.58 $14.96 $80.00 $100.00 Certified Mail NSF Title Search Court Costs (filing and service) $175.00 $155.50 $1,250.00 $416.742.61 Attorneys' Fees TOTAL 10. Interest accrues at a per diem rate of $76.22 each day that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 11. The attorneys' fees set forth above are in conformity with the WILSHIRE CREDIT CORPORATION Cortcspondence: P.O. Box 8517 - Penland. OR 97207~8517 - Voice (888) 502..0100 - Fax (503) 952.1416 - www.wfsg.com p.ytIll:nts: P.O. !loA 650314 - 0.11.,. TX 7526S-0314 Date January 30, 2004 Loan # 243812 PERRY, TODD A 5008 GREENWOOD eIR ENOLA P A 17025 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgaac on your home is in default, and the lender intends to foreclose. Specific information abom the nalllre of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav he able to help to save vour home, This Notice explains how the nro~ram works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENGY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when you meet with the CoullSelina A~eney. The name. address and phone number of Consnmer Credit Counselina Aaencies serving vour County are listed at the end of this Notice. If vou have any Questions. VOU mav call the Pennsvlvania Housin~ Finance A~eney toll free at 1-800-342-2397. (Persons with impaired hearing call call 1717\ 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 youI' area. The local bar association may be able to help you find a lawyer. LA NOTlFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCClON INMEDlTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN YOU SHOULD CONSIDER THIS LEITER AS COM INFORMATION PROVlDED flY YOU WIl.L BE U BANKRUPTCY DISCHARGE OF TillS DEIlT. TI1IS I OF OUR LIEN AGAINST THE COlLATERAl. PROP co S0203, licenses cQllection agencies. Payments shou TENNESSEE: 11lis cOllcclion agency is licensed by lhe Friday 7;OQ A.M. TO 5:00 P.M. Pacilic SloIndard Ti Lcltcr~178.B 10.2.02 .. FI:QI:L rru L3CTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR ANY '\V ,- - - ;-~"',:,.,. ,aT. HOWEVER, IF YOll ARE IN BANKRUPTCY OH RECEIVED A , L" . ' ) COLLECT THE DEBT, BUT NOTICE 01' POSSIBLE ENl'ORCEMENT ,~ i H .",n:\ c.J' C 10. the Colonluo Cullt.'Ction Agency Board, 1525 Sherman Street, Denver. b;r- ~r" f~l~' _ {YORK CITY: License 1032551. NORTH C'AROLrNA.: Pennll 3840, 'l'0,._~,r1f<..- .....ro.nmClll ofCOnuUl."fCC and Insur-lOt:c. Wilshire's uffice houf5 are Mond<lY ~ ~ WILSHIRE CREDIT CORPORATION PRESTAMOPOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMlR SU HIPOTECA. HOMEOWNERS' NAME: PERRY, TODD A PROPERTY ADDRESS: 5008 GREENWOOD CIR, ENOLA PA 170251289 LOAN ACCT. NO.: 243812 ORIGINAL LENDER: WILMINGTON CUIUlliNT LENDER/SERVICE: Wilsbire Credit Corporatit>n 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 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 tbe ACI, you are entitled 10 a temporary stay of foreclosure on your mortgage for Ibirty (30) days from tbe date of this Notice. During that time you must arrange and attend a "face _ to-face" meeling wilh One of the consumer credit counseling agencies listed at the end of tbis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed al the end of this notice, Ihe lender may NOT take aClion against you for thirty (30) days after the date of this meeting. Tbe names. addresses and telephone numhers of desit!tlllled consumer credit counseling agencies for the county ill which Ihe pronertv is located are set forth at Ihe end of this Notice. It is only necessary to schedule one facc-Io-face mceting. Advise your lender immediatelv of your intentions, APPLICATION FOR MORTGAGE ASSISTANCE - Your mOltgage is in default for the reasons set forth latcr in this Notice (see following pages for specific infonnation about tbe IIBture of your default.) If you bave tried and are unable to. resolve this problem with the lender. you have the right to apply for fimulcial assistance from the Homeowner's Emergency Mortgage Assistance Program, To do so, you must fill ou~ sign and file a completed Homeowner's YOU SHOULD CONSIDER THIS LETI'ER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR, ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT 11l1S DEBT, HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCV DISCHARGE OF THIS DIlBT. THIS LE1TER IS NOT AN ^ lTEMPT TO COLLECT TilE DEBT, BUT NOTICE OFl'OSStBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLA TERAI~ PROPERTY, COLORADO: In ColQrado, the. Culorado Collection ^SCllC}' Boaru. 1525 Shcrm:m Slrect. Denver, CO 80203. iitcnscs C()Ucction agencies. l)ayments should Mt be S(:ot lo the Board, NEW YORK aTV: License }032551. NORTH CAROLINA: Pennit 3840, TENNESSEJo:: This cQllection agency is licensed by lhe CQllection Service Board. Slate Dcfl3ruucnt ofCornmcrccand Insut'oince Wilshire's onlce hours 3fC Mundn)' _ Friday 1:00 A.M. TO 5:00 P.M. Pacific Stand:ud Time, Lettcr-178.B 1O~2"()2 WILSHIRE CREDIT CORPORATION 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-ta-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 TIDS LETTER, FORECLOSURE MAY 'PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds fur emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The PelIDsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive 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 med bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! It up to date.) NATURE OF THE DEF A UL T - The MORTGAGE debt held by the above lender on your property located at: 5008 GREENWOOD CIR, ENOLA PA 170251289 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTI-IL Y PAYMENTS and the following amounts are past due: Delinquency LaIc Charges Other Charges $ $ $ 6356.78 265.86 .00 TOTAL $ 6622.64 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEF AUL T - You may cure the default within THIRTY (30) DAYS of the date of this nolice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6622.64 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cashier's check. certified check or monev order made pavable and senl to: Wilshire Credit Corporation, 14523 SW Millikan Way, Suile 200, Beaverton, OR 97005. You can cure any olher default by taking the following aclion wilhin THIRTY (30) DAYS of the date of this lelter: (J2Q not use if nol applicable.) IF YOU DO NOT CURE THE DEF AUL T . If you do not curc Ihe default within THIRTY (30) DAYS of the date of this Noticel the lender intends to exercise it's ..ie.hts to accelerate the mortt!aee debt. This means that the entire oUlSlanding balance of the debt will be considered due immediately and you may lose the chance to pay the mortgage in YOU SHOULD CONStD8R THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES Acr AS A DEBT COLL8CTOR ANY tNFORMA TlON PROVIDED BY YOU WILL BE USED TO COLLECT TIllS DEBT. 11DWEVER. IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, TillS LEnER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BU'rNOTtCE OF POSSIBLE ENFORCEMENT OF OUR LlEN AGAINST THE COl.LA TER..AL PROPERTY. COLORADO: In Colorado. the Colorado CollectiDn Agency Board. 