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HomeMy WebLinkAbout01-1251MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY. I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS !CIVIL DIVISION : Cumberland County Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LZ~AL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin prevlo 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 UNABOGADO IMMEDIATAMENTE, SI NO TIENEABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AV~RIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3357 717-249-3166 or 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment aga'mst 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. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: Book: Page: 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 follows: MORTGAGED PREMISES: 3966 Enola Road MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 10/26/98 DATE RECORDED: 10/29/98 BOOK: being foreclosed is as Upper Frankford Township 1492 PAGE: 1109 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 in the event of a third party purchaser at Sheriff,s Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner,s Emergency Mortgage Assistance Program, Act 91 of 1983, has not been sent because the loan is over 24 months delinquent and the notice is therefore not required. WHEREFORE, the Defendant (s) the Plaintiff demands herein in the sum of costs and attorneys fees as more and for foreclosure and sale judgment, in rem, against $262,267.30 plus interest, fully set forth in the Complaint, of the Mortgaged premises. Mark~-Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 P~2/19 ALL THAT CERTAIN PIECE OR PARCEL OF ~/~D, SITUATE IN UPPER FRA~KFO~D TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVANIA, MORE PARTICULARLy BOURDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPRoVEMENTs ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FOHMERLy OF HAROLD T. SHOFFNER A~D LAND NOW OR FORMERLy OF RAy A. OP, NEH (WNIcH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDs WEST 881.57 FEET FROM PA. ROUTE 944)~ THENCE ALONG LAND NOW OF FOI~MEHLY OF SAT A. OF, NEE AND THROUGH A 10.5 FOOT DIRT LA!qE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN~ THENCE STILL ALONG LANDS NOW OR FORMERLy OF PAy A. OPENER, NORTH 24 DEGREES 45 MINUTEs 00 SEcoNDs WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423~ THENCE ALONG The EDGE OF TOWNSHIp ROAD T-423, NORTH 43 DEGREES 59 MINUTEs 46 SECONDs WEST 32.51 FEET TO AN IRON PIN AT A TREE AND C01~NER OF LANDs NOW OR FORMERLy OF LEROy E. PAUDA~AUGH~ THENCE BY LANDs NOW OR FOI~MERLy OF LEROy H. PAUDA~AUGE AND LANDS NOW OR FORMERLy OF MARVIN L. R~'rH, SOUTH 77 DEGREES 07 MINUTEs 15 SECONDs EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST~ THENCE STILL BY LANDS OF MARVI~ L. RUTH THE FOLLOWING COURSES AND DISTANCES~ SOUTH 61 DEGREES 16 MINUTEs 02 SECONDS EAST 37S.47 FEET TO AN IRON PIN AT AN EXISTING POST~ SOUTH 14 DEGREES 45 MINUTES 12 SECONDs PAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST~ SO~TH ,27 DEGREES 46 MINUTEs 01 SECOND PAST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST~ SOUTH 10 DEGREES 16 MInuTES 37 SECONDs PAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST~ SOUTH 21 DEGREES 15 M~NUTEs 43 SECONDS EAST 320.30 FEET TO AN IRON PIH~ SOUTH 29 DEGHEES 55 MINUTEs 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDs NOW OR FOrMERLy OF MARVIN L. RUTH AND LANDs OF EDGAR E. EOOVER~ THENCE BY LANDS NOW OR FOrMERLy OF EDGAR E. HOOVER AND LANDs NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTEs 01 SECONDs WEST 1,705.08 FEET TO AN IRON PIN AT COHNER OF LANDs NOW OR FOHMERLY OF HAROLD T. SHOFFNER AND PAy A. OENER, THE PLACE OF BEGINNING. CONTAININ~ 86.06?? ACRES AND SAID DESCRIPTION BEING IN ACCOADANCE WITH SURVEy OF CARL D. BERT, R.S., DATED FEBRUARy 20, 1975. TOGETHER WITH THE EIGHT OF WAy FROM A PRIVATE ROAD OR LAND EXTF/~DIHG FROM SOUTHWESTEi~N COI~NER OF SAID TPACT OF LAND OVER, THROUGH AND ACROSS THE LANDs NOW OR FOP~MERLy OF PHOEEE A. WARNEH TO HIGHWAy ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TPACT OF LA~D. J Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he 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 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. ! ~ar~' J~. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. SheriWs Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills Law Library Prothonotary 1.00 Share of Bills Mileage 6.90 Levy 15.00 Advertising Certified Mail Poundage 1.66 Law Journal Patriot News $ 84.56 paid by attorney 3-18-02 Sworn and subscribed to before me This 2)0 ~ dayof 314~e~A .~ A ~ / 2002, .D.2~~~ ~ Prothonotary So An_swer~: R. Thomas Kline, Sheriff Real Estate Deputy HARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS !CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSURE NO. 01-1251 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address Michael J. Janesko 3966 Enola Road, Newvilte, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 4. Name and address of the last r~corded holder of every mortgage of record: Name Address Plaintiff herein. United Credit Card Bank N.A. A National Bank Martson Deardorff Williams & Otto See Caption above. 8550 United Plaza Blvd., Baton Rouge, LA 70809 10 East High Street, Carlisle, Ste. 203 PA 17013 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 the property and whose interest may be affected by the sale: Name Address in Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of every knowledge who has any interest the sale: Name Tenants/Occupants 1 Courthouse Square, 1 Courthouse Square, Bureau of Compliance, Carlise, PA 17013 Carlise, PA 17013 Dept. 280946 Harrisbur9, PA 17128-0946 other person of whom the plaintiff has in the property which may be affected by Address 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowled9e or information and ~elief. 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 15, 2002 f ~~ & ASSOCIATES ~ /Maz~k J. %drenkESQ. ~_~Attorney for Pl~ntiff · ~ J. UD?~ R AsSOCiATES ATTY ~.P. ~O. 04302 1040 N. K~NGS H~G~AY' suiTE 500 CHEP~Y ~LL, NJ 0B034 :856_452.6~CoURT oF COMMON pLEAS cumberland County Corporation MacArthUr Ridge IT 909 ~idden ~idge Dr~ve' suite ~ MORTGAGE FoRECLoS~E 2O0 i~ing, TX 75038 plainti~ Vo NO. Michael J' janeSko E. Jade janeSko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(S) 01-1251 civil Term TO: E. Jade janesko, Mortgagor 3966 Enola Road L-~e% at 3966 Eno£_ -- June 5, 2002, ~% . ' e (real es~~ , eriff,s sale u~ ~,,se car£1~le, your houS _ ~ ~old at the Sh ~d Floor, Cou~U~.