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HomeMy WebLinkAbout09-7098 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 U,ArMART 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 Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION Securitized Asset Backed Receivables LLC 2005-OP1 =Cumberland Mortgage Pass-Through Certificates, Series 2005-OP1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff V. Rohan Dookharan County 2 Lilac Drive NO. (R - 7098 Mechanicsburg, PA 17050 Defendant(s) 0_"v; l term 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 f_, 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 demands 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 provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IIMEDIATI°i1HENTE, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 E 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 f 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the mortgage and is in the process of formalizing the Assignment of Mortgage to be sent 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: 2 Lilac Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 10/28/04 DATE RECORDED: 10/29/04 BOOK: 1886 PAGE: 173 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: (a) by failing or refusing to pay the installments of E 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 9/29/09: Principal of debt due $143,757.85 Unpaid Interest at 7.25% from 4/1/09 to 9/29/09 (the per diem interest accruing on this debt is $28.55 and that sum should be added each day after 9/29/09) 5,170.78 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $238.71 and that sum should be added on the first of each month after 9/29/09) 443.92 Late Charges (monthlyy late charge of $61.89 should be added in accordance with the terms of the note each month after 9/29/09) 309.45 Recoverable Balance 100.00 Attorneys Fees (anticipated and actual to 5% of principal) 7,187.89 TOTAL $157,574.89 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 $157,574.89 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premje OFFIAS, P.C. Attorney for Plaintiff MARK J. REN, ESQUIRE L,&rTART 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 r EF Sep-30-2009 01:06pm Frm- T-767 P.011/011 F-024 ALL THAT CERTAIN trail o? parcel of band end pmmM%.s&xft, "V pnd burp tan the Tovmeldp of swer Spring m the cm* of cm trberiew. 0n4 Corrtmoraeal? of pm mWli enia, ,? pW&Ulariy deser bad as lonows: BEGINNING at a point onto no * We of L+iac Drive (50eAwide) atthe dividing One beIwaen Lot Not. 27 end 28 on to haralruMer rnaneoned plan of t,tarroe WoM the dividing ime behmm Lot Nos. 27 and 28, North 28 degrom 38 mhAft 43 -scion rim V%*, the di a of 137.00 iset to a poW mt the divldirllp mine bll~ Lilt Noss. 28 end 29 on said plan; dvm* mWg sold *Aft line, North 81 ftmes 21 wk who 17 a mda East, the dletanoe of 81.00 felet io o point on ft W %VwV elide of9vjb@rq Oda; thence along the said side of Bayberry Ddve, South 28 ft - m e 38 nrUr tA& 43 mea m 1 As Eat, the distance of 125.00 fWA; therms akwq the same and aoM the arc of a owve having a r KHm of 12.00 feat the arc donee of 18.86 fiat I* a point an the said side of LYac Drive; thence akq; the old We of LHae Drive, South (erroneously rsfen to a North in the previous deed) 81 degrees 21 mleMa 17 eaeonds Want (wroneoLoV nelerred to as East in the prevkx s deed), the dWimm of 69.04 feet to a pakA. U* pkm afBECINNING. BEING Lot No. 28 an the Plan of Mdbarry Croeaft, me recorded in Plan Book 40, Pop W. BEING known as No. 2 Lila Drive,1-1 .oebura, pensykania. I Certify this to be recorded fn Cumberland County PA vK.j'•f3;-0 1,83 09m2009 12:93:21 PM f CUMBERLAND COUNTY -` _ Inst.P 200444012 - Page 11 of 11 f,? A-URdl August 12, 2009 7104 5400 2100 2274 6168 I pip . 2 3 8 6 5 4 Rohan Dookharan 2 Lilac Dr Mechanicsburg, PA 17050-3169 August 12, 2009 TM -N 0 1 T Aff A T H A E IPIR F Ou I& t?,W This is an ojfuial notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE THREE The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to 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 33 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 (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 NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Rohan Dookharan 2 Lilac Dr Mechanicsburg, PA 17050 0014555171 Option One Mortgage Corporation American Home Mortgage Servicing, Inc. EXHIBIT A Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM 0014555171 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 the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). 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 THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 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 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 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). 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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 YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITIONINBANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) C Page three 0014555171 , HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2 Lilac Dr, 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: (a) Monthly payments from 05/01/2009: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 08/11/2009: $5,080.76 $185.67 $100.00 $0.00 $5,366.43 HOW TO CURE THE DEFAULT -You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,366.43, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: American Home Mortgage Servicing, Inc. 1525 S. Beldine Rd. Coppell, TX 75019 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the 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 property IF THE