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Home My WebLink About10-0234UDREN 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 c /ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER `y r., q T- _ 1r- 111 WOODCREST ROAD, SUITE 200 - .? CHERRY HILL, NJ 08003-3620 :. 856-669-5400 c:;i = ? pleadings@udren.com ?•`=? ?'' c-a OneWest Bank FSB :COURT OF COMMON PLEAS a` 888 E. Walnut Street ::CIVIL DIVISION Pasadena, CA 91101 Plaintiff :Cumberland County V. Bryan S. Barrick Laura M. Barrick :NO. 247 Pine Grove Road Gardners, PA 17324 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you-. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. C jp92 oa -i ?Lj4,( (2 K=' IAI4,1.2-cl Rzk a3s431s LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 0 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 C 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. Current assignments of mortgage of record are as follows. Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: OneWest Bank FSB Recording Date: 12/8/09 Instrument #: 200941018 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: 247 Pine Grove Road MUNICIPALITY/TOWNSHIP/BOROUGH: Dickinson Township COUNTY: Cumberland DATE EXECUTED: 6/30/07 DATE RECORDED: 7/20/07 BOOK: 2000 PAGE: 1995 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: V (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 10/23/09: Principal of debt due $90,732.72 Unpaid Interest at 6.75*t from 6/1/09 to 10/23/09 (the per diem interest accruing on this debt is $16.78 and that sum should be added each day after 10/23/09) 2,410.63 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $285.58 and that sum should be added on the first of each month after 10/23/09) 1,264.08 Late Charges (monthly late charge of $13.36 should be added in accordance with the terms of the note each month after 10/23/09) 146.96 Recoverable Balance 77.00 Attorneys Fees (anticipated and actual to 511 of principal) 4,536.64 TOTAL $99,773.03 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 0 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 $99,773.03 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICI?S, P.C. BY: le ? Attorneys f r laintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE /ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 'VawP a- To Dwda sm Tam, Q=b91land C=rj, P )vt ni ag 'Dtr rte, ?;; ttaxi in m=crdm= wit)- si. survey Larry -v, xei0im ? S., r". ? , a, a ap. of F?ttsr;? it aua d. aer= w- fU3kmm; BEODOUNG st mm iv= pi; sar is c =mm !me- the North side ofA- i' me Grova P=4 at the. cram s'rC l d n6w or y Of Imet x m`z;. fiwtz.- ?i -land aid ofjand Kamt,4 340r& 2I dq;mw DE: =dn. 17 secorat#-s Wm, 11M.45to agar. i= per, thmae. bly land now or €mmcd of Cbwtu Wr Nmrtb 72 dW= 25 mmmm 36 *con& BW 29.71 im w. ihdae by land umf or Arraa miy gfmw -%mitb. So=k 21 de?eem Qtr lubmus 17 sus F .. I SOAtf6d'm mm iuc r M timam I?Y Mid comm. Ivnd. on t7t %=*t skit Of oim-- Cvmvr ROS4, Soaet `ate &*grees 51 43 a weg;w.t:.t, tear to an:txsa pum; ft= Oka= ofi'bcg Wming. CCU ADM s. ? gqa= f--%-, ma= ar ins and. beinrimpmse' WI& a rwo, -- xs x"!'? whi+ 1?3?uusrx * . a S , i?htlc, i;1 J?;d d»3 .? caw=w Di=m= C my dtwa Bwefi msl l+ mt s CQMPM y p-nre> 1„-msia, EM MG how- n as 7,47 ?='Gravc IRD41- r h* ofDl w.lls s¢+ro Cttzairc? ; icy, Cl c November 19, 2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMEOWNF.ROS MORTGAGE ASSISTANCE PROGRAM .MAPS may he able to hPln to save your home- This Notice explains hnw the program warks_ This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A Page 1 of 1 C HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Bryan S. Barrick 247 Pine Grove Road Gardners, PA 17324.___ 3002910168__ _- uicken Loans One West Bank HOMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE PROGRAM. YOU MAY RF, F.LTGIRT.F FOR FINANCIAL. ASSISTANCE WHICH CAN SAVE VOTTR HOME. FROM FOREC1,0SURE AND HELP YOU MAKF, FUTURE MORTGAGE, PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTO), 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 FORFCT,OSITRF. - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceD meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MFETTNG MUST OCCUR WITHIN THE NEXT (30) DAVS_ TF YOU DO NOT APPT.Y FOR FMRRGF.NC'.Y MORTGAG ASSTSTANCF YC)TI MTTST RRTNC. YOT IR MORTCTAC,F T TP TO T)ATF THE PART OF THTS NnTT ,F CALi ED OT40W TO CURE YOUR MORTGAGE DE FA T T Tf "T0, EXPLAINS HOW TO RRINCT VOTTR MORTGAGE TIP TO DATF CONSTTMER CREDIT' COTINSF.I.ING AC-ENCIFS - 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, addreggeg and telFmhone mimhen are get forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immedintelT of your intentions. APPLICATION FOR MORTGAGF. ASSLSTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST he filed or postmarked within thirty (30) days of your Page 2 of 2 face- to-face meeting. YOU MUS FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME 11MMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE, DF.FAIJILT - The MORTGAGE debt held by the above lender on your property located at: 247 Pine Grove Road Gardners, PA 17324 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: Monthly Payments of $552.77 for July 1, 2009 through August 1, 2009 = $1105.54 _ MQ I Pavmments of $603.04 for September 1, 2009 throggh November 1, 2009=$1809.12 Monthly Late Charges q_S13.36 for July 1. 