~ ~ntlff ahoy =~heduled to ~ - u=aring Room, ~--- ^ o~ obtalneu ~ ~- ~=_ commissioners ~ -~ of $268,79u.o~, the property wil ~ ~orce the court DuGgm~''~ If the sale is postponed, (the mortgagee) against yoU. be relisted for the Next Available Sale. To prevent this sheriff's sale, you must take ~~ 1. The sale will be cancelled if you pay to the mortgagee the hack payment, chargeS, costs and reaSOnable attorney's feeS. To find out how much you must P you may call: ~5~4~ · you may be able to stop the sale bY filing a petition asking the court to st~ 2 or open the judg~e if the judgmen~ was improperly entered· you may alSO ~ the sale for good cause- the court to 3. you may also be able to stop the sale through other legal proceedings· you ~ay need an attorney to assert your rights- The sooner you contact one, more chance you will have of stopping the sale. (See notice on page two oI to obtain an attorney-) ~D/i~A~-TILL~LE~T0 SAN~_~y~0~R~OP~E~ Y0~L~HAV~.~THE~ RI~kLTS 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 856-482-6900. 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 856-482-6900. 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 AFF0~D ONE, GO TO OR TELEPHONE TH~ OFFICE LISTED BELOW TO FIND OUT W~ERE YOU CAN GET LEGAL HELP. LAWYER REFEP-~AL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FP~ANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF 'LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER ~ I2LND NOW OR FORMERLY OF RAY A. ORNER (W/qICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER ~ THROUGH A 10.5 FOOT DIRT LkNE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF HAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINDTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES %6 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN'EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH A_ND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF FL~ROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF FJ~ROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES A_ND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD (~R LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, TH~OUGHAND ACROSS THE LANDs NOW OR FORMERLY OF PHOEBE A. WARNER TO HIGHWAY ROUTE NO. 944 ~ NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MIC}{AEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. wit back, YOU SH~ ~ 01_%25~ CiVi% : ~qO. : : : : Michael ~es~o, "'- ~. jade ~- Road ~966 EP°~a~ 17241 ~eW~ille' ~ Defendant,s%  o · Michael J' J~ w~le, PA 17241 TO. ~966 En°lao~ 17241 _-a~ Road, !e ~2002, a~ ~:0% ~n ~.~orCe the ,~ To prevent this sheriff' s sale, you must ~ed if yo ' s ~ees- ike ~ be canCe~le att°~eY ~ w~l~ eaSO~ 3n asking the courtask c~es' ~%%: ~ . the Co to stop t ~e able ~o asse~ { - the you ~Y -ce you ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FR-ANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LA_ND NOW OR FORMERLY OF FLAROLD T. SHOFFNER ~ LAND NOW OR FORMERLY OF RAY A. ORNER (WHIC"H IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER ~ THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF HAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINI3TES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE ~ CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES '46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT ~ EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN'EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH ~ LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER AND RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES ~dFD SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARy 20, 1975. G T THROUGH ACROSS SAID TEAOT OF OVER, ........ = mu~ u~ ~'URMERLY OF PHOEBE A. WARNER TO HIGHWAY ROUTE NO. 944 ~ NOW AS A MEANs OF ACCESS TO AND FROM TEACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM ~u~ z/~/±~4 IN DEED BOOK 101 PAGE 846. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) ~ ' NO 01-1251 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORPORATION MACARTHUR RIDGE H, Plaintiff(s) From MICHAEL J. JANESKO AND E JADE JANESKO MORTGAGOR, 3966 ENOLA ROAD, NEWVILLE, PA 17241 (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 fi.om 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 pr°perty °f 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 $268,790.83 L.L. Interest FROM 6/6/01 TO DATE OF SALE 6/5/02 PER DIEM ~ $47.90 - $17,483.50 Atty's Comm % Atty Paid $1,167.38 Plaintiff Paid Date: MARCH 1, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name MARK J. UDREN, ESQ Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLA/NTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale On March 12, 2002 the sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA known and numbered as 3966 Enola Road, Newville and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2002 By: Real Estate Deputy SHERIFF'S CASE NO: 2001-01251 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS JANESKO MICHAEL J ET AL RETURN - REGULAR DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JANESKO MICHAEL J the DEFENDANT , at 0013:35 HOURS, on the at 3966 ENOLA ROAD 9th day of March 2001 NEWVILLE, PA 17241 E. JADE JANESKO (WIFE) by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 10.00 .00 --34.20 Sworn and Subscribed to before me this '2'7 ~- _ _ day of ~' ~1 A.D. --~'/Pr0['honot&ry So Answers: R. Thomas Kline 03/12/2001 MARK J. UDREN, ASSOC. Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2001-01251 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS JANESKO MICHAEL J ET AL REGULAR DAWN KELL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JANESKO E JADE the DEPENDANT at ~0013:3~ HOURS, at 3966 ENOLA ROAD NEWVILLE, PA 17241 E. JADE JANESKO on the 9th day of March 2001 by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this __~7~ day of ~z~ ~ A.D. t~r~t honor ary So Answers- . R. Thomas Kline 03/12/2001 MARK J. UDREN, ASSOC. Deputy Sheriff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 0803% 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 500 Defendant (s) : ATTOP.NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 civil Term PRAECIPE FOR JUDGMENT FOR FAILUI~E TO A~S/N~ ASSES~RNT OF DAMAGE~ TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) 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: $262,267.30 5,550.48 As set forth in Complaint Interest From 2/22/01 to 6/05/01 Late charges per Complaint From 3/15/01 to 6/05/01 Escrow payment per Complaint From 3/01/01 to 6/05/01 I hereby certify Defendant are as shown accordance with Rule 257.61 TOTAL ~268.73_0.8:t that (1) the addresses of the Plaintiff above, and (2) that notice has been given 237.1, a copy of which is attached hereto. Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS PRO PROTHY and in MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 Civil Term DATED: TO: A~ril 2, 2001 Michael J. Janesko 3966 Enola Road Newville, PA 17241 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 JUDGMENTMAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YoU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TARE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland ~unty Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRiTA~BAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: pURSUANT TO TEE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. AiTY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION cumberland County NO. 01-1251 Civil Term DATED: April 2, 2001 TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 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 PODEA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBAALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO I~EDIATAMENTE 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 ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland ~gunty Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 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. MA~K J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0%302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 01-1251 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF New Jersey : : SS COUNTY OF Camden : THE UNDERSIGNED beinq 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: Michael J. Janesko Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: E. Jade Janesko, Mortgagor Residence: As captioned above Employment: Unknown Name: ~ar~ J. ~en, Esqu~r~ Title:~ Attorney [or Plalnui~i Sworn to and subscribed Company: Mark J. Udren & Associates before me this 5th day of June, 2001. ]ACQU~LIN[ A. A Notary Public ol New Jersey My Commission Expires 4/7/2003 No. NeWVZ~ ' Defendant (S) : 01_1251 civil Term TO: E. Jade janeSko, Mortgagor 3966 Enola Road Newville, PA 17241 NOTICE you.re hereby pennsylvania, ~in the above pursuant to Rule 236 of the supreme court of you a Judgment haS been entered against notified that prothonotary proceeding aS indicated belOW. ~ judgment by Default Money judgment ~-- judgment in RepleVin judgment for possession judgment on Award of Arbitration judgment on verdict judgment on court Findings ~E CALL: IF yOU HAVE ANY QUESTIONS coNCERNING THIS NOTICE pt ATTORlqEY-~ At this telephone number:~~~lQ~ i MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) NO. 01-1251 Civil Term TO: E. Jade Janesko, Mortgagor 3966 Enola Road Ne~rville, PA 17241 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEy Mark J. Udren. Esquire At this telephone number: 856-482-6900 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (s) ATTOP~NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term PRAECIPE FOR ~uDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DA~A~uF~ TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) 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 From 2/22/01 to 6/05/01 Late charges per Complaint From 3/15/01 to 6/05/01 Escrow payment per Complaint From 3/01/01 to 6/05/01 $262,267.30 5,550.48 257.61 TOTAL I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. ~IATES Mark J~ ~dren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDITED PRO ~ROTHY MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORIFEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE . . NO. 01-1251 Civil Term TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, notified that a Judgment has been entered against you proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCEP, NING THIS NOTICE PLEASE CALL: ATTORIqEY Mark J. Udren. Es_c/mire At this telephone number: 856-482-6900 you are hereby in the above MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term PRAECIPE FOR OuDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGR~ TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) 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 $262,267.30 Interest 5,550.48 From 2/22/01 to 6/05/01 Late charges per Complaint 257.61 From 3/15/01 to 6/05/01 Escrow payment per Complaint ~ From 3/01/01 to 6/05/01 TOTAL SEL~?u~ZgD~2~3 (1) the of the Plaintiff I hereby certify that addresses Defendant are as shown above, and (2) that notice has been given accordance with Rule 237.1, a copy of which is attached hereto. Mark J~ ~dren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: ~ - /4 - 0~ /,f'~(.t~, PRO PROTHY and in MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (s) : . i NO. . .- .- 01-1251 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest @6% From J~~ to Date of Sale September 5. 2001 Per diem @$53.37 (Costs to be added) $2u~8~790.83 MARK J. UDREN & ASSOCIATES ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED A_ND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AI~D LAND NOW OR FORMERLY OF RAy A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF HAy A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. OR/~ER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE .BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH AND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES 46 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT COP-NER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH AND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF EAROLD T. SHOFFNER AND RAy A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARy 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, THROUGH ANDACROSS THE LANDS NOW OR FORMERLy OF PHOEBE A. WARNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZA~BETH B. HILLIARD, HUSBAND ~ WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTOR/qEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term CERTIFICATE Mark J. Udren, Esquire, hereby states that he is 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: Sec. ) ) ) (x) ( ) An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 4904 relating to unsworn falsification to authorities. Pa. MARK J. & ASSOCIATES ark J. L~dr[n, ~SQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY FOI~ pLAII~TIFF F~ J' UDP. EN & AssOCiATES BY: Mark J- udren, ~squire ATTY ~.D. NO. 04302 1040 N. K~NGS H~GHWAY, suiTE 500 cHEP~Y H~LL, NJ 08034 856_482.6900/---------~--------~coURT OF COMMON pLEAS united companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, suite 200 Irving, TX 75038 : plaintiff : CIVIL DivISION Cumberland County MORTGAGE FORECLOSURE Vo NO. 01-1251 civil Term Michael J- janesko E. Jade janesko, Mortgagor 3966 Enola Road Newville, PA 17241 : Defendant(s) : AFFIDAVIT pURsUAlqT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1 Name and address of owner(S) or reputed owner(S): · Address 3966 Enola Road, Newville, 3966 Enola Road, New~ille, of Defendant(s) in the judgment: AddreSS PA 17241 PA 17241 Name Michael J- janesko E. Jade janesko, Mortgagor 2. Name and address Name Same as % i above 3. Name and address of every judgment creditor whose judgment is a reco= lien on the real property to be sold: Address Name Greenwood Trust Co., NovUS Services, Inc & Discover card Carrie E. RouSh a ' Market Saturd Y s PO Box 25010, Newark, NJ 19726 4118 Green Court, Harrisburg, 3751 E. HBG Pike, MiddletoWn, PA 17110 PA 17057 4. Name and address record: Name of the Plaintiff herein. United Credit Card Bank, NA, A National Bank Martson Deardorff Williams & Otto last recorded holder of every Address See Caption above. 