MORTGAGE IS FORECLOSED 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) DA Yperiod, 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 SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod 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 then past due, plus any late or other charges then 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 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 five (5) 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. Page four 0014555171 HOW TO CONTACT THE LENDER Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-866-612-3730 Fax Number: 1-866-497-1263 Contact Person: Trivonda Porter, Sara Haliko and Selena Moore E-mail Address: Trivonda.porter@ahmsi3.com4 Sara.haliko@ahmsi3.com, selena.moore@ahmsi3.com 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 belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOUMAYALSO 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 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019,1-866-612-3730 f * Indicates Counties Serviced Acorn Housing Corporation r 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 *Bucks, Chester, Delaware, Montgomery, Philadelphia Action Housing Inc 425 8th Avenue, Suite 950 Pittsburgh, PA 15219 (412) 281-2102 *Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 3341518 *Adams, Cumberland, Franklin, York Advocates for Financial Independence 1806 S Broad Street, Suite 1 B Philadelphia, PA 19145 (215) 389-2810 *Philadelphia Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 (215) 389-2810 *Delaware Allegheny County Acorn 5907 Penn Avenue, Suite 300 Pittsburgh, PA 15206 (412) 441-6551 'Allegheny American Credit Counseling Institute 21 S Church Street West Chester, PA 19380 (888) 212-6741 'Chester American Credit Couseting Institute 526-528 Dekalb Street Norristown, PA 19401 (610) 971-2210 (888) 212-6741 *Montgomery, Delaware Amedcan Credit Counseling Institute 530 W Street Road, Suite 201 Warminster, PA 18974 (215) 444-9429 (888) 212-6741 Bucks, Montgomery, Philadelphia American Credit Counseling Institute 937 North Hanover Street Pottstown, PA 19460 (888) 212-6741 'Barks, Bucks, Montgomery American Credit Counseling Institute 229 East Chestnut Street Coatesville, PA 19320 (888) 212-6741 *Chester, Lancaster Amedcan Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267)228.7903 *Mifflin American Financial Counseling Services 405 West Germantown Pike Norristown, PA 19403 (267) 228-7903 *Mt18in, Montgomery American Financial Counseling Services 2880 Bergey Road Suite 4 Hatfield, PA 19440 (267) 228-7903 *Barks, Chester, Montgomery American Financial Counseling Services 175 Strafford Avenue, Suite One Wayne, PA 19087 (610) 971-2210 (888) 212-6741 *Bucks, Chester, Delaware, Mongomery, Philadelphia American Financial Counseling Services 906 Penn Avenue Wyomissing, PA 19610 (267) 228-7903 (800) 490-3039 Barks Amedcan Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267) 2267903 *Montgomery American Financial Counseling Services 1917 Welsh Road Philadelphia, PA 19115, PA 19610 (267) 2267903 *Bucks, Montgomery, Philadelphia American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 'Adams, Franklin, York American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 (610) 874-1484 *Chester, Delaware APM 2147 Norht Sixth Street Philadelphia, PA 19122 (215) 235-6788 `Chester, Delaware, Philadelphia, Bucks Armstrong CO Community Action Agency 124 Arnsdaie Road, Suite 211 Kittanning, PA 16201 (724) 548-3405 *Armstrong Base, Inc. 447 South Prince Street Lancaster, PA 17603 (717) 392-5467 *Lancaster Blair County Community Action Agency 2100 6th Avenue, Suite 102 P.O. Box 1833 Altoona, PA 16602 (814) 946-3651 *Blair Booker T. Washington Center 1720 Holland Street Ede, PA 16503 (814)453.5744 'Crawford, Erie, Warren Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 (866) 866-0280 *Bucks Bucks County Housing Group 2324 Second Street Pike, Suite 17 Wrightstown, PA 18940 (866) 866-0280 *Bucks Bucks County Housing Group 470 Oki Dublin Pike Doylestown, PA 18901 (866) 8660280 *Bucks Bucks County Housing Group 349 Durham Road Penndel, PA 19047 (866) 8660280 *Bucks Bucks County Housing Group 515 West End Blvd Quakertown, PA 18951 (866) 866-0280 *Bucks Budget Counseling Center 247 North Fifth Street Reading, PA 10601 (610) 375-7666 *Barks, Chester, Schuylkill Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 (215) 877-1157 `Chester, Delaware, Philadelphia Catholic Social Services Saint Catherine Manor 5 Knox Road Scranton, PA 18505 (570) 558-3019 *Wyoming, Wayne, Bucks, Lackawanna, Monroe, Philadelphia CCCS of Delaware Valley 1230 New Rodgers Road, Suite F1 Bristol, PA 19007 (215) 563-5665 *Bucks CCCS of Delaware valley 1777 Sentry Parkway W, Suite 200 Blue Bell, PA 19422 (215) 563-5665 *Montgomery CCCS of Delaware Valley 280 North Providence Road Media, PA 19083 (215) 663-5665 *Chester CCCS of Delaware Valley Marshal Building 790 E Market St, Suite 170 West Chester, PA 19382 (215) 563-5665 *Chester, Bucks CCCS of Delaware Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215) 563-5665 *Bucks, Philadelphia CCCS of Delaware Valley One Cherry HIII, Suite 215 Cherry Hill, PA 08002 (215) 563-5665 'Philadelphia CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 821-4011 (800) 837-9815 *Barks, Bucks, Carbon, Lancaster, Lehigh, Northhampton, Schuylkill CCCS of Northeastern PA 201 Basin Street, Suite 6 Williamsport, PA 17701 (570) 323-6627 *Centre, Clinton, Lyooming, Northumberland, Union CCCS of Northeasters PA 202 W Hamilton Avenue State College, PA 16801 (814) 2363668 *Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Northeasters PA 401 Laurel Street Pittston, PA 18640 (570) 602-2227 *Bradford, Carbon, Columbia, Lackawanna, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeasters PA 411 Main Street, Suite 104 Stroudsburg, PA 18360 (570) 420-8980 *Bradford, Carbon, Monroe, Pike, Wayne CCCS of Western PA 1 North Gate Square #2 Garden Center Dr Greensburg, PA 15601 (888) 511-2227 'Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Western PA 55 Clover Hill Road Dallastown, PA 17313 (888)511-2227 'Fulton, Crawford, Lancaster E' * Indicates Counties Serviced CCCS of Western PA 2000 Linglestovm Road Harrisburg, PA 17102 (888) 511-2227 *Adams, Cumberland, Dauphin, Franklin, Perry, Synder, York CCCS of Western PA 312 Chestnut Street, Suite 227 Meadville, PA 16335 (888)511-2227 *Lawrence CCCS of Western PA 41 East Chestnut Street Washington, PA 15301 (888) 511-2227 'Westmoreland CCCS of Western PA 4402 Peach Street Erie, PA 16509 (888) 511-2227 *Crawford, Erie, Warren CCCS of Western PA 524 Franklin Avenue Aliquippa, PA 15001 (888) 511-2227 *Cambria CCCS of Western PA 917 A Logan Boulevard Altoona, PA 16602 (888) 511-2227 *Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Union CCCS of Western PA Pullman Commerce Center 112 Hollywood Dr Butter, PA 16001 (888) 511-2227 *Butier, Clarion, Jefferson, Mercer, Venango CCCS of Western PA River Park Commons 2403 Sidney Street Pittsburgh, PA 15203 (888) 511-2227 'Allegheny Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 (814) 337-8450 *Columbia, Venango Centro Pedro Clever, Inc 627 West Erie Avenue Philadelpia, PA 19140 (215) 227-7111 *Philadelphia Chester Community Improvement Project 412 Avenue of the States P.O. Box 541 Chester, PA 19016 (610) 8768663 'Chester, Delaware, Montgomery, Philadelphia Comm. On Econ Opportunity of Luzems Co. 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 'Carbon, Luzeme, Schuylkill, Wyoming Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17094 (717) 232-9757 'Cumberland, Dauphin, Franklin, Perry, Synder Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehem, PA 18015 (610) 691-5620 *Barks, Carbon, Lehigh, Monroe, Northampton Community Action Development Comm - CADCOM 113 E Main Street Norristown, PA 19401 (610) 277-6363 *Montgomery Community Action Southwest 150 W Beau Street, Suite 304 Washington, PA 16301 (724) 225-9550 'Monroe Community Action Southwest 58 E Greene Street Waynesburg, PA 15370 (724) 852-2893 'Allegheny, York, Fayette, Greene, Washington, Westmoreland Comm. on Econ. Opportunity of Luzeme County 163 Amber Lane WllkesBarre, PA 18702 (570) 826-0510 (800) 822-0359 'Wyoming Congreso 216 West Somerset Street Philadelphia, PA 19133 (215) 763-8870 'Philadelphia Council of Spanish Speaking Organization 705-09 North Franklin St Philadelphia, PA 19123 (215) 627-3100 'Philadelphia Credit Counseling Center 832 Second Street Pike Richboro, PA 18954 (215) 3961880 *Bucks Diversified Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 (215) 3363511 *Bucks, Chester, Delaware, Philadelphia Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 Liberity Ave., Suite 205 Pittsburgh, PA 15222 (412) 391-2535 *Allegheny Fayette Co. Community Action Agency Inc 137 North Beeson Avenue Uniontown, PA 15401 (724) 437-6060 'Fayette, Somerset FOB CDC 1201 West Only Avenue Philadelphia, PA 19141 (215) 549-8755 'Bucks, Chester, Delaware, Philadelphia Garfield Jubilee Associates 5138 Penn Avenue Pittsburgh, PA 15224 (412) 865-5200 'Allegheny Germantown Settlement 5538 Wayne Avenue Bldg C Philadelphia, PA 19144 (215)849.3104 'Bucks, Chester, Delaware, Montgomery, Philadelphia Greater Erie Commun. Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 'Crawford, Erie, Venango, Warren HACE 167 W Allegheny Ave., 2nd Floor Philadelphia, PA 19140 (215) 426-8025 *Bucks, Chester, Delaware, Philadelphia Hispanic Alliance for Community Advancement 2740 North Front Street Philadelphia, PA 19133 (215) 667-8932 'Monroe Housing Assoc. of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 'Philadelphia, Monroe Housing Opportunities of Beaver Co. 320 College Avenue, Unit 1 Beaver, PA 15009 (724) 728-7511 *Beaver. Lawrence Housing Partnership of Chester County 41 West Lancaster Avenue Downingtown, PA 19335 (610) 518-1522 'Chester, Delaware, Montgomery ` 4 Indiana Co. Community Action Prog. 827 Water Street Box 187 Indiana, PA 15701 (724) 465-2657 *Amnstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services Inc. 4225 Chestnut Street Philadelphia, PA 19104 (215) 3861298 'Philadelphia Korean Comm. Develop. Services Center 6055 North 5th Street Philadelphia, PA 18505 (215) 276-8830 'Philadelphia Lawrence County Social Services, Inc. 241 West Grant Street P.O. Box 189 New Castle, PA 16103 (724) 658-7258 'Lawrence Liberty Resources 714 Market Street, Suite 100 Philadelphia, PA 19106 (215) 634-2000 *Philadelphia Loveship, Inc. 2320 North 5th Street Harrisburg, PA 1711 (717) 232-2207 *Cumberand, Dauphin, Perry Lycom-Clntn Co Comm to Comm Action 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 (570) 3260587 'Centre, Clinton, Lycoming, Union Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 *Adams, Cumberland, Franklin, Fulton, Perry Media Fellowship House 302 South Jackson Street Media, PA 19063 (610) 565-0434 'Chester. Delaware Mon Valley Unemployment Committee 1800 West St., 3rd Floor Homestead, PA 15120 (412) 462-9962 'Allegheny, Washington, Westmoreland Mt. Airy, USA 6703 Germantown Ave., Suite 200 Philadelphia, PA 19119 (215) 844-6021 *Philadelphia Nazareth Housing Services 301 Bellevue Road Pittsburgh, PA 15229 (412) 931-6996 'Atiegheny * Indicates Counties Serviced reighb?rhood Housing Services of Reading 213 N Sth St., Suite 1030 Reading, PA 19601 (610) 372-8433 `Barks C PHFA 211 North Front Street Harrisburg, PA 17110 (800-) 342-2397 `Cumberland, Dauphin Philadelphia Council for