2009 through November 1 2091= $66.50_ Other charges (explain/itemize): Escrow Advance=$1329.63 Other Fee= $77.00 _U aid Late Charges = 93.52 TOTAL AMOUNT PAST DUE: _ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not apW icahie): WA HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4481.61 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaMents must he made Dither hysach, cashier's cherk, rertifit-d check or mancy nrdcr made. papbl and sent tn• Page 3 of 3 C; You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not pnlicahle ): NA IF V011 DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to egeuice its rights to a elerate the mniUage 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 y grr mortga4ed propgIJ37, IF THF, MORTGAGE. TS FORF.C LOSF.D UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If yon cure the default within the THTRTV (30 DAY period, ym w*11 not he 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. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RTGHT TO C.TJRF THE DEFAULT PRIOR TO SHF.RTFF'S SAT, F. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have thhe right to curse the default and prevent the sale at any time up to one hnur before th 4heriff'c Sal You may do cn hT nayig the total amo znf hen ac chi lp Lc any lath or other cha aec then dne? reac n le attorn y'c fPPC and costs connected with he foreclncu sale and any nth .r costs connected w" the Sheriffc Sale as ,=ifed in writing by the lender and by performing an?r other requirements un a the mn game. 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. EART.TFST POSSYMN SHF.RWF'S SALE nATF - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE, TYNDF.TL Name of Lender/Servicer: One West Bank Address: 2900 Esperanza Crossing Austin-TX 78758 _ -__ _ Phone Number: 1477-908-4357 Fag Number: 1-625-583-1370 Contact Person: Loss Mitiigation______ EFFECT OF SHERIFF'S SALE. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in. the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSIIMP_TION OF MORTGAGE. - You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 4 C, 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 III Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 C 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 INSTTI'UTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL. BANKRUPTCY LAW. Page 6 of 6 c HEMAP Consumer Credit Counseling Agencies ADAMS County Report last updated: 12/23/2008 1:53:12 PM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 717.637.3768 CCCS of Western PA 2000 l.inglestovvn Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 Priority Mail. J Mail. For vide proof of ach a Pewm to cover the Be waiver for fail receipt is ddressee or iece with the ent the arti. :ertified Mail Al. I! inquiry. i 1. m m ru m s O ri O O C3 G7 r? r-9 Cr C3 r- 1 Z C4 1 N m W M 0 2 41 C, to c? O E ? LU "- P, . %i + ? va ?0 t? aagset4 ° r 0 L M M w N OEM w w LLI LL ? ? O P LL o .LL) odr, a V CE: Z LL e ucc: -j O EC O 2 NO ? p 0 t3 C3 O V- 0 O V vJ ? (? N C 0 0 a is or Priority Mails. shall. :rtitied Mail. Fa' to ae prOOr m attach a Return stage to cover the ive a fee waver for ified Mali receipt Is the addressee or i mailpiece with the se present the arti- the Certified Mail and mail. king an Inquiry. A n v rn ra r D C3 C3 C3 S Er 0 C3 l`- S I E 9 Cz S 19 N T CID Z CO UO` C a E g L < L 0 co C> w CL AQ jSeH ------ ?. O ----- 1 C3 :n - c w ?- z UJ <Q ?cr i? l Z- cc)2 ?tp? ? ? r V I I i 1 G ?a b' 4 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 make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICF,S, P.C. BY;..,- Attorneys for P intiff MARK J. UDREN, SQUIRE 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 C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ?? `' n f Chief Deputy ?? Edward L Schorpp Solicitor Onewest Bank FSB vs. Bryan S. Barrick Case Number 2010-234 SHERIFF'S RETURN OF SERVICE 01/08/2010 05:01 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 8, 2010 at 1701 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Laura M. Barrick, by making known unto herself personally, at 240 Pine Grove Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to her personally the said true and correct copy of the same. 01/12/2010 05:38 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2010 at 1738 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bryan S. Barrick, by making known unto himself personally, at Carlisle Tire & Wheel, 621 N. College Street, 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: $69.20 January 14, 2010 SO AN ERS, Y R ANDERSON, SHERIFF i '??ty Sheriff By Deputy Sheriff UDREN LAW OFFICES, P.C. MARK J,: UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF One West Bank FSB :COURT OF COMMON PLEAS 888 E. Walnut Street :CIVIL DIVISION Pasadena, CA 91101 €:Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Bryan S. Barrick NO. 10-234 Civil Term Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: w -n i-t-, I_ _ }, Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Bryan S. Barrick and Laura M. Barrick for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 10/24/09 to 2/13/10 Late charges per Complaint From 10/24/09 to 2/13/10 Escrow payment per Complaint From 10/24/09 to 2/13/10 $99,773.03 1,896.14 40.08 1,142.32 TOTAL $102,851.57 $I4.0O P t F.7i / e,& 1+60S6 e,-13'754-5 