8550 United Plaza Blvd., Ste. Rouge, LA 70809 10 East High Street, Carlisle, mortgage of 203, Baton PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None the property and whose interest may be affected by the sale: Name Address Name and address of every other person who has any record interest in Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street, 13 N. Hanover Street, Bureau of Compliance, Harrisburg, Carlisle, PA 17013 Carlisle, PA 17013 Dept. 280946 PA 17128-0946 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 3966 Enola Road, Newville, PA 17241 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: June 5, 2001 MARK J. UDREN & ASSOCIATES Mar~--ES--~---~ Attorney for Plaintiff MARK J. UDREN & AssoCIATES BY: Mark J- udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, sUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending corporation MacArthur Ridge II 909 Hidden Ridge Drive, suite 200 Irving, TX 75038 Plaintiff ATTORNEY FOR pLAINTIFF COURT OF coMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael J- janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(S) NO. 01-1251 civil Term TO: Michael J- janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Ne~ville, PA 17241 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, · t of $268,790.83, obtained by Plaintiff D~ 0 enforce the court ]u~gm~n .... ~ the sale is postponed, the ~, t a ee) agalnS~ yuu. ~ . above (the mortg g ...... ~e Next Available Sale. property will be re±lstea ~uz ~,. To prevent this sheriff's Sale, you must take i~e~%ia~=~= 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: IBS=6~82r~9/k0~ 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-) 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 856-482-6900. 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 856-482-6900. 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 PA~ER TO YOUR ~AWYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFOP~D ONE, ~0 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT NEERE YOU CAN ~ET LEGAL HELp. LAWYER ~EFEP~-~L SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ATTO~I"~ FOE ATT~ ~'~' ~,v. suiTE 500 10%0 ~' K~S CH~RRY H~' ~j 0805& . COLTKT OF COMMON pLEAS united Companies Lending : CIVTL DivTsION cumberland County CorporatiOn MacArthur Ridge TI ' 909 Hidden Ridge Drive, suite MORTGAGE FORECLOSURE 200 irving, TX 75038 plaintiff Michael J- janeskO ~ NO. E. Jade janeSko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(S) 01-1251 civil Term TO: E. Jade janesko, Mortgagor 3966 Enola Road Newville, PA 17241 house (real estate) at 3966 Enola Road, Newville, PA 17241 i sheriff's sale on September 5, 2001, at %0:£ ' e Commissi°nerS~%~?~nt of $268,79~'8~'~ is postponed, ti AM ~n th .... the cour5 J~ ..... If the PA, to en~Oz~ ~-~ee) againS~ ~'~ Available Sa£e- ~ --- (the mor~D ~ ~ the property w~x~ ~ - NQTJ~~ To prevent this sheriff's Sale, you must take i  mortgagee the back pa~ent, ] elled i~ you pay to the 1. The sale will be canC -~ attO~eY's ~eeS. To ~ind out how much you must c~rges, costs and re you ~Y call: ~ st alSO you ~Y be ~le to stop the sale by filing a petition asking the court to 2. or open the judgment, if the judgment was improperly entered- you may the court to postpone the sale for good cause- 3. you ~Y also be able to stOp the sale through other legal proceedings- you ~Y need ~ attorney to assert your rightS. The sooner you contact one more c~nCe you will have o~ stopping the sale- (See notice on page two o to obtain an attorney-) 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 856-482-6900. 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 856-482-6900. 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 YOU~ LA~gYER AT ONCE. IF YOU DO NOT HAVE A LAW~ER OR CANNOT A~FO~D ONe, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT W~ERE YOU CAN OET LEGAL HELP. LAWyER ~FERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADos DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 :CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 Civil Term ATTOP~NEY FOR PLAINTIFF AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, 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, hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. relating to unsworn falsification to authorities. Dated: August 2, 2001 attached with said Pa Rule C.P. Section 4904 ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MA~K J. DDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF 5OO COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, 2. Name and address of Defendant(s) in the judgment: Name Address PA 17241 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 Greenwood Trust Co., Novus Services, Inc & Discover Card Carrie E. Roush PO Box 25010, Newark, NJ 19726 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 4. Name record: Name and address of the last recorded holder of every mortgage of Address Plaintiff herein. United Credit Card Bank, NA, A National Bank Martson Deardorff Williams & Otto See Caption above. 8550 United Plaza Blvd., Ste. 203, Baton Rouge, LA 70809 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 COURTHOUSE SQUARE, 13 N. Hanover Street, Carlisle, PA 17013 Domestic Relations Section 1 COURTHOUSE SQUARE, 13 N. Hanover Street, Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 3966 Enola Road, Newville, PA 17241 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. MARK J. UDREN & ASSOCIATES DATED: AUGUST 2, 2001 Mark J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE CHERRY HILL, NJ 08034 856-482-690O United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael d. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road New~ille, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF 500 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 civil Term DATE: June 12, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OWNER(S): HICHAEL J. JANESKO & E. JADE JANESKO, MORTGAGOR PROPERTY: 3966 Enola Road, New~ille, PA 17241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~ County Sheriff's Sale on ~b~r~, at 10:00 AM, at the COURTHOUSE, COMMISSIONERS HEARING ROOM, 2ND FLOOR, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A z~ A United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.50 Share of Bills 25.66 Mileage 6.50 Levy 15.00 Advertising 15.00 Certified Mail 4.27 Poundage 20.25 Postpone Sale 20.00 Law Journal 465.35 Patriot News 384.33 $1032.86 paid by attorney Sworn and subscribed to before me This _/F ~'~day of ~e~ Prothonotary So Answers: R. Thomas Kline, Sheriff Rdal Estfite Deputy ~ ]1q~°6, MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHE1%RY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo ATTOR/qEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County - MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road New~ille, PA 17241 NO. 01-1251 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RLrLE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 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 Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 REAL ESTAi'E SALE No. z~' 3n ~, ~ 13, Och~ I interest in the real DroDertv Zi,,,~or; in Gummed Count, P~ ~¢/,~ ... and m~ the sheriff levied upon the oe~e~:~ ,mbered as: ~ ~ ~ !xhibit "~ m~ this writ ~ by this PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND · SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 20, 27, AUGUST 3, 2001 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. RF, AL ESTATE 8ALE NO. 28 Writ No. 2001-1251 Civil United Companies Lending Corporation VS. Michael J. Janesko and E. Jade Janesko Atty.: Mark J. Udren ALL THAT CERTAIN piece or par eel of land. situate in Upper Frank- ford Township, Cumberland Cotm- ty, Pennsylvania, more particularly bounded and described as follows, Harold T. Shoffner and land now or formerly of Ray A. Omer (which iron Roger ~ SWORN TO AND SUBSCRIBED before me this 3 dayof AUGUST 2001 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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-New.~ 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 41h, 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 241h and 31st day(s) of July and the 7th day(s) of August 2001. That neither he 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 he 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 1o 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 Miscella~3~ous Book "M", Volume 14, Page 317. / PUBLICATION ........................................... ..~...~. ~... S A L E ~28 ' ~L E~:~, ~ Me.r, Pennsy.~a ~ m ~My commission expires June 6, 2~2 ~ : CUMBERED ~U~ SHERI~S ~E CUMBERED ~U~ ~SE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 382.83 $ 1.50 $ 384.33 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and T n P ri - w , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. Docket for Case: "+ GetCaseNo0 + ,, (. + DktTypeExpand(m.gsDktType) + ,,) Page 1 of 2 Filing Date 08/31/01 08/31/01 09/19/01 09/27/01 10/18/01 11/19/01 11/19/01 11/20/01 11/30/0l 11/30/01 12/03/0l 12/07/01 12/07/01 01/02/02 01/02/02 01/09/02 01/14/02 01/16/02 Bankruptcy Docket Report 1 01-04746 (Harrisburg) JANESKO, MICHAEL J and JANESKO, ELLEN J Docket items entered between 01/01/1931 and 02/07/2002 Docket Entry VOLUNTARY PETITION under Chapter 13 & Mailing Matrix [Disposed] [EOD 08/31/01 ] [CR] NOTICE of intent to dismiss case unless missing documents are filed: due by 09/17/01 Re: Item # 1. [Complied] [EOD 08/31/01 ] [CR] CORRESPONDENCE to Attorney allowing until September 26, 2001 to file missing documents. Re: Item # 2. [EOD 09/19/01] [CA] Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. [EOD 09/28/01 ] [BR] CERTIFICATE of Mailing of Notice of 34~Meeting. Objections to the plan are due 15 days after meeting held. [EOD 10/18/01] [CA] 341 meeting held. [EOD 11/20/01] [CA] MOTION for relief from stay filed by EMC MORTGAGE CORPORATION. (Pd., $75.00 Rec.#576228) [Disposed] [EOD 11/19/01 ][SP] REQUEST for admission [EOD 11/19/01] [SP] CERTIFICATE OF NON-CONCURRENCE [EOD 11/19/01 ][SP] ORDER that answers aredue on 12/10/01 Re: Item # 6. [Resched~lled] [EOD 11/19/01] [SP] 341 meeting not held-to be rescheduled. [EOD 11/20/01 ] [CA] ~ CORRESPONDENCE from Movant requesting reissuance of Stay Order due to non-service. Re: Item # 7. [EOD 11/30/01] [SP] ORDER that answers aredue on 12/20/01 Re: Item # 6. [EOD 11/30/01] [SP] ~ This entry cancels the previous due date. Re: Item # 7. [EOD 11/30/01] [SP] CERTIFICATE of service of notice of rescheduled 341 Meeting [EOD 12/03/01 ] [CA] MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on-~l/10/02 at 02:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 [EOD 12/07/01] [SP] CERTIFICATE of service Re: Item # 10. [EOD 12/07/01] lICE] MOTION for default judgment Re: Item # 6. [Disposed] [EOD 01/02/02] [SP] ORDER granting default judgment Re: Item # 14. [EOD 01/02/02] [SP] ORDER granting relief from stay Re: ltem# 6. [EOD 01/02/02] [SP] MOTION to reconsider Order Re: Item # 15. [EOD 01/10/02] [CG] CORRESPONDENCE SETTING PHONE CONFERENCE on 02/05/02 at 10:30 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRiSBURG,PA. Re: Item # 16. [EOD 01/14/02] ICG] CORRESPONDENCE from Trustee re: hearing. No appearances for debtor. Case to be dismissed. Re: Item # 12. [EOD 01/16/02] [CG] http://pacer.pamb.uscourts.gov/cgi_bin/foxweb exe/npaeer/nPacergExecThis=docket&pui 02/07/2002 Docket for Case: "+ GetCaseNo0 + ,, (,, + DktTypeExpand(m.gsDktType) + ,,) Page 2 of 2 01/18/02 19 341 meeting not held-to be dismissed. [EOD 01/18/02] [CA] 01/22/02 20 ANSWER by EMC MORTGAGE CORPORATION Re: Item # 16. [EOD 01/22/02] ICG] 02/04/02 21 ORDER dismissing case for Debtors'failure to appear at 341 Meeting and upon Trustee's Motion to Dismiss Re: Item # 1. [EOD 02/04/02] [CG] 02/06/02 22 FINAL REPORT of Ch. 13 Trustee Re: Item # 21. [EOD 02/06/02] [DR] 02 11:13:44 PACER Service Center Transaction Receipt 02/07/2002 11:13:44 PACER Login: [Imuo011 {tClient Coae: {Description: [IDocket {{Case Number: }[12001-04746 Billable Pages: _Jl!~.~_{lCost: ilo. 14 Need help? Try the PACER User's Guide ~acer Servic~e Center http://pacer.pamb.uscourts gov/cgi-bin/foxweb exe/npacer/nPacerC, ExecThis=docket&pui 02/07/2002 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Vo ATTORNEy FOR PLAINTI) : COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County · MORTGAGE FORECLOSURE . Plaintiff : Michael J. Janesko E. Jade Janesko, Mortgagor : 3966 Enola Road : Newville, PA 17241 Defendant(s) : CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: NO. 01-1251 Civil Term II. The judgment entered in the above matter is based on an Action: __A. In Assumpsit (Contract) __B. In Trespass (Accident) ~C. In Mortgage Foreclosure __D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. The Defendant(s) own the property being exposed to sale as: An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Pennsylvania. Commonwealth of Resident: Defendanl~ent of the i~ ~k J. Udre~, ESQUIRE ddress & I.