Comm. Advmnt 100 N 17th St, Suite 600 Philadelphia, PA 19103 (215) 567-7803 (800) 930-4663 'Chester, Delaware, Montgomery, Philadelphia The Trehab Center of Northeastern PA 10 Public Avenue P.O. Box 366 Montrose, PA 18801 (570) 278-3338 (800)982.4045 'Susquehanna The Trehab Center of Northeastern PA 115 SR 92S Tuckhannock, PA 18657 (570) 836-6840 (800) 982-4045 'Wyoming The Trehab Center of of Northeestem PA 1225 Main Street Honesdale, PA 18431 (570) 253-8941 (800) 982-4045 'Bradford, Sullivan, Susquehanna, Toga, Wayne, Wyoming The Trehab Center of Northeastern PA 144 E East Avenue Wellsboro, PA 16901 (570) 724-5252 (800) 982-4045 `Tioge The Trehab Center of Northeastern PA German Street P.O. Box 389 Dushore, PA 18614 (570) 928-9667 (800) 982-4045 'Sullivan Philadelphia Senior Center 509 South Broad Street Philadelphia, PA 19147 (215) 546-5879 `Philadelphia Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 (570) 622-1995 'Barks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 981-5310 'Crawford, Lawrence, Mercer South Philadelphia H.O.M.E.S. 1444 Point Breeze Avenue Philadelphia, PA 19146 (215) 334-4430 'Philadelphia The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Ave., Suite M-6 Sayre, PA 18840 (570) 888-0412 (800) 982-4045 'Bradford United Communities Southeast Philadelphia 2029 South 8th Street Philadelphia, PA 19148 (215)467-8700 `Philadelphia Urban League of Philadelphia 1818 Market Street Philadelphia, PA 19103 (215) 561-8070 'Bucks, Delaware, Philadelphia Neighborhood Housing Services, Inc. 710 5th Avenue, Suite 1000 Pittsburgh, PA 15219 (412) 281-9773 'Allegheny New Kensignton Community Development 2515 Frenkford Avenue Philadelphia, PA 19125 (215) 427-0350 'Warren The NORCAM Group 4200 Crawford Avenue Suite 200 Northam Cambria, PA 15714 (814)948-4444 'Cambria, Clearfield Northern Tier Community Action Corp. 135 West 4th Street P.O. Box 389 Emporium, PA 15834 (814) 4861181 'Cameron, Elk, Mckean, Potter Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia Nueva Esperenza 4261 North 5th Street Philadelphia, PA 19140 (215) 324-0746 'Philadelphia Opportunity Inc. 301 East Market Street York, PA 17403 (717) 424-3645 `Montgomery The Partnership CDC 4020 Market Street, Suite t00 Philadelphia, PA 19104 (215) 662-1612 'Monroe Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd., Bldg 200 Pittsburgh, PA 15220 (412) 429-2842 'Allegheny Southwest Community Development Corp. 6368 Paschall Avenue Philadelphia, PA 19142 (215) 729-0800 'Montgomery St. Martin Center 1701 Parade Street Ede, PA 16503 (814) 452-6113 `Crawford, Erie, Venengo, Warren Tableland Services Inc. 535 East Main Street Somerset, PA 15501 (814) 445-9628 'Cambria, Fayette, Somerset, Westmoreland Tabor Community Services 308 E King Street, Suite 1 Lancaster, PA 17602 (717) 397-5182 (800) 788-5062 'Chester, Lancaster, Lebanon United Neighborhood Centers of Northeastern PA 425 Alder Street Scranton, PA 18505 (570) 346-0759 'Lackawanna, Wyoming, Wayne, Luzeme Urban League of Philadelphia 610 Wood Street Pittsburgh, PA 15229 (412) 931-6996 'Allegheny Voices for Independence 1107 Payne Avenue Erie, PA 16503 (814) 874-0064 (800) 838-9890 'Ede Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave W. P.O. Box 547 Warren, PA 16365 (814) 726-2400 'Forest, Waren West Oak Lane CDC 6259 Limekiln Pike Philadelphia, PA 1914 (215) 224-0880 `Monroe I .. 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 relati to unsworn falsification to authorities. UDREN FIC P. C, ,-- / BY: A;t?to Cdr Plaintiff J. UDREN, ESQUIRE LeTUART 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 `./ f ILED - vC ? t, i 2 014GC1 16 AM 10: 15 +98.5o PA A-rW 1.38913 a . daa, 3'7 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OFFICE € THE »ERIf fi 2009 OCT 20 AN 9: 50 Edward L Schorpp Solicitor Wells Fargo Bank, NA vs. Rohan Dookharan Case Number 2009-7098 SHERIFF'S RETURN OF SERVICE 10/16/2009 09:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2009 at 2120 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rohan Dookharan, by making known unto himself personally, at Cumberland County Prison 1101 Claremont Road Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 SO ANSWERS, October 19, 2009 R THOMAS KLINE, SHERIFF By t Sheriff 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National 'COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION Securitized Asset Backed :Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 ::NO. 09-7098 Civil Term Plaintiff V. Rohan Dookharan 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: November 17, 2009 UDREN P . C. C-BY: 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 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 persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date : ©CT• P..1PV_ 30?` aC) © q 1 _4?' Name : athy Smi Tit 1 e :Assistant Secretary Company: American Home Mortgage Servicing, Inc. as servicer on behalf of Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 Rohan Doorkharan Loan #0014555171 MJU #09090440-1 OF T#U*rlCE T 2109 NOV 17 AM I©: 4 5 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION Securitized Asset Backed :Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through :MORTGAGE FORECLOSURE Certificates, Series 2005-OP1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff V. Rohan Dookharan ::NO. 09-7098 Civil Term 2 Lilac Drive Mechanicsburg, 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) Rohan Dookharan 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 $157,574.89 Interest Per Complaint 1,398.95 From 9/30/09 to 11/17/09 Late charges per Complaint 123.78 From 9/30/09 to 11/17/09 Escrow payment per Complaint 477.42 From 9/30/09 to 11/17/09 TOTAL $159,575.04 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAR-.