Y I hereby certify that (1) the addresses of the Plaintiff and Defendant ate as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS DATE : .01, Zin UDREN LA C. BY: Attor for Plaintiff MARK J. UD ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE rALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE INDICATE .? PRO P HY 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 C) o C_ CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ` - _ rr LOUIS A. SIMONI, ESQUIRE - I D #200869 , c _ 0 t -s Him ADAM L. KAYES, ESQUIRE - ID #86408 t MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER ',:` 111 WOODCREST ROAD, SUITE 20 0 ! rw err" CHERRY HILL, NJ 08003-3620 856-669-5400 "-. pleadings@udren.com OneWest Bank FSB COURT OF COMMON PL EAS 888 E. Walnut Street :CIVIL DIVISION Pasadena, CA 91101 Plaintiff :Cumberland County V. Bryan S. Barrick Laura M. Barrick NO. tb ?,3 1.. !U l? 247 Pine Grove Road Gardners, PA 17324 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you,. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT H VE A LAW ER GO TO OR TELE:rHOM Tag: 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. C D??OO?3o- I SHERIFFS RETURN OF SERVICE 01/08/2010 05:01 PM - Michael Barrick, Deputy Sheriff, who being duty sworn according to law, states that on January 8, 2010 at 1701 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Laura M. Barrick, by making known unto herself personally, at 240 Pine Grove Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to her personally the said true and correct copy of the same. 01/1212010 05:38 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2010 at 1738 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bryan S. Barrick, by making known unto himself personally, at Carlisle Tire & Wheel, 621 N. College Street, 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: $69.20 SO AN RS, January 14, 2010 Y R ANDERSON, SHERIFF t Sherift` ?`-- - • gy , Deputy Sheriff ?I 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 nleadings(Oudrpn_ om One West Bank FSB Plaintiff V. Bryan S. Barrick Laura M. Barrick Defendant(s) TO: Bryan S. Barrick Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 Date of Notice: February 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-234 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, 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 TH?.S_?S -F -A'?T? TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE US,?-F 6R THAT PURPOSE. MARK J. UDRT7,--7SQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 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 inaggMudrAn nnm One West Bank FSB Plaintiff V. Bryan S. Barrick Laura M. Barrick Defendant(s) TO: Bryan S. Barrick 247 Pine Grove Road Gardners, PA 17324 Date of Notice: February 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-234 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, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT-2-URPOSE. `--------- TUART 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 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 One West Bank FSB Plaintiff V. Bryan S. Barrick Laura. M. Barrick Defendant(s) TO: Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Date of Notice: February 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-234 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, 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, 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 131PaAinas(&udren cnm One West Bank FSB Plaintiff V. Bryan S. Barrick Laura M. Barrick Defendant(s) TO: Laura M. Barrick 240 Pine Grove Road Gardners, PA 17324 Date of Notice: February 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-234 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 O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, Suite 200 Cherry Hill, New Jersey 08003-362-1 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 III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF OneWest Bank FSB :COURT OF COMMON PLEAS 888 E. Walnut Street -CIVIL DIVISION Pasadena, CA 91101 ;Cumberland County Plaintiff =MORTGAGE FORECLOSURE V. Bryan S. Barrick Laura M. Barrick NO. D 247 Pine Grove Road Garnders, PA 17324 Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE 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: Defendant: Age: Residence: Employment: Bryan S. Barrick Over 18 As captioned above Unknown above 17 ame : Dennis Kirkpatrick Title: Vice President Company: OneWest Bank, FSB Laura M. Barrick Over 18 As captioned Unknown Sworn to and subscribed before me this 5 day of ban , 200 .................................................................. N a u 1c `,,,,1.0.,, O??RYPUS ALEX Notary puafiMCBRIbE State of t exas My Comrnis sio.n Expires November 10, 2010 V UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - STUART WINNEG, ESQUIRE - LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUI; LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE - ID #04302 ID #45362 - ID #34576 ID #75860 RE - ID #203437 - ID #200869 ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com One West Bank FSB Plaintiff V. Bryan S. Barrick Laura M. Barrick Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-234 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 2/14/10 to Date of Sale June 2, 2010 Ongoing Per Diem of 16.78 to actual. date of sale including if sale is held at a later date (Costs to be added) 1 0 ,1 x•00 PD AT7Y A-(20 CBF 4a . 