~# as above MA~K J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (s) ATTOPA~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From J3~001 to Date of Sale Per diem @$47.90 (Costs to be added) $ $26~L33 0.83 ~5~  EN & ASSOCIATES ~ ) -~ar-k--'J-A--U'r~'~_~ ATTO.,Y FOR~_~NQTUII~ MARK J. DDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTOi~NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ' NO. 01-1251 .- : : Civil Term WRIT OF ~X~CUTION TO THE SHERIFF OF Cumberland COUNTY: TO satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 3966 Enola Road Newville, PA 17241 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From ~ to Date of Sale ~ Per diem @$47.90 (Costs tO be added) By Prothonotary Clerk Date COURT OF COMMON PLEAS NO. 01-1251 Civil Term United Companies Lending Corporation vs. Michael J. Janesko E. Jade Janesko, Mortgagor WRIT OF EXECUTION REAL DEBT $ 268,790.83 INTEREST $~ fro~ to Date of Sale ~ Per diem @$47.90 COSTS PAID: PROTHY $ SHERIFF $ STATUTORY COSTS DUE PROTHY. PREMISES TO BE SOLD: 3966 Enola ~d gar~J, ud~ren, E~QUIRE SUITE 500 CHERRY HILL, NJ 08034 (856) 482-6900 ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRA-NKFOPJD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING .AT ~%N IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF F~AROLD T. SHOFFNERAi~D LAND NOW OR FORMERLY OF HAY A. ORNER (WHICIq IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF R3~Y A. ORNER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLY OF LEROY H. HAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. HAUDABAUGH A_ND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES %6 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN'EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH A_ND LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LA/~DS NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF F-AROLD T. SHOFFNER AND RAy A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES A_ND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARy 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF I2~ND OVER, THROUGH ~ ACRO'SS THE LAIRDS NOW OR FORMERLY OF PHOEBE A. WkRNER TO HIGHWAY ROUTE NO. 944 AND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIA~.D, HUSBAND ~ WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff Michael J. Janesko E. Jade Janesko, Mortgagor : 3966 Enola Road : Newville, PA 17241 ATTOP/FEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County - MORTGAGE FORECLOSURE NO. 01-1251 Civil Term Defendant(s) : CERTIFICATE Mark J. Udren, Esquire, hereby states that he is 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: Sec. ) ) ) (x) ( ) An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 4904 relating to unsworn falsification to authorities. 18 Pa. CoS. ~K ~.~R~ & ASSOCIATES /~ar~ J. UUrer~, ESQUIRE ~_~ATTOP~NEY FOR ~iNTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2O0 Irving, TX 75038 ATTOR/~Ey FOR PLAINTIFF : COURT OF COMMON PLEAS ! CIVIL DIVISION : Cumberland County -MORTGAGE FORECLOSURE Plaintiff v. Michael J. Janesko :NO. E. Jade Janesko, Mortgagor 3966 Enola Road : Newville, PA 17241 Defendant(s) 01-1251 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 2. Name and address Name Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road, New~ille, of Defendant(s) in the judgment: Address 3966 Enola Road, PA 17241 Newville, PA 17241 Newville, PA 17241 3966 Enola Road, 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush Saturday, s Market 4118 Green Court, Harrisburg, PA 17110 3751 E. HBG Pike, Middletown, PA 17057 4. Name record: Name and address of the last recorded holder Address of every mortgage of Plaintiff herein. United Credit Card Bank N.A. A National Bank Martson Deardorff Williams & Otto See Caption above. 8550 United Plaza Blvd., Baton Rouge, LA 70809 10 East High Street, Ste. 203 Carlisle, PA 17013 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 7. Name and address of knowledge who has any interest the sale: Name 1 Courthouse Square, 1 Courthouse Square, Bureau of Compliance, Carlise, PA 17013 Carlise, PA 17013 Dept. 280946 Harrisburg, PA 17128-0946 every other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 3966 Enola Road, Newville, PA 17241 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: 15, 2002 ~/.~~& ASSOCIATES February · /Maz~ O. Udren~ ESQ. ~~'~r~y~l~ntiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 NO. . : : 01-1251 Civil Term Defendant (s) : , _ Sa?.E OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. E To prevent this Sheriff's Sale, you must take 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: ~ 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.) ~QI/~MAi~gTILL~BE~ABL~ TO SA~E YO~ PROP~EP2~y AND_ YOU~OT}{~T~ 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 856-482-6900. 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 856-482-6900. 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 CAITROT AFFOP. D ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FINE OUT WHERE YOU CAN ~ET LEO. AL HELP. LAWYER REFEI~RAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire 'ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTOP/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 NO. 01-1251 Civil Term Defendant(s) ~$HERIFF'S SALE OF REAL PRO~LTY TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~Q~PREVENT THIS S}{ERIFF'S SAL~ To prevent this Sheriff's Sale, you must take 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: - - 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.) 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 856-482-6900. 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 856-482-6900. 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 OIFE, ~O TO OR TELEPHONE THE OFFICE LIST~ BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FR3~NKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAND NOW OR FORMERLY OF HAROLD T. SHOFFNER AND LAND NOW OR FORMERLY OF RAY A. ORNER (WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FORMERLY OF RAY A. ORNER ~ THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDS NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES 45 MINUTES 00 SECONDS WEST 1,993.20 FEET TO AN IRON PIN AT AN EXISTING POST AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE A-LONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO AN IRON PIN AT A TREE ~ CORNER OF LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH; THENCE BY LANDS NOW OR FORMERLY OF LEROY H. RAUDABAUGH A_ND LANDS NOW OR FORMERLY OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINI3TES 16 SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE STILL BY LANDS OF MARVIN L. RUTH THE FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES %6 MINI/lES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST 213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MINUTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF MARVIN L. RUTH ~ LANDS OF EDGAR E. HOOVER; THENCE BY LANDS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLY OF FIAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLY OF HAROLD T. SHOFFNER ~ RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARY 20, 1975. TOGETHER WITH THE RIGHT OF WAY FROM A PRIVATE ROAD OR LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT OF LAND OVER, TH~OUGHAi~-D ACROSS THE LANDS NOW OR FORMERLY OF PHOEBE A. WARNER TO HIGHWAY ROUTE NO. 944 A_ND NOW AS A MEANS OF ACCESS TO AND FROM TRACT OF LAirD. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHA~EL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND A_ND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. MARl( J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) NO. 01-1251 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From J//Ile to Date of Sale per diem @$41.72 (Costs to be added) $ MARK J. UDREN & ASSOCIATES HARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2O0 Irving, TX 75038 Plaintiff Vo Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEy FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION : Cumberland County · MORTGAGE FORECLOSURE NO. 01-1251 Civil Term TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, are directed to levy upon and sell the following described property: 3966 Enola Road Newville, PA 17241 SEE LEGAL DESCRIPTiON ATTACHED you Amount due Interest From J/lu~_6~_2QD~ to Date of Sale Per diem ~$41.72 (Costs to be added) By Prothonotary Clerk Date COURT OF COMMON PLEAS NO~ 01-1251 civil Term United Companies Lending Corporation vs. Michael J. Janesko E. Jade Janesko, Mortgagor WRIT OF EXECUTION REAL DEBT $ ~8~790.g3 INTEREST $_26,6/d7~3~6 fronk_J3/II~6, 2D_Q1 to Date of sale Ma~chi~_231D~ Per diem @$41.72 COSTS PAID: PROTHY SHERIFF STATUTORY $- COSTS DUE PROTHY. $- pREMISES TO BE SOLD: 3966 Enola Road N~, PA 17241 J~r~ J- ~Udrek_~,MARK j. ~, &ES~ATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 (856) 482-6900 ALL THA/~ CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPE~,. FRANKFORD TOWNSHIP, CUMBE~ COUNTy, PENNS YLVA/~,- MORE PARTICULARLy BOUNDED AND DESCRIBED AS FOLLOWS TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: ' Z NOW oR FgRMERLY OF. IRON PIN mS NORTH 22 OEG = = mY A. oRNER FROM PA. ROUTE 944); THENCE ALONG LAND NOW OR FOP,~[ERLY OF RAY A. OR-NER AND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 · MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDs NOW OR FORMERLY OF RAY A. ORNER, NORTH 24 DEGREES. 45 MINIrfES 00 SECONDs WEST 1,993 .'20 FEET TO AN IRON PIN AT ~ EXISTING PO~T AT THE EDGE OF TOWNSHIP ROAD T~423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGRESS 59 MINUTEs 46 SECONDS WEST 32.51 FEET . TO AN IRON PIN AT A TREE A_ND CORNER OF LANDs NOW OR FOR~[ERLY, OF LEROY H. RAUDA.BAUGH; THENCE BY LANDS NOW OR FORMERLy OF LEROY H. · RAUDA~AUGH AND LANDs NOW 8R' FOP,/~tERLy OF MARVIN L. RU/~H, SOUTH 77 DEGREES 07 MINLEFES 16 SECONDs EAST 1,824.37 FEET TO 'AN IRON PIN AT BY LAlqDS OF MARVIN L. RUTH THE ; SOUTH 61 DEGREES 16 MINI3TES '02 SECONDS EAST 375 47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH · 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 27 DEGREES %6 MINI3TES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT A/q EXISTING POST; SOUTH 10 DEGREES 16 MINI3TES 37 SECONDs EAST '213.45 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH 21 DEGREES 15 MII'UJTES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MINUTES 00 SECONDS EAST 511.50 FEET TO AN IRON PIN AT CORNER OF LANDS NOW OR FORMERLy OF MARVIN L. RLEFH ~ LANDS OF EDGAR E. HOOVER; THENCE BY LAb-DS NOW OR FORMERLY OF EDGAR E. HOOVER AND LANDs NOW OR FORMERLY OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MIb-UTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER OF LANDs NOW OR FORMERLY OF HAROLD T. SHOFFNER ~ RAY A. ORNER, THE PLACE OF BEGINNING. CONTAINING 86. 0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEY OF CARL D. BERT, R.S., DATED FEBRUARy 20, 1975. TOGETHER WITH T~E .RIGHT OF WAY 'FROM A PRIVAT ' EXTENDING FROM SOUTH,'.TM .......... E. ROAD ~R LAND ......... "~-~ ~ORNER OF SAID TRACT .0%.Lww~OET~) · ~uu~a AND ACROSS THE LANDS NOW OR FORMERLy OF PHOEBE ..HIGHWAYTRACT OF ROUTE LAND. NO. 944 AND 'NOW AS A MEANS OF ACCESS TO AND FROM BEING ~NOWN AS 39~6 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISEs .IS VESTED IN MICHAEL J. JANESKO BY DEED FROM · MAURICE G. AND ELIZABETh{ B. HILLI~RD, HUSBAND AND WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 10l PAGE 846. the ~ Name Domestic onweal Name ~/edge and Who ~e 're~be~ 25. 20 .p. ~u. 1060 ~' ,~L~, NJ 0505~ ~ ~ OF CO~4~4ON pLEAS ~E~~ ~comPmnie~ ~- . cu~er~ CorpOrati°n~age II ~ suite : ForECLOSUrE ~ ~{~, ~o~TGAGE 909 200 T~ ~5038 NO- 01'1151 Civil Ter~ Name , ~o~Us GreenwoOd Trust Co- -er Card services' Thc & Disco~ Carrie E. KoUSh saturday, s Market 41%8 Green Court, ~arrisburg 375% E' BBG pike, Middlet°W o ola ~oaU _ ;eWville' - Delendant(s~ ' --- ~0 ~UL~ 3129'~ -~ion, by AFF~D~ ~ainti~f ~he date ~=tion, r~ as o~ ~ ..nation .~a Comp~ ~ ~ Uar~, ~ileu ~ ~ ~oa~, ~ attOrney' ~{ ExecUt~ at: 39~o ~ the ~r~ ~ty loCa~ , ~ or repUteu ~ real prop= s" of owner%S' Address 'lle, pA 1. ~ame and addre = 3966 Enola ~oad, Michael J' janeSk° ==nt[s~ in the 3966 Enol5 Ko.d, · ~el J' janes~o 3966 Enola Koad, · M~ch _me janes~O, Mortgagor . jud9~ creditor whose E- J~ -S o~ eve~ be S ' ~nd addre~-o~ertY to Address %9q~6 Name ~ real P~ ~ lien pO Bo~ 25010, Newark, MARK J. UDREN & ASSOCIATEs ,BY: Mark j. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRy HILL, NJ 08034 85___6-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 COURT OF COMMON PLEAs CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff : Michael j. Janesko : E. Jade Janesko, Mortgagor :NO. 3966 Enola Road Newville, PA 17241 : Defendant(s) ~ 01-1251 Civil Term ATTORATEy FOR PLAINTIFF TO: Michael j. Janesko 3966 Enola Road E. Jade Janesko, Mortgagor Newville, PA 17241 3966 Enola Road Ne~ville, PA 17241 YOur house (real estate) at 3966 Enola Road, Newvil scheduled to be sold at the Sheri , le th,e Commissioners Heari~- ~ ffs Sale on March 5 .... ' PA 17241 is enforce the co~ -. ~ ~*~ ~oom, 2nd Floor ~ , ~uu~, at 10:00 AM ' mort~a~ee~ ~ ~.~ 3uugment of $268,790 ~ ,_~ourthouse, Carlisle ~ .~ ~ / ~galnst vou ~ ~ .o~, Obtained ~, ~ .... , =~ , ~o re±lsted for the Ne.~-~ i .~z ~ne sale is Dost ..... ~ .