-4 C . ('BY: h . 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 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : ?QZd%?+•li?C l 1 a60 ` e/ &?- ?- .Z? ' PRO PROTHY 61/ 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 pleadingsoudren.com Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff V. Rohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF ._«,. ? t, t -.. n y ?ni ' w _-- :.3 "t. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. CIA - ICA 8 & i V ? (-Ferm 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 Sheriffs Office of Cumberland County R Thomas Kline Sheri of ctm,?'4f4? Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant r r~E OF THE srtsniFr Edward L Schorpp Solicitor Wells Fargo Bank, NA vs. Rohan Dookharan Case Number 2009-7098 SHERIFF'S RETURN OF SERVICE 10/1612009 09:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2009 at 2120 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rohan Dookharan, by making known unto himself personally, at Cumberland County Prison 1101 Claremont Road Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 SO ANSWERS, f -000? 41 October 19, 2009 R THOMAS KLINE, SHERIFF By Dgftjt3K Sheriff UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUARV WINNEG, ESQUIRE - ID #45362 LORRArNE 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 BILL, NJ 08003 856-669-5400 1 ad; ng-gMudren _ com Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgqa e Pass- Through Certificates, Series 205-OP1 Plaintiff V. Rohan. Dookharan Defendant(s) TO: Bohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 Date of Notice: November 6, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-7098 Civil Term 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 DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND S AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE US FO 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 Corporate 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 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 nPr?(?udr n om Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortggagge Pass- Through Certificates, Series 20D5-OP1 Plaintiff V. Rohan Dookharan Defendant(s) TO: Cumberland County Prison c/o Rohan Dookharan 1101 Claremont Road Carlisle, PA 17013 Date of Notice: November 6, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-7098 Civil Term 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 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND S AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE US FO TF4 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 ill 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 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for ?CIVIL DIVISION Securitized Asset Backed =Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through =MORTGAGE FORECLOSURE Certificates, Series 2005-OPI P.O. Box 961730 4 Irving, TX 75063-1730 NO.(Dj -'-d-(l b C l Vt' e?M Plaintiff V. Rohan Doorkharan 2 Lilac Drive Mechanicsburg, PA 17050 Defendant(s) STATE OF COUNTY OF 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: AFFIDAVIT OF NON-MILITARY SERVICE Rohan Doorkharan Over 18 As captioned above Unknown Sworn to and subscribed ed- before me this 30 da of ®GCrO a-P_V__, 200? C zg? ame : Kathy s -th Title: Assista Company: V'ATMn Home Mortgage Servicing, Inc. as servicer on behalf of Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 LINDA BAYLESS Z N Notary Public, State of Florida Commission* OD6159W My comm. expires Nov. 19, 2010 F,` E F THE "'MTAOY, 269 NOY 17 AM iO: 4 6 cm 9 ?? 0 D Pct dA/ Urlre ,ems x-33 67/ N,4?,- es nut/cJ 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION Securitized Asset Backed :Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through :MORTGAGE FORECLOSURE Certificates, Series 2005-OP1 Plaintiff V. Rohan Dookharan :NO. 09-7098 Civil Term Defendant(s) TO: Rohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDR.= LAW OFFICES, P.C. MAXV J. UDREN, ESQUIRE - ID #04302 STUP+AT WINNEG, ESQUIRE - ID #45362 LOP-MINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHA ZRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOOEXREST CORPORATE CENTER ATTORNEY FOR PLAINTIFF 11L TOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856 -669-5400 Dleaiinqs@udren.com Wells Fargo Bank, National Association as Trustee for Se curitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Rohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 NO. 09-7098 Civil Term 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) Rohan Dookharan 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 $157,574.89 Interest Per Complaint 1,398.95 From 9/30/09 to 11/17/09 Late charges per Complaint 123.78 From 9/30/09 to 11/17/09 Escrow payment per Complaint 477.42 From 9/30/09 to 11/17/09 TOTAL $159.575.04 I hereby certify that (1) the addresses of the Plaintiff and Def eodant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LA?