00 )4• o0 " 01. 50 4a.oo iJue.Co 5o L-L RE L06+ 1,829.02 CK-* 1* 508(0 e 437_$,95 UDR AW OFFICES, P. B Attorneys -rCr L intiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE (ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE r o n $102,851.57 UDREN LAW OFFICES, P.C. ATTORNEY 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 FOR PLAINTIFF One West Bank FSB :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County ;MORTGAGE FORECLOSURE Bryan S. Barrick :NO. 10-234 Civil Term Laura M. Barrick Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: zz. - I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. A r aintiff MARK J . UDREN, - QUIRE 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 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 One West Bank FSB :.COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County EMORTGAGE FORECLOSURE Bryan S. Barrick NO. 10-234 Civil Term Laura M. Barrick Defendant (s) C E R T I F I C A T E r.... M GD r `? Q's I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW DREI CES , P.C. Att-azneys for-Plaintiff MARK J. UDR-E I, 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 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 One West Bank FSB :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. €,Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick "NO. 10-234 Civil Term Laura M. Barrick Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 rn _" rig One West Bank FSB, 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: 247 Pine Grove Road Gardners, PA 17324 1. Name and address of Owner(s) or reputed owner(s): Name Address Bryan S. Barrick Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 247 Pine Grove Road Gardners, PA 17324 240 Pine Grove Road Gardners, PA 17324 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 International Portfolio 200 Bar Harbour Dr. Apt/Ste 400 West Conshocken, PA 19428 4. Name and address of of record: Name One West Bank FSB Address 888 E. Walnut Street Pasadena, CA 91101 Era Mortgage, A Corporation 3000 Leadenhall Road Mount Laurel, NJ 08054 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 247 Pine Grove Road Gardners, PA 17324 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: February 13, 2010 UDR OFFICES, P.C. BY: A { ^ ? f? ?aintiff 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 the last recorded holder of every mortgage 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 One West Bank FSB :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick :NO. 10-234 Civil Term Laura M. Barrick Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bryan S. Barrick 247 Pine Grove Road Gardners, PA 17324 Your house (real estate) at 247 Pine Grove Road Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 I 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 One West Bank FSB ':COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick ::NO. 10-234 Civil Term Laura M. Barrick Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bryan S. Barrick Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 Your house (real estate) at 247 Pine Grove Road Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. 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 One West Bank FSB :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick :NO. 10-234 Civil Term Laura M. Barrick Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Your house (real estate) at 247 Pine Grove Road Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 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 One West Bank FSB :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County ;MORTGAGE FORECLOSURE Bryan S. Barrick ::NO. 10-234 Civil Term Laura M. Barrick Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Laura M. Barrick 240 Pine Grove Road Gardners, PA 17324 Your house (real estate) at 247 Pine Grove Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 V FOR PLAINTIFF ` o --n CO rC Xc- One West Bank FSB :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Bryan S. Barrick Laura M. Barrick :NO. 10-234 Civil Term Defendant (s) UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 `LAN 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 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: February 13, 2010 ;UDREN C . A ys for 17`laintiff MARK J. UD'REN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE %ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE I 1 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 : 1 / 5/!O Name : Dennis Kirkpatrick Title: Vice President Company: OneWest Bank, FSB Bryan S. Barrick Laura M. Barrick Loan #3002910168 MSU #09100530-1 (Cumberland County, Pennsylvania) 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-234 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ONE WEST BANK FSB, Plaintiff (s) From BRYAN S. BARRICK and LAURA M. BARRICK (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 $102,851.57 L.L. $.50 Interest from 2/14/10 to Date of Sale 6/2/10 Ongoing per diem of $16.78 to actual date of sale including if sale is held at a later date -- $1,829.02 Atty's Comm % Due Prothy $2.00 Atty Paid $201.70 Other Costs Plaintiff Paid Date: 2/16/10 David D. Buell, Proth notary (Seal) By: REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Deputy Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 ~. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 Flj ~}~„ai , iu. LORRAINE DOYLE, ESQUIRE - ID #34576 „ r.. ~I`Y~"rb'.l /~{') r~' '(}.~„ ~Cz'1`f` r^y,,,,t , ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 Z~~~ ~'~'~ ~ ~ P~ J' LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 ~~~~` ' ` ~ ' ~ i '. j MARGUERITE L. THOMAS, ESQUIRE - ID #204460 = "'~-- ` ~' ~ -' ~ ' WOODCREST CORPORATE CENTER ~~~i~~~L~rt''al~ 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 One West Bank FSB : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : Cumberland County v. Bryan S. Barrick Laura M. Barrick E NO. 10-234 Civil Term Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: April 29, 2010 __ U~DRrEN,,,I~Aid/°`tSF~'ICES, P/:'~. BY . / ~ keys for Plaintiff MARK J . iJ~RREN ; '---EBQUI RE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. 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 One West Bank FSB Plaintiff v. Bryan S. Barrick Laura M. Barrick Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-234 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Bryan S. Barrick and Laura M. Barrick PROPERTY: 247 Pine Grove Road, Gardners, PA 17324 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 2. 2010, at 10:00 A.M., at the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ~XHI6~IT q y ~ J ~_ n Q r >y c v O CO O 0 cn W O .-. C !~. `. 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NZO Z D o>c °' v ~ o ~n~ o wv y m m m v ~ a N ^^ ^^ o ~ ~ ~ (7 C7 '~ m ~ p c ~ N ~ (p ~ I N G ~ C 5 ~ I ' o N d a 3 I 4' 016H265'1921~i ~ ~ I rn I a' ~ V~.v~Ln x ~ ~m ~- I '.1 V) ' ~ ~ ~ N C m ~ ~ '~:;1'~1; ~n14 1 ! ~ ~ y ~ H ~ I Maiiad From ' lt{1~~1~ ~ ° m m ~d~mm oxam~ I I o ~ o ~~=oa ~o 3 ° y ~ C~ 2 ~^' ~ ~ m ~ v o m ~° - gy m ei 7 ~7 (7 m ~v ~ ~ < a ~ ~ ? N ~ ~_ _ v o ~ m ! O z N N N d J ~_ :+ N N~ 6 0 TI O O N O N C t ' ` ~~ SU j d ~ O O C O n l; ~ y 7 C Q _ ~ ~ m ` ~, ~, ~ <a _ ~ ~ m ~ m~ w O ~ ... _.. , .. ~ N N l'1 O ~ ~. m m~ c 3 d O ry N n y - C G ~ ~ ~ ~ m 3 m .. nx ~ >> m n-cd3~a - ~ 3y ~ ~ nm ~ ynD y as ~0 ~ k m'a' m m ~ c~~.3 =_ ~~ O ~ on.y~. 7°~m moSa.no ~ m ° ° n ~ ~ °-'m3 ~ o ~ v v 3 ~ '01~ O m m o~ y~ o n ~~ ~ ~ y ~ N on m ~cm .~ n~ ~ y ~~ Tfn NO Q (~D -'y m m 3 y 3 1l (q y m o ~ ~ 3 m 2 m ~ O ~ a d °1 m m a ~ ~ mo~~o~ ~'1 :0 w 3 m ° v N o ~ . m v m ~ v ~ o ~ ~ > > ~ v X B~ A to ~ , m ~ ~ m m I 1 T W a - m N O (D Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~14~1'`~ctr ot~rr~r~t~rr/,~~~ a; ~r~,~:~ ~ _ u ., Onewest Bank FSB vs. Bryan S. Barrick (et al.) Case Number 2010-234 SHERIFF'S RETURN OF SERVICE 04/06/2010 05:05 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1704 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 Bryan S. Barrick and Laura M. Barrick, located at, 247 Pine Grove Road, Gardners, Cumberland County, Pennsylvania according to law. 04/08/2010 07:38 PM -Timothy 81ack, Deputy Sheriff, who being duly sworn according to law, states that on 4/8/10 at 1930 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: Bryan S. Barrick, by making known unto, Bryan S Barrick, personally, at, 621 North College Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/09/2010 Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1704 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: Laura M. Barrick, by making known unto, Laura M. Barrick, personally, at, 240 Pine Grove Road, Gardners, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same SHERIFF COST: $908.92 SO ANSWEERS, April 20, 2010 RON R ANDERSON, SHERIFF ~?~H~BIT Ci rrj Cou;iiyS:~ite Sher~Yf, 7eleosoYt, Inc. ~ ~,~~ ~y~ ~ ~ -~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 3TUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLl3, ESQUIRE - ID #34576 ALAN M. MINATO, 83QUIRS - ID #75860 CHANDRA M. ARREMA, 88QUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 2.oa CHERRY HILL, NJ 08003-3620 856-669-5400, pleadiaga~udrea.com One West Bank FSB :COURT OF COMMON PLEAS 'CIVIL DIVISION Plaintiff :Cumberland County v. Bryan S. Barrick Laura M. Barrick €NO. 10-234 Civil Term Defendant(s) cn ^~ c ~-~ ~ i-;-:_ Tip _ Nr~a ~~.~ ~~ C`~ -~-, ~- .__ ~ $~ ~- =- AMENDMENT TO PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, hereby amends its pending Petition For Postponement of the Sheriff's sale scheduled in the above captioned matter in compliance with Cumberland County, PA Local Rule 208.3 (a} (2) , (9) as follows: 1. A Judge has not ruled upon any other issue in the captioned or any related matter. 2. On July 28, 2010, the Plaintiff hereby certifies that a letter was sent via first class, regular mail to the pro se Defendants as captioned, seeking concurrence o Petition. BY: instant St~fia re Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: STUART WINNEG, ATTY LD. NO. 45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 $56-669-5400 One West Bank FSB Plaintiff v. Bryan S. Bazrick Laura M. Barrick Defendant(s) ATTORNEY FOR PLAINTIFF NO. 10-234 Givil Term CERTIFICATION OF SERVICE 1, the undersigned Attorney, Attorney for Plaintiff/Movant, One West Bank FSB, hereby certify, that I served a true and correct copy of the within Amendment to Petition for Postponement of Sheriff s Sale by pre-paid first class regular mail along with a request to the other parties to provide their concurrence or non-concurrence. Service was made on the 28 ~' day of July,.2010 TO: Bryan S. Barrick 247 Pine Grove Raad Gazdners, PA 17324 Bryan S. Barrick c/o Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17413 Laura M. Barrick 247 Pine Grove Raad Gardners, PA 17324 IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION One West Bank FSB Plaintiff v Bryan S. Barrick NO. 1'0-234 Civil Term Laura M. Barrick Defendant (s) . CERTIFICATION OF NON-CONCIIRRENCE I hereby certify that the pro se Defendant(s) have not concurred with the within Motion to Postpone Sheriff's Sale as the Motion is of an Emergency nature, and the Defendant(s) being pro se, have not provided a facsimile number, email address or telephone number by which they can be contacted t ate t eir concurrence v.,...._.