1525 Sherman Street, Denver. CO 80203. licenses collection agencies. Payments should not be sent to the Board. NEW YORK CITY: Lieel1SCl032S5L NORTH CAROLINA: Pennit 3840. TENNESSEE: This coUJ:ction agency is licensed by the Collection Service Board, State Department of Commerce ;md InSUf:ln~, Wilshire's office h<.ltll"S arc Monday ~ Friday 7:00 A.M. TO :5:00 P.M. Pacific Stnndard Time. l.ctlCr.178.B 10.2-02 WILSHIRE CREDIT CORPORATION monthly installments. If full payment of the total amount past due is not made within THlRTY (30) DAYS, the lender also intends to instruct it's allomeys to start legal action to foreclos. upon vour morl1!:alled properly. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff tbe mortgage debt. If the lender refers your case to it's allomeys, 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 10 pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. 111e allorney's fees will be added to the amount you owe the lender. which may also include other reasonable costs. If vou cure the default within the THffiTY (30) DAY perIod. vou will not be required to pav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal halanceand all olher sums due under the mortgage. RIGHT TO CURE THE DEF A UL l' PRIOR TO SHERIFF'S SALE - If you have not cured the default within Ille THlRTY (30) DAY period and foreclosure proceedings have begun, vou still have the rieht to cure the default and prevcnt the salc at anv timc up to one hour before the Sheriff's Sale. You may do so bv payin~ the total amount then past due. any late or other charges then due. reasonable allomev's fees. any costs cOMeeted with the foreclosure sale. any other costs connected with lbe Sheriffs Sale as SDCcified in writing by the lender. and bv perfonnin~ any other reQuirements under the mortgage. Curing your default In the manner set forth In this notice wlll restore your mortgage to the same position as if you IuId never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that sucb a Sberiffs Sale of the mortgaged property could be held would be approximately 6 nlontbs frnm the date of this Notice. A notice of the actual dale of the Sheriffs Sale will be sent to you before the sale. Of course, Ille amount needed to cure the default will increase the longer you wait. You may find out at any lime exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Wilshire Credit Corporation PO Box 8517 Portland, Oregon 97207-8517 Address: Phone Number: 1-800-776-0100 Fax Numher: 1-800-776-6599 Contae! Person: MR THOMAS BAILEY Ext. 2571 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff, Sale will end your ownership of the mortgaged property and your right to occupy It. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove )'Ou and your furnishings and other belongings could be started by the lender at any limc. ASSUMPTION OF MORTGAGE - You mayor ma)' not sell or lran.fer your home to a buyer or transferee who will assume the mortgage debt. provided that an the outstanding payments, charges and allorney's fees and costs are paid prior YOU SHOULD CONSIDER THIS WnER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEIlT COLLECTOR. ANY INFORMA TtON PROVtDED llV YOU WiLl. BE USED TO COLLECT THJS DEBT. HOWEVER. IF YOU ARE IN BANKRUPTCY OR RECUlVED A BANKRUPTCV DISCHARGE OF THtS DEBT, THIS LEnER IS NOT AN A'J'J'EMPT TO COLLECT Tt.tE DEllT.llUTNOnCE OF POSSlOl.E ENFORCEMENT OF' OUR UEN AGAINST THE COLL^..TERAL PROPERTY. COLORADO: In ColoradQ. the Colt)rddt) Cullection Agency Boam. 1525 ShCT'flUln Street, Denver, CO &0203, licenses collection agencies, Paymcnt~ should not be SCflt to the Board. NEW YORK CIT\': License 1032551. NORTH CAROLINA: Permit 3840, TENNESSE[: This coll~ctionagency is licc:f1St.'d by thO' Collection Service Board, State DepaftmentofCommeree and Insur::mcc. Wilshire's office hours ore Monday- friday 7:00 A.M. TO 5:00 P.M. Pacific Standanl Time. Lcttcrwt78J3 to-2w02 WILSHIRE CREDIT CORPORATION to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL TIiE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE MORTGAGE DEBT. TO HA VB THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF, TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR DEFAULT MORE TIIAN TIffiEE TIMES IN ANY CALENDAR YEAR,) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR AJ:\'Y OTHER LA WSUlT INSTITUTED UNDER TIiE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENCE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMA TlON PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT 1I0WEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVFJ> A BANKRUPTCY DISCHARGE Of' TillS DEBT. THIS I.ETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY, COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street. Denver. CO 80203, licenses CQlwction agencies. Payments should not he sent to the Board. NEW YORK CITY: License 1032551. NORTH CAROLINA: Pennit 3840. TENNESSEE; This COlleclion agency is licensed by the Collection Service Board. State Department of Commerce and Insurance. Wilshire's office hours arc Monday. Friday 7:00 A.M. TO 5:00 P.M, Pacific Standard Time. Lelter-17g,B l(}-2..{)2 WILSHIRE CREDIT CORPORATION Correspondence, P.O, !lox 8517 - Portland, OR 97207-ll517 - Yoice (888) 502.()IOO - Fax (503) 952-7476 - www,wfsg,com Payments' P.O. Box 650314 - Dallas, TX 7526S.()314 Date January 30, 2004 Loan # 243812 PERRY,CARRlE 5008 GREENWOOD CIR ENOLA P A 17025 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mormage on your home is in denlUlt. 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) IIl1lV be ah]e 10 help 10 save vour home. This Notice exlllains how the program works. To see if HEMAP can help. vou must MEET WmI A CONSUMER CREDIT COUNSELING AGENGY WITHIN 30 DAYS OF THE DATE OF TIllS NOTICE. Take this notice with YOU when YOU meet with the Coumeline Agency. The name. address and phone number of Consumer Credit Counseling Agencies servin\! your County are listed at the end of this Notice. If yl)u have any QUestions. vau may eaU the Pennsylvania Housing Finance Agency toll free at 1.800-342-2397. (Persons with impaired hearin~ can caU (717)780-]869.) 