-0• C . (,BY: 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 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE e dbfb(_t a&d 7 PRO PROTHY 1 4 ^ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID 045362 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION Securitized Asset Backed :Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through :MORTGAGE FORECLOSURE Certificates, Series 2005-OP1 Plaintiff V. Rohan Dookharan Defendant(s) :NO. 09-7098 Civil Term TO: Rohan Dookharan Cumberland County Prison c/o Rohan Dookharan 1101 Claremont Road Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Ju, Judgment Judgment Judgment Judgment Judgment Prothonotary 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 UDP-30 LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - STLT-JUT WINNEG, ESQUIRE - LORRIINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHA"RA M. ARKEMA, ESQUI; LOU18 A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE - WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff v. Rohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 ID #04302 ID #45362 - ID #34576 - ID #75860 RE - ID #203437 - ID #200869 ID #86408 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-7098 Civil Term 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) Rohan Dookharan 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 $157,574.89 Interest Per Complaint 1,398.95 From 9/30/09 to 11/17/09 Late charges per Complaint 123.78 From 9/30/09 to 11/17/09 Escrow payment per Complaint 477.42 From 9/30/09 to 11/17/09 TOTAL $159,575.04 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAY.+L...4E- C . ,, (BY: 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 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : NOJenµ?-_r 171 o441? %Sl PRO PROTHY /?L 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 - 2D #204460 c';. WOODCREST CORPORATE CENTER -;'' ~' 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 -- Wells Fargo Bank, National Association as :COURT OF COMMON PLFrAS Trustee for Securitized Asset Backed ;CIVIL DIVISION -- , Receivables LLC 2005-OPl Mortgage Pass- :Cumberland County = Through Certificates, Series 2005-OP1 ~' P.O. Box 961730 Irving, TX 75063-1730 Plaintiff v. Rohan Dookharan 2 Lilac Drive :'NO. 09-7098 Civil Term Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO P8.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: c~ ~ ~_ i ~_ ' r: u~ T) - _ _.s ::- =! c.~ c, .. 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: January 22, 2010 UDR ICES, P.C. BY: ' Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE "^'~JIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 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 Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005- OP1 Plaintiff v. Rohan Dookharan Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-7098 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Rohan Dookharan PROPERTY: 2 Lilac Drive, (Silver Spring Township) Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 3. 2010, at 10:00 A.M., in the Commissioner's 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. p - ., ,-w ~ ~ ~t ~ _" ~ K~ 4, v 2 g.~ Z7 0 s m ~~ O O O O 0 O n c v- (D 7 Q. 0 w 00 V V TI (D Q c v T O 3 c N Q' ID n O .a ~o a ~C C 7 O 3~ fD 7 Vi o m CT A W N ~ ~ W Oo V ~ Cn ~ W N ~ r p Z m Q ' ~ -" a d ~°"m c ~ ( nc w 0 CD c~ Nair m ° ~' C m m , ~ j W 0D mC~ fD N ~ ^ ~ ~ ~~C~ tnv c~c~ z Z v~ D o m~ m~ ~ m ° ~ 2~~ ~° rv C~ ~ ~ Z °:Q ~ y .~ a omZ D v n n ~3 O ~ ~- ~ N ~m r mv y = ~~~ m ~~. ~ n W w m ~ cnn y ~ m ~ ~~ p~ - p C7 ~~ D r ~_ fJ O ~ r ~g 'off C =f11~ mo DZ ~ n ~~~ ~N D~ D v D= C Dczi~ z~ m o - 'o zOD~ ~ n ~ ~. 3 O ° m ~ o ~~ ~j ~O~ ~ ccmi w~ ay ~ a 3 wtnv i m OC p ~ D r ~ R `~ w~ ~~~ ° r p Z r~ C) m. 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N ~ N ~.N '~ m m w o n m o' ~ o a fD fD 77 O~ ~ ~'fG - y a `~'~ N Oa ~ m ~ ~ n~ j'° ~ m Ti(n Nv D Q f f~D ' sd~d=3 V1 .~. a ~ - m 2 °--'~ m 3 y 3 ~'I fA N~ m m o ~ m ~ o ~' m 3 ~° ~ ~ H ~_ 3 mmmnvs~ $0"~~03 n .Z7 .Z7 w _ N C1 ?. 3 m u °o ~ m ~ o ° ~ ~ a: ~ r.,:.~ ~w, ~ m ~- ~ ~p f6 m O m m ~ a ~ ~ t ~ 4'`3 ~ ~ ry! ~ m m m ° ~~ 6' ~~ ~ N -., . w. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~'~' . ~ ~.. Ronny R Anderson Sheriff ~~~~ti~,,~ of ~iuni~ry,~~~~~ Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~ ~ ~ : ~ -~ ~ ~ ~ ~°~ Wells Fargo Bank, NA vs. Rohan Dookharan SHERIFF'S RETURN OF SERVICE Case Number 2009-7098 12/17/2009 05:36 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1743 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Rohan Dookharan, located at, 2 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 12/17/2009 05:36 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1743 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Rohan Dookharan, by making known unto, Rohan Dookharan, personally, at, 2 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. ~:-~ ~. ,~r,} Coi.inrySuitc Shen.`f. Te:ansoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY • Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOllCItOf ~.°~'t~~r 4t ~ua~6Pr~~ ,= w . • r7 /fai ~ ~} r Y~ 49I=f I~.E r'ryHe S~ERIf:F ~~'_- ,~- YF':~ ~~ ~:~~ ~_._ ~ f ,~ ~-` Prw y~,~`~ p, .Tl' t' ~ _ ~,; ~ 4~, -• r'__ '"~ Wells Fargo Bank, NA vs. Rohan Dookharan Case Number 2009-7098 SHERIFF'S RETURN OF SERVICE 12/17/2009 05:36 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1743 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Rohan Dookharan, located at, 2 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 12/17/2009 05:36 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1743 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Rohan Dookharan, by making known unto, Rohan Dookharan, personally, at, 2 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/03/2010 Property sale postponed to 4/7/2010. 04/05/2010 Property sale postponed to 5/5/2010. 05/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on May 5, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Alan Minato, on behalf of Wells Fargo Bank, N.A., as Trustee for Securitized Asset Backed Receivables, LLC, Trust 2005-OP1, Mortgage Pass-Through Certificates, Series 2005-OP1, 4600 Regent Blvd, Ste 200, Irving, TX 75063, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 950.77 SHERIFF COST: $950.77 July 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~f~~ D~ po(. Q~. a.oa pat . G~. . 