~... _... or objection to the within motion. __-•-~'"~f Dated: July 28, 2010 ~.~'F7inneg, Esquire orney for Plaintiff • +~ t- IN THB COURT OF COMMON PLEAS OF CUI~88RLAND COUNTY CIVIL DIVISION One West Bank FSB Plaintiff v. Bryan S. Warrick Laura M. Warrick Defendant(s) N0. 10-234 Civil Term O R D E R AND NOW, this ~,~~ day of July, 2010, after consideration of Plaintiff's Petition for Postponement of Sheriffs Sale of the mortgaged property located at 247 Pine Grove Road, Gardners, PA 17324, it is hereby ORDERED that the said Sale currently scheduled for August 4, 2010, is extended 1 (one) month, to the regularly scheduled Cumberland County Sheriff's Sale scheduled for September 8, 2020. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the August 4, 2010 Sheriffs Sale. TO:/ Bryan S. Warrick 247 Pine Grove Road Gardners, PA 17324 Laura M. Warrick 247 Pine Grove Road Gardners, PA 17324 /~ryan S. Warrick c/o Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 ./~dren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department ? S C!~ BY THE COURT: J. ~., e~ t.. ~ i~" L ~-~ C ~ -r•= ~ -. f r. ,- ~ ~' -e -, :: 3 ~ •• ~~~ ~ ~~ . ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Onewest Bank FSB vs. Bryan S. Barrick (et al.) 0.0"Ir of cwrbr",I 11,44 OFFICE :,F 1,. . ,- -F 2013 ri CT 12 t3?i '' r' } PENCISYL\,'r,INI A Case Number 2010-234 SHERIFF'S RETURN OF SERVICE 04/06/2010 05:05 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1704 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 Bryan S. Barrick and Laura M. Barrick, located at, 247 Pine Grove Road, Gardners, Cumberland County, Pennsylvania according to law. 04/08/2010 07:38 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 4/8/10 at 1930 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: Bryan S. Barrick, by making known unto, Bryan S Barrick, personally, at, 621 North College Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/09/2010 Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1704 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: Laura M. Barrick, by making known unto, Laura M. Barrick, personally, at, 240 Pine Grove Road, Gardners, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same 06/01/2010 Property sale postponed to 7/7/2010. 07/06/2010 Property sale postponed to 8/4/2010. 08/02/2010 Property sale postponed to 9/8/2010. 09/09/2010 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 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren on behalf of OWB REO, LLC, 155 North Lake Avenue, Pasadena, CA 91101, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,002.69 SHERIFF COST: $1,002.69 SO ANSWERS, October 08, 2010 RbNISV R ANDERSON, SHERIFF I Le" *Ocyl 00 'a S? t t- Pd ?ci CounrySuite Sheriff. Teie?soft. Inc. /LtL ? ? w q;?3 VTREN SLAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK,J. UDREN, ESQUIRE - ID 004302 STUART OINNEG,'ESQUIRE - ID #45362 LORRAINE-DOYLE, ESQUIRE - ID #34576 AZAN 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 One West Bank FSB :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick :NO. 10-234 Civil Term Laura M. Barrick Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 One West Bank FSB, 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: 247 Pine Grove Road Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s): Name Address Bryan S. Barrick Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Carlisle Tire & Wheel 621 N. College Street Carlisle, PA 17013 247 Pine Grove Road Gardners, PA 17324 240 Pine Grove Road Gardners, PA 17324 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 International Portfolio 200 Bar Harbour Dr. Apt/Ste 400 West Conshocken, PA 19428 I V 4. Name and address of of record: Name One West Bank FSB Address 888 E. Walnut Street Pasadena, CA 91101 Era Mortgage, A Corporation 3000 Leadenhall Road Mount Laurel, NJ 08054 S. Name and address of every other person who has any record lien or 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 247 Pine Grove Road Gardners, PA 17324 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: February 13, 2010 UDREN-1, W?,? OFFICES , P. C. BY: Attorneys -foe`-- laintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE iALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE the last recorded holder of every mortgage 01 MIREN LAW OFFICES, P.C. MARK'J. UDR$N, ESQUIRE - ID 004302 937UART WINNEG, ESQUIRE - ID #45362 1..ORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 I.,OUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAY'ES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 3.11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com One West Bank FSB Plaintiff V. Bryan S. Barrick Laura M. Barrick Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. 