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 Jocal 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 CONTENIDO DE ESTA NOTlFlCACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WIU. BE USED TO COUliCT TIllS DEBT. HOWEVER. lF YOU ARE IN BANKRUPTCY OR RECEtVED A BANKRUPTCY DISCHARGE OF THIS DEBT. THIS LE1'TER IS NOT AN ATTEMPT TO COLLECT THE OEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR UEN AGAINST THE COU~ATERAL PROPERTY. COLORADO: In Colorado, the Colomdv Collection Agency Board, 1525 Sht:nrum Street. Th:nvcr, CO 80203, licenses collection agencies.. Puymems should not be sent to the Boord. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE; This collection llgenc)" is licensed by the Collection Service Board. Stlite Dep3rtmcmofCommerce 311d Insurancc. Wilshire's offiCenOtlTS an: Muntin)' ~ Friday 7:00 A.M. TO :5:00 P.M. Pacific Standard Time. LeUcr-17S.13 1O-2~02 WILSHIRE CREDIT CORPORATION PRESTAMO POR EL PROGRAMA LLAMADO ''HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME: PERRY, CARRIE PROPERTY ADDRESS: 5008 GREENWOOD CIR, ENOLA PA 170251289 LOAN ACCT. NO.: 243812 ORIGINAL LENDER: WILMINGTON CURRENT LENDER/SERVICE: Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMl'LY WITH THE PROVISIONS OF TIlE HOMBOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTIlER ELiGl.BILITY 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 mongage for thirty (30) days from the date of this Notice. During IIlllt tin,e 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 WI1'HIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE, TIlE PART OF TIllS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit connseling agencies listed at the end uf this notice, the lender may NOT take action against you for thirty (30) days after the da1e of this meeting, The names. addresses and telephone numbers of desil!llated consumer credit counseling ageneies for the COUlltY in which the property is located are set forth at the end of this NOlice. It is only necessary to schednle OIlC face-to-facc meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth I.ter in tbis 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 AssistlUlce Progmm. To do so, you must fill out, sign and file a completed Homeowner's YOU SflOULD CONSIDER THIS I.ETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR, ANY INFORMATION PROVtDED BY YOU WILL BE USED TO COLLECT TillS DEBT, HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OFTtllS DEBT, TillS LETTEI\ IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST '!lIE COLLATERAL PROPERTY, COLORADO: In Cclontdu. the Colorodo Collection ^:;;:enc)' Boord, 1525 Shennan Street. Denver. CO 80203, licenses coUeelion agencies, PaymcJ1ts should !lot be seOl to the Board, NEW YORK CITY; Lkense 1032.551. NORTIJ CAnOLlNA: Pcnnit 3840. TENNESSEE: 1l1is collc<:tion agency is licr:osetl by ihc Collection Service Board. Slate Dcpartmen1 ofCummercc and Insurance. Wilshire'S (If/ice hOUfS 3r-c-, Monday ~ Fridny 7:()(J A.M. TO 5:00 P.M, Ptldfi<: Standard Time. Lel<<"r~118,B I O~2*02 WILSIDRE CREDIT CORPORATION Emergency Assistance Program Application with One of the designated consumer credit counseling agencies listed at the end of this Notice. Only consnmer credit counseling ageneies bave 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. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAlL 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 Peunsylvania Housing Finance Agency bas sixty (60) days to make a decision after they receive your application. During that time, no foreelosnrc proceedings will be pursued against you if you have met the time requirements set fortb 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 ATTEMl'T TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brinl! it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property loeated at: 5008 GREENWOOD CIR, ENOLA PA 170251289 IS SERlOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $ Late Charges $ Other Charges $ TOTAL $ 6356.78 265,86 ,00 6622.64 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTiON (Do not use if not atlDlicable): HOW TO CURE THE DEFAULT - Vou may cure tIle default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6622,64 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's check. cenified check or monev order made pavable and sent to: Wilshire Credit Corporation, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. You can cure any other default by taking the following action wi.thin THIRTY (30) DA YS of the date of this letter: (QQ not use if not applicable,) IF YOU DO NOT CURE THE DEF AUL T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise it's r1ehts to aeeelerate the mortelll!e debt. This means thattbe entire outstanding balance of the debt will he considered due immediately and you may lose the chance to pay the mortgage in YOU SHOULD CONSIDER nlls LETrER AS COMtNG FROM A OEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COt.LECTOR. ANY INFORMA nON PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT, HOWEVER, If YOU ARE IN BANKRUPTCY OR RECEIVED A tlANKRUPTCY DtSCIIARGE OF TillS DEBT, THIS LEITER IS NOT AN A ITEMPT TO COLLECT THE DEBT, BUT NOTICE OFl'OSSII3LE ENFORCEMENT OF OUR LlEN AGAINST THE COLLATERAL PROPERIT. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Strecl. Denvcr. CO 80203. licenses collection agencies. Payments should not be sent ro the Board. NEW YORK CITY: License 1032551, NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State. Department of Commerce and insurance. Wilshire's offieehouf'S are Monday _ Friday 7:00 A.M. TO 5:00 P.M. P.acilic Standard Time. Lcttcr-178.B 10-2-02 WILSHIRE CREDIT CORPORATION monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it's attorncys to start Icgal action to foreclose upon "our mortll'a/!ed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mDrtgage debt. If the lender refers your case to it's attDrneys, 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 s!llrted aguinst you, you will have to pay all reasonuble attorney's fees aetually incurred by the lender even if they exceed $50.00. The attorney's fees will be added to the amOunt you owe the lender. which may also include other reasonable costs. If vou cure the default wltl.in the THIRTY (30) DAY period. Yon will not be required to pn,"' attornev"s fees. OTHER LENDER REMEDIES - The lender may also sue you persnnally for Ille unpaid principal halance and all other sums due under Ille mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings ha"e hegun, vou still have the rill'ht to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You may do so by Davina the total amount then past due. apv late or other charll'es then due. reasonable attorney's fees, an" costs connected with the foreclosure sale. any other costs connected with the Sheriff's Sale as SPecified in wtitina by the lender, and bv perfonnina any other requirements under tbe mort""ge. Curing your default In tbe manner 5et forth in this notice will restore your mortgage to the same poslllon a5 If you bad never defaulted. EARLIEST POSSmLE SHERIFF'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 tbis Notiee. A notice of the actual date of the Sberiff's Sale will be sent '0 you before the sale. Of course, the amowlt needed to cure tbe default will increase the longer you wait, You may find out at any time exactly what the required payment of action will be by contacting tbe lender. HOW TO CONTACT THE LENDER: Name of Lender: WHsltlre Credit Corporallon Address: PO Box 8517 Portland, Oregon 97207-8517 Phone Number: 1-80()..776-0100 Fax Number: 1-80()"776-6599 Contact Person: MR THOMAS BAILEY Ext. 2571 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to oceupy it. If you continue to live in the propeny after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor mal' not sell or transfer your home 10 a huyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior YOU SHOULD CONSlDER THIS LE1TER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR, ANY INFORMATION PROVIDED OY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER. IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF TIllS DEBT. THIS LETIER IS NOT AN A'n'EMPT TO COLLECT TI'IE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUk LIEN AOArNST THE COLLATERAL PROPERTY. COLORAI>O: In Coloradu. the Colorado Collection Agency Board. l525 Shcnn::1I1 Street. Denver.. CO 80203. \iceuses collectioll agencies. Payments should nOl be sent to the Board. NEW YORK CITY: Lkense 1032551. NORTH CAROLINA: Ptnnit 3840. TENNESSEE: This colleclion ngency is licensed by the Collection Service Board, State r.>epanment of Commerce and Insurance. Wilshire's office hours are Monday ~ l:riday 1:00 A.M. TO 5:00 P.M. ~cific Standard Time, Letter-118.B 10-2-02 WILSillRE CREDIT CORPORATION 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 PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE MORTGAGE 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 DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENCE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY YOU SHOUtp CONSIDER THIS I.ETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES A(;T AS A DEBT COLI.ECTOR. ANY INFORMATtON PROVIDED BY YOU WILl. BE USED TO COLLE(;T THIS DEBT, HOWEVER. IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT. THIS LETTER IS NOT AN A TruMPT TO COLLECT THE DElJT. BUT NOTICE OF POSSIBLE ENFORCEMENT Or: OUR LIEN AGAINST 1TIE COLLATERAl. rHOPERn'. COLORADO; In COIOr-ddo, the Colorndll Collection Agency Board. 1525 Shetn10ln S~et,. Denver, CO 80203, licenses eot1ec\1on agencies. Payments should nt)t be sent to the Board. NEW \tORK CIT\': License J032551. NORTH CAROLiNA; PL'J'mjt 3840, TENNESSEE: This t;oUection ugency is licensed by the Collcction Service Booro, Slale: Depal'1rncnt of Comn\Crce and Insur41\Cc. Wilshire's ofiicc hours are Monday ~ Friday 7:00 A.M. TO 5;00 P.M. Pacific Slandard Time. . Letter~178.B lO~2-02 7V~ig. ~ i:L ~ '- . II) ~ V'l (;::, r- () ~ ;j-v r l p::.. J ,-, C") 9 -L' -;1 :-;::1 "; :'] GQ '. -"~:1 ) .. r'O" '-, I t.. SHERIFF'S RETURN - REGULAR CASE NO: 2004-02321 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS PERRY TODD A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE PERRY TODD A was served upon the DEFENDANT , at 1945:00 HOURS, on the 26th day of May 2004 at 5008 GREENWOOD CIRCLE ENOLA, PA 17025 TODD PERRY by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.28 .00 10.00 .00 36.28 Sworn and Subscribed to before me this //J e day of C),uA.<~. 02(}() '{ A. D . ( JUt" {J h.,II,. ,~' 7Ptothonof~ry So Answers: r~~~ R. Thomas Kline OS/27/2004 KERNS PEARLSTIN,J' ~ ONOlRATO By: ~~ Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-02321 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERI,AND LASALLE BANK NATIONAL ASSOC VS PERRY TODD A ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PERRY CARRIE the DEFENDANT , at 1945:00 HOURS, on the 26th day of May , 2004 at 5008 GREENWOOD CIRCLE ENOLA, PA 17025 by handing to TODD PERRY, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: _~// ./ y..4!' .f ~>~#<4"'-~ ~ R. Thomas Kline Sworn and Subscribed to before OS/27/2004 KERNS PEARLS TINE ONORATO FATH By: ~~ -It 7:~; She'riff me this /0 """ day of ~"-'-_ .200''/ A.D. (-l "- () ~~ ~ ~onotary / STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a Default Judgment against Defendants, TODD A. PERRY and CARRIE PERRY, and in favor of Plaintiff, LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003- BC9, c/o Wilshire Credit Corporation, for failure to answer Plaintiff's Complaint within the time prescribed by Pa. RC.P. 1026 and assess Plaintiff's damages as follows: Principal of Mortgage debt due and unpaid $397,999.96 Interest currently due and owing at 6.99% per annum calculated from 11/1/03, currently Escrow Overdraft $18,292.75 $764.72 at $76.22 each day NSF $8.50 $797.58 $14.96 $80.00 $100.00 $175.00 Property Inspections Late Charges at $132.93 and for each month hereafter Certified Mail BPO's Title Search Court Ceot, :f:ling 8~d !cNiel!) $IIlO.lia+ Attorneys' Fees $1,250.00 TOTAL .ft1~\nOA)7 .it,,? I..{PJ. 1../7+ Total damages to be assessed at Four Hundred Nineteen Thousand, ~ ~ -4- 8""~i ~ ~/-~~ ~ 4/~ I./I"J.Jf1 '* Hundred T~il'l'y.c:;~,t Dollars and Ninoty Seven Cents (t-l W,DeJ.31j, together with interest at the aggregate daily rate of Seventy-Six Dollars and Twenty-Two Cents ($76.22) from June 29, 2004, until the date of entry of final judgment, plus interest thereafter on the judgment, at the rate stated in the subject note, plus any costs, expenses, attorneys' fees and all other amounts due and payable under the Note and Mortgage, up through the sale of the mortgaged premises. RESPECTFULLY SUBMITTED, KERNS, PEARLSTINE, ONORATO & FATH, LLP Date: ~~3~ BY; Stephen M. Attorney for -* ?EIL. e~c:o.U€..- C2L L U)~ mJ..y 00 7;1:2./01 AND NOW, _ )UL\f= J6 , 2003, Judgment is entered in favor of Plaintiff and against Defendants, TODD A. PERRY and CARRIE PERRY, by Default, for want of an Answer, and damages assessed at the sum of Four Hundred Nineteen Thousand, Six Hundred Thirty-Eight Dollars and Ninety-Seven Cents ($419,638.97), as per the above certification. ~k.