5~ LL pd r!J~ 7731 ~ ~~s~i~ (c? CountySuile Sheriff. Teleosoft. Inc. ` ~, ' UpREN LAW OFFICES, P.C. I~,RR !J. UDREN, ESQUIRE - ID #04302 3TUART WINNRG, $SQUIRE - ID #45362 LORRAINE DOYI,E, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAPES, ESQIIIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 Plaintiff v. Rohan Dookharan Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. 09-7098 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1, 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: 2 Lilac Drive, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Rohan Dookharan 2 Lilac Drive Mechanicsburg, PA 17050 Cumberland County Prison c/o Rohan Dookharan 1101 Claremont Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage r of record: Name ~. Address Wells Fargo Bank, P.O. Box 961730 National Association as Irving, TX 75063-1730 Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. 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 2 Lilac Drive Mechanicsburg, PA 17050 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 17, 2009 UDRFN....._Fr.~W"'." P . C . ~.__ . BY 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 UDREN LAW OFFICES P C ATTORNEY .FOR PLAINTIFF t MARK J. UDREN, TSQUIRE - ID #04302 STUART WINN'l~G, ESQUIRE - ID #45362 'i,ORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860. CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ' LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAYES, ESQUIRE - ID #86408- WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20.0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udrea.com Wells Fargo Bank, National SCOURT OF .COMMON PLEAS Association as Trustee for €CIVIL DIVISION Securitized Asset Backed :Cumberland County Receivables LLC 2005-OP1 Mortgage Pass-Through ;MORTGAGE FORECLOSURE Certificates, Series .2005-OP1 Plaintiff v. Rohan Dookharan Defendant(s) NO. 09-7098 Civil Term NOTICE OF SH$RIFF'S SALE OF REAL PROPERTY TO: Cumberland County Prison c/o Rohan Dookharan 1101 Claremont Road Carlisle, PA 17013 Your house (real estate) at 2 Lilac Drive (Silver Spring Township)Mechanicsburg, PA 17050 is scheduled to be sold--at the Sheriffs Sale on March 3, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse,. Carlisle, PA, to enforce the court judgment of $159,575..04, obtained by Plaintiff above ( he 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 actioa: 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: f856)` 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.) .YOII iKAY STILL BE ABLE TO SAVE YOIIR PROPERTY AND YOII 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 wi1T be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money wi1T be paid out in accordance with this schedule unless exceptions {reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (TO) 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. YOII SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT SAVE A LAWYER OR CANNOT AFFORD ONE, GO'TO OR TELEPHONE TFiB OFFICE LISTED BELOW TO FIND OUT WHERE YOII CAN GET LEGAL HELP. LAWYER REFERRAL 38RVICE 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 r A L AI,L THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF SILVER`SPRING IN THE COUNTY OF CEMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: .BEGINNING AT A POINT ON THE NORTHWESTERLY SIDE OF LILAC DRIVE (50 FEET WIDE), AT THE DIVIDING LINE BETWEEN LOT NOS. 27 AND 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE. BETWEEN .LOTS NOS. 27 AND 28, NORTH X28 DEGREES 38 MINUTES 43 SECONDS WEST, THE DISTANCE OF 137.00-FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOT NOS. 28 AND 29 ON SAID PLAN; THENCE AZONG SAID DIVIDING LINE, NORTH 61 DEGREES 21 MINUTES 17 SECONDS .EAST, THE DISTANCE OF 81:00 FEET TO A POINT ON THE WESTERLY SIDE OF BAYBERRY DRIVE; THENCE ALONG THE SAID SIDE OF BAYBERRY DRIVE, SOUTH 28 DEGREES 38 MINUTES 43 SECONDS EAST, THE DISTANCE OF 125.00 FEET; THENCE ALONG THE SAME AND ALONG THE ARC OF A CURVE HAVING A RADIUS OF 12.00 FEET, THE ARC DISTANCE OF 18.85 FEET TO A POINT ON THE SAID SIDE OF-LILAC DRIVE; THENCE ALONG SAID SIDE OF LILAC DRIVE, SOUTH (ERRONEOUSLY REFERRED TO A NORTH IN THE PREVIOUS. DEED) 61 DEGREES 21 MINUTES 17 SECONDS WEST (ERRONEOUSLY. REFERRED TO AS EAST IN THE PREVIOUS DEED ), THE DISTANCE OF 69.00 FEET TO A POINT THE PLACE OF BEGINNING. BEING LOT NO. 28 ON THE PLAN OF MULBERRY CROSSING, AS RECORDED IN PLAN BOOK 40, PAGE 142. BEING KNOWN AS NO. 2 LILAC DRIVE, MECHANICSBURG, PENNSYLVANIA BEING KNOWN AS: 2 Lilac Drive, Mechanicsburg, PA 17050 PROPERTY ID NO.: 38-21-0289-078 TITLE TO SAID BREMISES IS VESTED IN ROHAN DOOKHARAN, MARRIED MAN BY DEED FROM LYNNE A. SHELLENBERGER, FORMERLY LYNNE A. TAYLOR AND BARRY L. SHELLENBERGER, WIFE AND HUSBAND DATED 10/28/04 RECORDED 10/29/04. IN DEED BOOK-265 PAGE 4877. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-7098 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR SECURITIZED ASSET BACKED RECEIVABLES LLC 2005- OPiMORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-OPl Plaintiff (s) From ROHAN DOOKHARAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named 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$159,575.04 L.L.$.50 Interest FROM 11/18/09 TO DATE OF SALE MARCH 3, 2010 -ONGOING PER DIEM OF $28.55 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,026.30 Atty's Comm Atty Paid $161.40 Plaintiff Paid Due Prothy $2.00 Other Costs Date: NOVEMBER 17, 2009 (Seal) is R. Lon , n tary By: Deputy REQUESTING PARTY: Name ALAN M. MINATO, 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. 75860 On November: 24, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered 2 Lilac Drive, Mechanicsburg, - more fully described on Exhibit "A" filed with this writ and by thisreference incorporated herein. Date: November 24, 2009 By: ~C. •' ~~ ~' R Estate Coordinator .._ r , ,~ ~~ ` ~_ ... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Cazlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22, January 29, and February 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chazacter of publication are true. isa Marie Coyne, Edit SWORN TO AND SUBSCRIBED before me this 5 day of Februaz, --_...~ __ Notary NOiAR1Al SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNiY My Commission Expires Apr 28, 2010 •slt ^o. QOM-7Oli OIvY Wells Farms Beak, NA vs. Rohan Dookharan Atty: Alan Minato ALL THAT CERTAIN tract or parcel of land and premises, situ- ate, lying and being in the Township of Silver Spring in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the northwesterly side of Lilac Drive (50 feet wide) at the dividing line between Lot Nos. 27 and 28 on the hereinafter mentioned plan of lots; Thence along the dividing line between Lots Nos. 27 and 28, North 28 degrees 38 minutes 43 seconds West, the distance of 137.00 feet to a point at the dividing line between Lot Nos. 28 and 29 on said plan; Thence along said dividing line, North 61 degrees 21 minutes 17 seconds East, the distance of 81.00 feet to a point on the westerly side of Bayberry Drive; Thence along the said aide of Bayberry Drive, South 28 degrees 38 minutes 43 seconds East, the distance of 125.00 feet; Thence along the same and along the arc of a curet having a radius of 12.00 feet, the arc distance of 18.85 feet to a point on the said side of Lilac Drive; Thence along said side of Lilac Drive, South (erroneously referred to a North in the previous deed) 61 degrees 2rminutea 17 seconds West (erroneously referred to as East in the previous deed ), the distance of 69.00 feet to a point the place of BEGINNING. BEING Lot No. 28 on the Plan of Mulberry Crossing, as recorded in Plan Book 40, Page 142. BEING KNOWN AS NO. 2 LILAC DRIVE, MECHANICSBURG, PENN- SYLVANIA. PROPERTY ADDRESS: 2 Lilac Drive ,Mechanicsburg, PA 17050. The .Patriot-News Co. 812 Market St. HarrisburgY PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c'~l~e ~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22110 01/29/10 c--' ~.. < 02/05/10 Sworn to d ubscribed before a is 2 ay of February, 2010 A.D. '- Notary Public \~~~, . COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public City Of Harrisburg, f3auphin County My Commission Fires Nw. 26, 2011 Member, Pennsylvania Association of Notaries Doclat NwnMr: 200P~7098 CIvN Tsrm WNIs Fargo Bank, NA vs. ~ Rohan Dookharan Atty: Alan Mlnato ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF SILVER SPRING IN TIIE .COUNTY OF CUMBERLAND, AND COMMONWEALTH OF . PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS rroLLOws: BEGINNING AT A POINT ON THE NORTHWESTERLY SIDE OF LII:AC DRIVE (50 FEET WIDE) AT TIIE DIVIDING LINE BETWEEN LOT NOS. 27 AND 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEIN LOTS NOS: 27 AND 28, NORTH 28 DEGREES 38 MINUTES 43 SECONDS WEST, THE DISTANCE OF 137.00 FEET TO A POIlVT AT THE DIVIDING LINE BETWEEN LOT NOS. 28 AND 24 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 61 DEGREES 21 MIlVUTES 17 SECONDS EAST, THE DISTANCE OF 81.00 FEET TO A POINT ON'THE WESTERLY SIDE OF BAYBERRY. DRIVE; THENCE ALONG THE SAID SIDE OF BAYBERRY DRIVE, SOUTH 28 DEGREES 38 MINUTES 43 SECONDS .EAST, THE DISTANCE OF 125.00 FEET; THENCE ALQNG THE SAMI's AND ALONG THE ARC OF A CURVE HAVING A RADIUS OF 12.00 FEEL; THE ARC DISTANCE OF 18.85 FEET TO A POINT ON THE SAID SIDE OF LILAC DRIVE; THENCE. ALONG SAID SIDE OF LII.AC DRIVE, SOUTH (ERRONEOUSLY REFERRED TO A NORTH IN' THE PREVIOUS DEED) 61 DEGREES 21 I7 ; .~ .: ~T 'Y Ib AE IQf'I"~ ., ~. pt~pt"I+0 A tC1~f P 1lB4 t'l.N~.OF BIsTiIN1:~BEING LOT N0.2$-OF'THE PLAAI OF MULBERRY CROSSING, AS RECORDED IN PLAN BOOK 40, PAGE 142. BEING KNOWN AS N0. 2 LILAC DRIVE, MECHANICSBURG, PENNSYLVANIA PROPERTY ADDRESS: 2 Lilac Drive , MeclvrticsbaYg, PA 1705(1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which SECURITIZED ASSET BACKED RECEIVABLES LLC TR is the grantee the same having been sold to said grantee on the 5TH day of MAY A.D., 2010, under and by virtue of a writ Execution issued on the 17TH day of NOV, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 7098, at the suit of SECURITIZIED ASSET BACKES RECEIVABLES LLC TR against ROHAN DOOKHARAN is duly recorded as Instrument Number 201020292. IN TESTIMONY WHEREOF, I have he unto set my hand and ~l of said office this ,, day of d,in?AK UDRE LAW OFFICES, P.C. BY: Mark J. Udren, Esquire A11TTZYEHILL, Y I.D. NO. 04302 1 ODCREST ROAD, SUITE 200 CHE NJ 08003-3620 P.O.'I"Box 84, Gladwyne, PA 19035 856-Ih69-5400 lren. coin COUNTY ADULT PRO$ATION Plaintiff VS. DOOKHARAN ROHAN Defendant(s) ATTORNEY FOR RLAr1KT1VF C c::) --t rri- 3 -rs COURT OF COMMON PLEAS Time CIVIL DIVISION CUMBERLAND COUNTY, PA MORTGAGE FORECLOSURE NO. 2009-07098 WAIVER OF NOTICE OF SHERIFF'S SALE TO: Cumberland County Adult Probation I hereby accept service of the Notice Of Sheriff's Sale relating to the above captioned action in mortgage foreclosure for and on behalf of Wells Fargo Bank, National Association as Trustee for Securitized Asset Backed Receivables LLC 2005-OP1 Mortgage Pass-Through Certificates, Series 2005-OP1, and hereby waive the thirty (30) day Notice provision of Pennsylvania Rule Of Civil Procedure 3129.1, et seq.,in connection with the Sheriff's sale of real property commonly known as 2 LILAC DRIVE held on 05/05/2010, and release any and all claims CUMBERLAND COUNTY ADULT PROBATION may have against the subject real property only. Cumberland County Adult Probation, By: Name: Cf?a 1cs A 13?ac Title: : ,a) Co,a,t 6 a Accepted ?Ir Ana n Behalf Of Cumberland County Adult Probation 1 8 ?? Dated: 11-LOV l1