10-234 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bryan S. Barrick 247 Pine Grove Road Gardners, PA 17324 Your house (real estate) at 247 Pine Grove Road Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY SWILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RfGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 A:,L THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF TOLAND, DICKINSON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY BY LARRY V. NEIDLINGER R.S.P.E., A COPY OF WHICH IS ATTACHED HERETO AS FOLLOWS: BEGINNING AT AN IRON PIN SET IN COMMON LAND ON THE NORTH SIDE OF PINE GROVE ROAD AT THE CORNER OF LAND NOW OR FORMERLY OF JANET KUNTZ; THENCE BY SAID LAND OF JANET KUNTZ, NORTH 21 DEGREES 08 MINUTES 17 SECONDS WEST 182.45 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CHARLES WINDOMAKER, NORTH 72 DEGREES 25 MINUTES 56 SECONDS EAST 29.71 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF MARY SMITH, SOUTH 21 DEGREES 08 MINUTES 17 SECONDS EAST 180.60 FEET TO AN IRON PIN; THENCE BY SAID COMMON LAND ON THE NORTH SIDE OF PINE GROVE ROAD, SOUTH 68 DEGREES 51 MINUTES 43 SECONDS WEST 29.65 FEET TO AN IRON PIN; THE PLACE OF BEGINNING. CONTAINING 5.387 SQUARE FEET, MORE OR LESS AND BEING IMPROVED WITH A TWO STORY FRAME DWELLING HOUSE AND OUTBUILDINGS. BEING THE SAME PREMISES WHICH BARTON L. SHANK AND KELLY S. SHANK, BJW, BY DEED DATED 1/22/2004 AND RECORDED 2/09/2004 IN DEED BOOK 261 PAGE 2997 CONVEYED UNTO.BENEFICIAL CONSUMER DISCOUNT COMPANY DJB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA. BEING KNOWN AS 247 PINE GROVE ROAD, TOWNSHIP OF DICKINSON, CUMBERLAND COUNTY. BEING PROPERTY PARCEL NUMBER: 08-38-2172-004. BEING KNOWN AS: 247 Pine Grove Road Gardners, PA 17324 PROPERTY ID NO.: 08-38-2172-004 TITLE TO SAID PREMISES IS VESTED IN BRYAN S. BARRICK AND LAURA M. BARRICK, HUSBAND AND WIFE BY DEED FROM BRYAN S. BARRICK (INCORREC'T'LY VESTED AS BRYAN S. IN DEED RECORDED 6/30/0400 IN BOOK 634 PAGE 4351) AND LAURA M. BARRICK, HUSBAND AND WIFE DATED 10/09/06 RECORDED 2/23/07 IN DEED BOOK 278 PAGE 4326. 5 EMREN 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 One West Bank FSB ,COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Bryan S. Barrick :NO. 10-234 Civil Term Laura M. Barrick Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Laura M. Barrick 247 Pine Grove Road Gardners, PA 17324 Your house (real estate) at 247 Pine Grove Road Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,851.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) J . ? YOU MAY STILL-BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF TOLAND, DICKINSON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY BY LARRY V. NEIDLINGER R.S.P.E., A COPY OF WHICH IS ATTACHED HERETO AS FOLLOWS: BEGINNING AT AN IRON PIN SET IN COMMON LAND ON THE NORTH SIDE OF PINE GROV& ROAD AT THE CORNER OF LAND NOW OR FORMERLY OF JANET KUNTZ; THENCE BY SAID LAND OF JANET KUNTZ, NORTH 21 DEGREES 08 MINUTES 17 SECONDS WEST 182.45 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CHARLES WINDOMAKER, NORTH 72 DEGREES 25 MINUTES 56,,SECONDS EAST 29.71 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF MARY SMITH, SOUTH 21 DEGREES 08 MINUTES 17 SECONDS EAST 180.60 FEET TO AN IRON PIN; THENCE BY SAID COMMON LAND ON THE NORTH SIDE OF PINE GROVE ROAD, SOUTH 68 DEGREES 51 MINUTES 431 SECONDS WEST 29.65 FEET TO AN IRON PIN; THE PLACE OF BEGINNING.' CONTAINING 5.387 SQUARE FEET, MORE OR LESS AND BEING IMPROVED WITH A TWO STORY FRAME DWELLING HOUSE AND OUTBUILDINGS. BEING THE SAME PREMISES WHICH BARTON L. SHANK AND KELLY S. SHANK, B/W, BY DEED DATED 1/22/2004 AND RECORDED 2/09/2004 IN DEED BOOK 261 PAGE 2997 CONVEYED UNTO BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA. BEING KNOWN AS 247 PINE GROVE ROAD, TOWNSHIP OF DICKINSON, CUMBERLAND COUNTY. BEING PROPERTY PARCEL NUMBER: 08-38-2172-004. BEING KNOWN AS: 247 Pine Grove Road Gardners, PA 17324 PROPERTY ID NO.: 08-38-2172-004 TITLE TO SAID PREMISES IS VESTED IN BRYAN S. BARRICK AND LAURA M. BARRICK, HUSBAND AND WIFE BY DEED FROM BRYAN S. BARRICK (INCORRECTLY VESTED AS BRYAN S. IN DEED RECORDED 6/30/0400 IN BOOK 634 AGE 4351) AND LAURA M. BARRICK, HUSBAND AND WIFE DATED 10/09/06tECORDED 2/23/07 IN DEED BOOK 278 PAGE 4326. WRIT OF EXECUTION and/or ATTACHMENT a . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-234 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ONE WEST BANK FSB, Plaintiff (s) From BRYAN S. BARRICK and LAURA M. BARRICK (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 $102,851.57 L.L. $.50 Interest from 2/14/10 to Date of Sale 6/2/10 Ongoing per diem of $16.78 to actual date of sale including if sale is held at a later date -- $1,829.02 Atty's Comm % Due Prothy $2.00 Atty Paid $201.70 Other Costs Plaintiff Paid Date: 2/16/10 David D. Buell, Prot onotary (Seal) By: REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDIREN LAW OFFICES, PC WOIODCREST CORPORATE CENTER 111 1WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 8$6-669-5400 Supreme Court ID No. 75860 Deputy On March 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA, Known and numbered, 247 Pine Grove Road, Gardners, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: eal Estate Coordinator 81 Z d 9 1933 OIOZ , ` J\? ? rF4 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa arie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaii being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a lego periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the (following dates, viz: April 16, April 23, and April 30, 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 character of publication are true. ?P.1? 