~ Prothonotary if STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. CERTIFICATE OF SERVICE Stephen M. Hladik, Esquire, hereby certifies he served a true and correct copy of the Praecipe to Enter Default Judgment in the above-captioned matter by first class mail, postage prepaid on June 28, 2004, upon the parties listed below: Todd A. Perry 5008 Greenwood Circle Enola, PA 17025 Carrie Perry 5008 Greenwood Circle Enola, PA 17025 By: Stephen I ,Esquire Attorney for Plain 'ff STEPHEN M. HLADIK, ESQUIRE ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term AFFIDAVIT OF NON.MILlTARY SERVICE STATE OF PENNSYLVANIA COUNTY OF MONTGOMERY S.S.: THE UNDERSIGNED, Stephen M. Hladik, Esquire, being duly sworn, deposes and says that he is the attorney for the Plaintiff in the within action, and that the averments herein are based upon investigations made and records maintained by the Plaintiff or the servicing agent of the Plaintiff herein, and that the above-named Defendants 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 is as follows: Defendant: Todd A. Perry Age: Over 18 Residence: 5008 Greenwood Circle, Enola, PA 17025 Employment: Unknown Defendant: Carrie Perry Age: Over 18 Residence: 5008 Greenwood Circle, Enola, PA 17025 Employment: Unknown KERNS, PEARLSTINE, ONORATO & FATH, LLP BY: Stephen M. Attorney for PI i (, Esquire in iff \ Sworn to and subscribed befor~ me this )..~ay ~' ,2004. (-~ AA 1 7',1.vt. MM.lH-L..' ~atY Public MMONW~A.!!H.FP~r:l .. ' 3EAL LlSAf i . '1otary Public Lan? :;'1 CoonIy My Comm,'3' , 3 Jure 19, 2001 (File #16-334) STEPHEN M. HLADIK, ESQUIRE ATTORNEY /.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a written Notice of Intention to Take Default Under Pa.R.CP. 237.1, was mailed to the Defendant(s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on June 17, 2004, as set forth in the copy of said Notice attached hereto, to the following Defendants: Todd A. Perry, 5008 Greenwood Circle, Enola, PA 17025 Carrie Perry, 5008 Greenwood Circle, Enola, P 17025 Date: uj 171c1 By: . ~ Steph n . Hladik, Esquire Attorne or Plaintiff (File #16-334) . . , . STEPHEN M; HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY !.D. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 . Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Todd A. Perry 5008 Greenwood Circle Enola, PA 17025 DATE OF NOTICE: June 17, 2004 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 (10) 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 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. AI no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte 0 escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe lIevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 lIame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Todd A. Perry, 5008 Greenwood Circle, Enola, PA 17025 Carrie Perry, 5008 Greenwood Circle, Enola, PA 1j025 Afj 1'< By: Ii / , Stephen M. Hladi~,lI suire Attorney for Plaint ' (File #16-334) STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as COURT OF COMMON PLEAS OF Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT, NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Carrie Perry 5008 Greenwood Circle Enola, PA 17025 DATE OF NOTICE: June 17, 2004 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 (10) 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 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. AI no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte 0 escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe lIevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 lIame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Todd A. Perry, 5008 Greenwood Circle, Enola, PA 17025 Carrie Perry, 5008 Greenwood Circle, Enola, PA 17025 By: , ~ Stephen M. Hlaqi~,s uire Attorney for Plai . (File #16-334) C(Q0 ~ ~iL~~ -....... l)- f; b~:cJ ~ ~ - F ~-!::.~l:J ~ * .., ., u-j ,......,-, . . (", - , r'.. ) .. I.~ () STEPHEN M. HLADIK, ESQUIRE ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Execution in the above matter, and direct the Sheriff to levy on the real property located at 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania, 17025. TOTAL $419,483.47 / $12,933.13 $432,416.60' Amount due Interest from 6/30104 'together with interest at the aggregate daily rate of $80.33, plus costs, expenses, attorneys' fees, and all other amounts due and payable under the Note and Mortgage and for foreclosure and sale of the mortgage premises. Respectfully submitted, Date: (()\i\0'\ KERNS, PEARLSTINE, ONORATO & FATH'~\ By: Stephen MH ~SqUire Attorney fo intiff . . File No, LST179-906 EXHIBIT A ALL THOSE CERTAIN tract ofland, situate in Township of Hampden, Cumberland County, Pennsylvania * known as Lot No.5 on Subdivision Plan of GTeenwood Estates recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows: BEGINNING at a point being the Southwest corner of Lot No.4 on the aforesaid Plan; thence South 47 degrees, 55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 104.99 feet with a radius of 60 feet to " proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; lhence South 31 degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn P. Cazper, north 85 degrees, 33 minutes, 49 seconds West a distance of112.45 to a point; thence along lands now or formerly of Parnay Development Company, Inc. North II degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a point, the place ofBEGlNNING. CONTAlNING therein 46,588.29 square feet, more or less or 1.0695 acres more or less. BEING PARCEL Number 10-14-0840-0100. BEING THE SAME premises which KBG Associates, LLC, a P A Limited Liability Company, by deed dated 9/11/2001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County, Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and wife as tenants by the entirety. . ,,~ (/) '~5:" ~~ - ?:v ('.... ~. ~. 0' ~ 0-.1 ........ \~ s:::::--.... \ 0<' J -- C><) ~ -4;::, .......... -- (J.J c~ ~ YJ 2? ~ ~ f" 0 CJ-...I 0- I \ c.>- ~ 0' v.. <:::! r' t-~ C~ (~ ~~ -Ii U') =-.J r.'Oj , ii", I Cj .( C--:-.' (..; -< WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2321 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NATIONAL ASSOC AS TRUSTEE FOR STRUCTURED ASSET INVESTMENT LOAN TRUST SERIES 2003-BC9 clo WILSHIRE CREDIT CORP Plaintiff(s) From TODD A AND CARRIE PERRY, 5008 GREENWOOD CIRCLE, ENOLA PA 17025. (I) You are directed to levy upon the property ofthe defendant (g)and to sell REAL ESTATE LOCATED AT 5008 GREENWOOD CIRCLE, ENOLA PA 17025 (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 gamishee(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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $419,483.47 Interest FROM 6/30/04 = $12,933.13 Ally'S Comm % Ally Paid $134.28 Plaintiff Paid Date: SEPTEMBER 8, 2004 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG prothJt tary f \ . . By: \ . '^-+-t~ 1d,"2i~ . DePuty U REQUESTING PARTY: Name STEPHEN M HLADIK ESQUIRE Address: 425 W MAIN ST POBOX 29 LANSDALE PA 19446-0029 Attorney for: PLAINTIFF Telephone: (215) 855-9521 Supreme Court ill No. 66287 STEPHEN M. HLADIK, ESQUIRE ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, , v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. () ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term AFFIDAVIT PURSUANT TO Pa. R.C.P. No. 3129.1 LaSalle Bank National Association, as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9, Plaintiff in the above-captioned action, sets forth as of the date of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the following was information concerning the real property situate at 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania, 17025, the same being more particularly described on Exhibit "A" attached hereto and incorporated by reference. 1. Names and Addresses of Owner(s) or Reputed Owner(s): Name: Address: Todd A. Perry Carrie Perry 5008 Greenwood Circle Enola, PA 17025 5008 Greenwood Circle Enola, PA 17025 2. Name and address of Defendant(s) in judgment: Name: Address: Todd A. Perry 5008 Greenwood Circle Enola, PA 17025 Carrie Perry 5008 Greenwood Circle Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is of record on the real property to be sold: Name: Address: LaSalle Bank National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o Wilshire Credit Corp. 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 4. Name and address of the last recorded holder of every mortgage of record: Name: Address: LaSalle Bank National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o Wilshire Credit Corp. 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 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: None Date: 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: T enantlOccupant 5008 Greenwood Circle Enola, PA 17025 Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Domestic Relations Human Services Bldg. 25 S. Front Street 8th Floor Harrisburg, PA 17101 Commonwealth of PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I hereby verify that the statements made in this Affidavit are true and correct to the best of my knowledge or information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsifications to authorities. Respectfully submitted, KERNS, PE LSTINE, ONORATO & FATH, LLR ~.\ l\V\ '~ ' . By: 1\;" Stephen M.IHlRd k;, Esquire Attorney fo~~i~it1tiff STEPHEN M. HLADIK, ESQUIRE ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. 0, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Todd A. Perry 5008 Greenwood Circle Enola, PA 17025 Carrie Perry 5008 Greenwood Circle Enola, PA 17025 Real estate situate at 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, as more fully set forth on Exhibit "A" attached hereto, is scheduled to be sold at Sheriff's Sale on Wednesday, December 8, 2004, at 10:00 a.m. in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Four Hundred and Nineteen Thousand, Four Hundred Eighty-Three Dollars and Forty- Seven Cents ($419,483.47), (plus any additional interest and costs) obtained by LaSalle National Bank Assoc. as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sale you must take immediate action. 1. The Sale will be stopped if you pay LaSalle National Bank Assoc. as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 (c/o Wilshire Credit Corp.), back payments, late charges, costs, and reasonable attorneys' fees due. To find out how much you must pay, you may call: Stephen M. Hladik, Esquire 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 Telephone number 215-855-9521 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 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 below to find out how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND 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 the Sheriff of Cumberland County at (717) 240-6390. 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 paid the Sheriff the full amount due in the Sale. To find out if this happened, you may call the Sheriff of Cumberland County at (717) 240-6390. 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 a 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 on or before January 8, 2005. This schedule will state who will be receiving the 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 filing the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your property 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, 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 Respectfully submitted, Date: 0\\\ \)~ KERNS, PEARLSTINE, ONORATO & FATH, LLP ~~\ .\ ' \ By: i ' Stephen ...~d\' Esquire Attorney r. laintiff . . File No. LSTl79-906 EXIDBIT A ALL THOSE CERTAIN tract ofland, situate in Township of Hampden, Cumberland County, Pennsylvania * known as Lot No.5 on Subdivision Plan of Greenwood Estates recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows: BEGINNING at a point being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 degrees, 55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 104.99 feet with a radius of 60 feet to a proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31 degrees, 49 minutes, 00 seconds West along formerly of Howell P. ClIIper and Lynn P. ClIIper, north 85 degrees, 33 minutes, 49 seconds West a distance of112.45 to a point; thence along lands now or formerly of pamay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a point, the place of BEGINNING. CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less. BEING PARCEL Number 10-14-0840-0100. BEING THE SAME premises which KBG Associates, LLC, a P A Limited Liability Company, by deed dated 9/11/2001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland COlUlty, Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and wife as tenants by the entirety. . LaSalle Bank National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 VS Todd A. Perry and Carrie Perry In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-2321 Civil Term Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 