4tlxl-? "- Lisa Marie C02' Editor SWORN TO AND SUBSCRIBED before me this 2010 0 =Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Cormolosio0 Expires Apr 26, 2014 Writ No. 2010434 Cull Onewest Bank FSB VS. Bryan S. Barrick Laura M. Barrick Atty: Mark J. Udren ALL THAT CERTAIN tract or land with the improvements thereon erect- ed, situate in the Village of Toland, Dickinson Township, Cumberland County, Pennsylvania bounded and described in accordance with a sur- vey by Larry V. Neidlinger R.S.P.E., a copy of which is attached hereto as follows: BEGINNING at an iron pin set in common land on the north side of Pine Grove Road at the corner of land now or formerly of Janet Kuntz; thence by said land of Janet Kuntz, North 21 degrees 08 minutes 17 seconds West 182.45 feet to an iron pin; thence by land now or formerly of Charles Windomaker, North 72 degrees 25 minutes 56 seconds east 29.71 feet to an iron pin; thence by land now or formerly of Mary Smith, South 21 degrees 08 minutes 17 sec- onds East 180.60 feet to an iron pin; thence by said common land on the north side of Pine Grove Road, South 68 degrees 51 minutes 43 seconds West 29.65 feet to an iron pin; the place of beginning. CONTAINING 5.387 square feet, more or less and being improved with a two story frame dwelling house and outbuildings. BEING the same premises which Barton L. Shank and Kelly S. Shank, b/w, by deed dated 1/22/2004 and recorded 2/09/2004 in Deed Book 261 Page 2997 conveyed unto Ben- eficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, be' _ = Pine Grow Read, T 60 insou, Cumberland County. 9VN€1 property parcel nueaber: 08-38-2172-004. BEING KNOV N AS: 247 Pine ClrO t Road, wears, PA 17324. PROPERTY ID NO.: 08-38-2172- 004. TITLE TO SAID PREMISES IS VESTED IN Bryan S. Barrick and Laura M, Barrick, husband and wife by deed from Bryan S. Barrick (in- correctly vested as Bryan S. in deed recorded 6/30/0400 in Book 634 Page 4351) and Laura M. Barrick, husband and wife dated 10/09/06 recorded 2/23/07 in Deed Book 278 Page 4326. M J r f•• ; s, 4t'?a€tf' . 1 i£st1 11'- The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE i4e Patr*ot1WAtW5 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's 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: 04/16/10 04/23/10 04/30110 ----- `.C. ` ................ Sworn to and sdb'scribed before me this 18 day of May, 2010 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L WSW, NotFi.n=nty Lower Paxton Twp., pauMy Commission Bores N26, 2011_ J Member, Pennsylvania Association of Notaries Wot No. 2010.234 t2tr41 Term OM rst44h#k FSS VIL im" it IM mk . AW. Mok J ALL THAT CElftM tract or land with the improvements thereon erected, situate in the Village of Toland, Dickinson Township, Cumberland County, Pennsylvania bounded and described in accordance with a survey by Larry V. Neidlinger R.S.PE., A copy of which is attached hereto as follows: BEGINNING at an iron pin set in common land on the north side ofPiine Grove Road atthe comer of land now or formerly of Janet Kuntz; thence by said land of land Kuntz, north 21 degrees 08 minutes 17 seconds west 182.45 Feet to an iron pin; thence by land now or formerly of Charles Windomaker, north 72 degrees 25 minutes 56 seconds east 29:71 Feet to an iron pin; thence by land now or formerly of Mary Smith; south 21 degrees 08 minutes 17 seconds east 180.60 Feet to an iron pin; thence by said common land on the north side of Pine Grove Road, south 68 degrees 51 minutes 43 seconds west 29.65 feet to an iron pin; the place of beginning: Containing 5.387 square feet, more or less and being improved with a two story frame dwelling house and outbuildings. BEING THE SAME PREMISES which Barton L. Shank and Kelly S. Shank, b/w, by deed dated 1/22/2004 and recorded 2109/2004 m deed book 261 page 2997 conveyed unto beneficial consumer discount company dlb/a Beneficial Mortgage Company Of Pennsylvania, being known as 247 pine Grove Road, Township Of Dickinson, Cumberland County. BEING. PROPERTY PARCEL NUMBER: 09-38-2172-004. BEING KNOWN AS: 247 Pine Grove Road, Gardners, PA 17324 PROPERTY ID NO.: 08-38-2172-0 Title to said premises is vested niIryan S. Barrick And Laura M. Barrick, husband and wife by deed from Bryan S. Barrick (incorrectly vested as bryan s. In deed recorded 00104(IO in book 634 page 4351) and Latrra M. Barrick, husband and wife dated 100/06 recorded 2/23/07 in deed book 278 page 4326. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which OWB REO LLC is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 16th day of February, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 234, at the suit of Bryan S & Laura M Barrick against OWB REO LLC is duly recorded as Instrument Number 201029003. IN TESTIMONY WHEREOF, I have hereunto set my hand IA- and seal of said office this day of _._ 4 A.D. O / (\ of Deeds ?? ? MM ,=4