16,2004 at I :45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Todd A. Perry and Carrie Perry, by making known unto Carrie Perry, personally and wife of Todd A. Perry, at 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on October 18,2004 at I :55 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Todd A. Perry and Carrie Perry located at 5008 Greenwood Circle, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Todd A. Perry and Carrie Perry, by regular mail to their last known address of 5008 Greenwood Circle, Enola, PA 17025. These letters were mailed under the date of October 07, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he returns the within writ as STAYED per instructions from Attorney Stephen Hladik. Sheriffs Costs: Docketing 30.00 Poundage 14.88 Advertising 15.00 Posting Bills 15.00 Law Library .50 Prothonotary 1.00 Mileage 19.24 Levy 15.00 Surcharge 30.00 Law Journal Patriot News Share of Bills 307.25 280.60 30.42 $758.89 . So~:..c: . ".. Th' t.U. d f in ~ ~ ~~~ IS ~ ay 0 /1Y(.q , 'f --- C": {\. R. Thomas Kline, Sheriff 2004, A.D. ~~o;~ fluLb V; 0/1 B~J ~S.{NL(:tC\ Real Estate eputy Sworn and subscribed to before me ~ I,,-D (Je. ' d),OJ- / d)~s Iv STEPHEN M. HLADIK, ESQUIRE ATTORNEY 1.0. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, Co , ATTORNEY FOR PLAINTI F Y COURT OF COMMON PLEAS 0 CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. AFFIDAVIT PURSUANT TO Pa. R.C.P. No. 3129.1 LaSalle Bank National Association, as Trustee for Structured Asse Investment Loan Trust Series 2003-BC9, Plaintiff in the above-captioned action sets forth as of the date of the Praecipe for Writ of Execution (Mortgag Foreclosure) was filed, the following was information concerning the real propert situate at 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same being more particularly described on Exhibit "A" attached heret and incorporated by reference, 1. Names and Addresses of Owner(s) or Reputed Owner(s): Name: Address: Todd A. Perry 5008 Greenwood Circle Enola, PA 17025 Carrie Perry 5008 Greenwood Circie Enola, PA 17025 2. Name and address of Defendant(s) in judgment: Name: Address: Todd A. Perry 500B Greenwood Circle Enola, PA 17025 Carrie Perry 500B Greenwood Circle Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is of record on the real property to be sold: Name: Address: LaSalle Bank National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 clo Wilshire Credit Corp. 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 LaSalle Bank National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o Wilshire Credit Corp. 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 4. Name and address of the last recorded holder of every mortgage 0 record: Name: Address: 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: None Date: 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: Tenant/Occupant 5008 Greenwood Circle Enola, PA 17025 Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Domestic Relations Human Services Bldg. 25 S. Front Street 8th Floor Harrisburg, PA 17101 Commonwealth of PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I hereby verify that the statements made in this Affidavit are true an correct to the best of my knowledge or information and belief. understand that false statements made herein are made subject to th penalties of 18 Pa. C.S. section 4904 relating to unsworn falsifications t authorities. Respectfully submitted, KERNS, PEARLSTINE, ONORATO & FATH, LLP , ., --.... -' By: Stephen M. Hladik, Esquire Attorney for Plaintiff STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO. 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 LASALLE BANK NATIONAL ASSOC., as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005, PLAINTIFF, v. TODD A. PERRY CARRIE PERRY 5008 Greenwood Circle Enola, PA 17025, DEFENDANT. ATTORNEY FOR PLAINTI COURT OF COMMON PLEAS 0 CUMBERLAND COUNTY, PA NO: 04-2321 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Todd A. Perry Carrie Perry / 5008 Greenwood Circle 5008 Greenwood Circle Enola, PA 17025 Enola, PA 17025 To: Real estate situate at 5008 Greenwood Circle, Enola, Cumberlan County, Pennsylvania 17025, as more fully set forth on Exhibit "A" attache hereto, is scheduled to be sold at Sheriff's Sale on Wednesday, December 8 2004, at 1 0:00 a.m. in the Cumberland County Courthouse, One Courthous Square, Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Fou Hundred and Nineteen Thousand, Four Hundred Eighty-Three Dollars and Forty Seven Cents ($419,483.47), (plus any additional interest and costs) obtained b LaSalle National Bank Assoc. as Trustee for Structured Asset Investment Loa Trust Series 2003-BC9 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sale you must take immediate action. 1. The Sale will be stopped if you pay LaSalle National Bank Asso . as Trustee for Structured Asset Investment Loan Trust Seri 2003-BC9 (c/o Wilshire Credit Corp,), back payments, late charge, costs, and reasonable attorneys' fees due. To find out how mu you must pay, you may call: Stephen M. Hladik, Esquire 425 West Main Street P.O. Box 29 Lansdale, PA 19446-0029 Telephone number 215-855-9521 2. You may be able to stop the Sale by filing a petition asking th Court to strike or open the judgment, if the judgment wa improperly entered. You may also ask the Court to postpone th Sale for good cause. 3. You may be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner yo contact one, the more chance you will have of stopping the Saie. (Se below to find out how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND 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 th highest bidder. You may find out the price bid by calling the Sheri of Cumberland County at (717) 240-6390. 2. You may be able to petition the Court to set aside the Sale if the bi price was grossly inadequate compared to the value of you property. 3. The Sale will go through only if the buyer paid the Sheriff the ful amount due in the Sale. To find out if this happened, you may cal the Sheriff of Cumberland County at (717) 240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you w II remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount du is paid to the Sheriff and the Sheriff gives a deed to the buyer. t 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 f r your house. A Schedule of Distribution of the money bid for yo r house will be filed by the Sheriff on or before January 8, 2005. Thi schedule will state who will be receiving the money. The mone will be paid out in accordance with this schedule unless exception (reasons why the proposed distribution is wrong) are filed with th Sheriff within ten (10) days after filing the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of gettin your property back, if you act immediately after the sale. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SE FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATIO ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Respectfully submitted, KERNS, PEARLSTINE, ONORATO & FATH,LLP '~ ^ Date: By: Stephen MJHladik, Esquire Attorney for Plaintiff . . File No, LSTl7 -906 EXHIBIT A ALL THOSE CERT Ail'l tract ofland, situate in Township ofHarnpdell, Cumberland County, Pennsylvania known as Lot No.5 on Subdivision Plan of GTeellwood Estates recorded in the Office of the Recorder ofD dB of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows: * BEGlN1\'lNG at a point being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 de es, 55 minutes, 45 second5 East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 1 04.99 feel with a radius 0 60 feet to a proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31 degrees, 49 minutes, 00 seconds West along formerly of Howell P. CllIper and Lynn P. C3Iper, north 85 degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along land5 now or formerly 0 Parnay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a point, the place ofBEGINNlNG. CONTAlNING therein 46,588.29 square feet, more or less or 1.0695 acres more or less. BEING PARCEL Number 10-14-0840-0100. BEING THE SAME premises which KBG Associates, LLC, a P A Limited Liability Company, by deed dat 9/1 1/2001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County, Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband d wife as tenants by the entirety. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2321 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne LASALLE BANK NATIONAL ASSOC AS TRUSTEE FOR STRUCTURED ASSET INVESTMENT LOAN TRUST SERIES 2003-BC9 c/o WILSHIRE CREDIT CORP Plaintiff(s) From TODD A AND CARRIE PERRY, 5008 GREENWOOD CIRCLE, ENOLA P A 17025. (I) You are directed to levy upon the property ofthe defendant (s)and to sell REAL ESTATE LOCATED AT 5008 GREENWOOD CIRCLE, ENOLA PA 17025 (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 attaclunent 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $419,483.47 Interest FROM 6/30/04 = $12,933.13 L. L. $.50 Ally's Conun % Atty Paid $134.28 Plaintiff Paid Date: SEPTEMBER 8, 2004 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG 'j." Ory d~. By: . /. ~~ . Deputy / REQUESTING PARTY: Name STEPHEN M HLADIK ESQUIRE Address: 425 W MAIN ST POBOX 29 LANSDALE PA 19446-0029 Attorney for: PLAINTIFF Telephone: (215) 855-9521 Supreme Court lD No. 66287 Real Estate Sale #49 On September 09,2004 the Sherifflevied upon the defendant's interest in the real property situated in Hampden Tovmship, Cumberland County, P A Known and numbered as 5008 Greenwood Circle, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 09,2004 By: Jakj~~ Real EstaQ Deputy , , '1 ' ':' II iJ J I " . /_. ,) [1 -, '.... ,::C' (: , --j A; :., ;Jj: ~ ,.-' ~ c:;:;;:I c:;:;;:I c::::::J G:e> (t\@ REAL ESTATE SALE No. 49 Writ No. 2004-2321 ..CMlTenn laSalle Bank NatIonal ASsoc., . As 1'rusteefor.SlruClunId Asset ImleSlmentLoan 1hJst. SerIes.2OI)3.8C9 .. .. Va Todd A.P8irY. aitI CarrIe Perry Atty: ~_ ,Hladik' ' DESCRIPl10N " ..,...., ,,' AIL THOSE CFRfAIN lilIctof land, sitnaIe in Townsbip of ll.mpden.CinnberJand County. PeniJsyl.vaDia knowiIu Lot No.5 OIl SubdivWon Plan of GreenwOOd I'.slattsMmled in 1be Office of 1be~ofDeeds of Con1bedaI\d County in Plan BOok 76. Page 128. more particolady boondedanddesaibed ufol1ows:, IlEGlNNJNG at a point beillg1be Southwest comeroj'Lot No.4 on 1be.aforesaidPllln: tbenl:e SOllllr47degretli,5Sminm;4S $eOOIldS East along 1be said Lot No. 4 a distance of l7l,76fea to a point in 1be cul-de-sac ofOreellwooll CiroIe JIlllPOSOd; 1hepct a10nglbe CIIIVl' ot1be cuI~ a length of 104.99 feet with arndius.of 60feet 10 a proposed COIlCI"eIe 1>>.......... on the cuI-&-..., of Greenwood CiroIe JIlllPOSOd; thence South 31 ilegttes;. 49. minutes,. 00 $eOOIldS West. along fonnerly of Howell P. CaJperand Lynn P.CaJper, !lOI1b as degrees, 33 ~i49 .seoonds West a . <listance ofH2.4S feet to a point; lbence along lands .now or forinerly of Pamay . Development Conqlany.Inc, N'llI1h,U degrees. 34mjnutes, 54 seron4s East a distoce of370.69 feet to a poin~ thej"dace ofBEGlNN1NG. . CONTAINING tbmin 46,5Sp9'~ feet. IIlOI'e0l"kss, 01"1.0695 ~oreorIess. BElNOParee1 #1(\.J4.U84O.{)lllO BEING TIlE SAME preinises which KBO Associate<, u.c, a PA Limited Liability Company, bjideed dated 911112llO1 and MmIed 9113/2001 in 1be ~ of Deeds Office in and for Cumbedaild County, Pennsylvania, in Book 248 PageJSS2, gmnted and ~ unto Todd A. !'my and Carrie Pen)', husband and wife, as temmlsbythetJ1li1ely, . , i, . REAL ESTATE SALE NO. 49 Writ No. 2004-2321 Civil LaSalle Bank. National Assoc., as Trustee for Structured Asset Investment Loan Trust Series 2003- BC9 vs. Todd A. peny and Carrie peny Atty.: Stephen Hladik File No. LSTl79-906. EXHIBIT A ALL THOSE CERTAIN tract of land. situate in Township of Hamp- den, Cumberland County, Pennsyl- vania known as Lot No.5 on Subdi- vision Plan of Greenwood Estates recorded in the Office of the Record- er of Deeds of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows: BEGINNING at a point being the Southwest corner of Lot No.4 on the aforesaid Plan; thence South 47 degrees, 55 minutes, 45 seconds East along the said Lot NO.4 a dis- tance of 171. 76 feet to a point in the cuI-de-sac of Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 104.99 feet with a radius of 60 feet to a proposed concrete monument on the cuI-de-sac of Greenwood Circle pro- posed; thence South 31 degrees, 49 minutes, 00 seconds West along for- merly of Howell P. Carper and Lynn P. Carper, north 85 degrees, 33 min- utes, 49 seconds West a distance of 112.45 to a point; thence along lands now or formerly of parnay De- velopment Company, Inc, North II degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a point, the place of BEGINNING. CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less. BEING PARCEL Number 10-14- 0840-0100. BEING THE SAME premises which KBG Associates, LLC, a PA Limited Liability Company, by deed dated 9/11/200 I and recorded 9/ 13/2001 in the Recorder of Deeds Office in and for Cumberland Coun- ty, Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and wife as lenants by the entirety. .