=~lnElff above (the ~u ~val±able Sale. = ~=u, the property will be To prevent this Sheriff.s Sale, you must take ~e~e~%~ti~ 1. The sale will be cancelled if you pay charges, costs and reasonable attorney.s to the mortgagee the back payment, late you may call: /8553~_~kgDQ~ fees. To find out how much you must pay, 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. obtain an attorney.) (See notice on page two on how to If the Sheriff,S Sale is not Stopped, bidder. You may find out the price bid by Calli~¢ r Property Wil~ 2. You may be able to g 8S6-482-6900. ~ be Sold to the highest Was grossly inadequate petition the Court to set aside the Sale cOmpared to the Value of YOur PrOperty. if the bid price 3. The Sale will go through Only if t due in the Sale. To find out if this has hapD~buyer pays the Sheriff the full ~ ~u, You may call 856-482-6900 amount 4. If the amount due from the BUyer is not Paid to the the OWner of the property as if the Sale never happened Sheriff, you Will remain to the .You have the right to remain in the PrOperty ~ntil the ful bring legal prOCeedings to evict You. 6'Sheriff and the Sheriff gives a deed to the buyer. At that A sChedule ~me, the b of distribution o ~hto a share of the Within 30 days af ~e Uyer may · ' for YOUr house Will be filed l~ib~ ~his SChedule wil~ SChedule o~ ~. Scrlbution i~ ~ COrdance wit .~ State who ' by ~ ulStribution ~ ~.rong) are fi~ t~ls SChedule Will be receiv, the Sheriff ~° ~lled. ~ With tB~ ~ Unless e~ ..... lng that 7. You may als ~unln ten (ln~ ~SOns why if You act ' o have Other ~, uays after immediately after rights and defenses, or ways of getting YOUr home back, the Sale· YOU SSOULD T~E TEIS P~ER TO YOU~ ~A~..- - A~FORD O~TE, ~ TO OR T~LEp~O~ ...-- "~T ONC~ ~W TO Cu~erland REFER~ SERVICE C°~tY Bar Association 2 Liberty AVenue Carlisle, 717~249_3166 PA 17013-3387 or 800-990-9108 ASSOCIATION DE LiCENCiD~oS DE Fi~ELFiA Cumberland County Bar Association 2 Liberty Avenue Carlisle, 717-249-3166 PA 17013-3387 or 800-990-9108 Iw-A~ ~' UDP~N & ASSOCIATEs BY: Mark j. Udren, Esquire ATTy I.D. MO. 04302 1040 N. KINGS ~IG~WAy, SUITE 500 C~ERRy ~ILL, NJ 08034 -856 482 6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, SUite 200 Irving, TX 75038 Plaintiff Vo Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant 'COURT OF COMMON PLEAs : CIVIL DIVISION ~ Cumberland County ' MORTGAGE FORECLosURE NO. 01-1251 Civil Term ATTORNEy FOR PLAINTIFF Mark j. Udren. . C E R T I F I c A T E Pl~%ntiff in the ~Esqulre, hereby Sta~ sUD3ect to the ~r-~°~e-captioned ma~,h~s that he is the ~ ~ uvlSlons of Act 9~ ~=z and that t~ =~u?rney for the ~ mecause it is '~= premises are not ) An FHA insured mortgage NOn-owner OCcupied Vacant ¢ This Sec. 4904 Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. Certification is ma . relating to Unsw~- ~e~s~b3ect to the penalties of 18 ~ rals&flcation to authorities. Pa. C.S. UDREN & ASSOCIATEs %~\~4. Name and address of the yecord: Name Plaintiff herein. United Credit Card Bank N.A. A National Bank Martson Deardorff Williams & Otto last recorded holder of every mortgage Address See Caption above. 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 10 East High Street, Carlisle, PA 17013 5. Name and address of every other person who has any record lien on property: Address Name of the None 6. Name and address of every other person who has any record interest the property and whose interest may be affected by the sale: Name Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue in Address 1 Courthouse Square, 13 N. Hanover St., Carlise, Bureau of Compliance, Dept. Harrisburg, PA 17128-0946 Carlise, PA 17013 PA 17013 280946 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 3966 Enola Road, Newville, PA 17241 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. MARK J. UDREN & ASSOCIATES DATED: November 25, 2002 '~Udren, ESQ. r Plaintiff MAI%K J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF i COURT OF COMMON PLEAS i CIVIL DIVISION : Cumberland County · MORTGAGE FORECLOSURE NO. 01-1251 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every judgment creditor whose judgment lien on the real property to be sold: Name Address is a record Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush 4118 Green Court, Harrisburg, PA 17110 Saturday's Market 3751 E. HBG Pike, Middletown, PA 17057 ~VRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1251 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORP., MacARTHUR RIDGE II Plaintiff (s) From MICHAEL J. and E. JADE JANESKO, 3966 ENOLA ROAD, NEWVILLE PA 17241. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 3966 ENOLA ROAD, NEWVILLE PA 17241 (SEE ATTACHED LEGAL DESCRIPTION). You are also directed to attach the property of the defendant(s) not levied upon in the possession (2) 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 pr°perry °f the defendant(s) not levied upon an subject to attachment is found in the possessinn 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 $268,790.83 L.L. Interest FROM 6/6/01 TO 3/5/03 ~ $41.72 per diem $26,617.36 Atty's Corem % Due Prothy $1.00 Arty Paid $1,267.12 Other Costs Plaintiff Paid Date: DECEMBER 3, 2002 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856) 482-6900 Supreme Court ID No. 47741 CURTIS R. LONG MARK J. UDREN & ASSOCIATES BY= Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP~RY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2O0 Irving, TX 75038 Plaintiff v. Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 De~da-nt~s) ATTOR/~EY FOR PLAINTIFF : COURT OF COMMON PLEAS !CIVIL DIVISION : Cumberland County !NO. 01-1251 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, 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, Order is attached hereto as Exhibit "B". All Notices were served within the 3129. This Affidavit is made subject to ti relating to unsworn falsification tc Dated: February 22, 2003 then proof of compliance with said 1~ set forth by Pa Rule C.P. s.Of 18 Pa.C.S. Section 4904 tK J-~TES Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Rid9e II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) ATTORNEy FOR PLAINTIFF COURT OF COM~4ON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 Civil Term DATE: January 22, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): PROPERTy: Improvements: NOTICE OF SHERIFF,S SALE MICF~EL J. JANESKO & E. JADE JANESKO 3966 Enola Road, Newville, PA 17241 RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~L~o3erjta~d County Sheriff,s Sale on Mar~ch_5~lO2, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A 0 United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko, his wife In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 10:05 o'clock AM, 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: Michael Janesko, by making known unto E. Jade Janesko, wife of defendant, a.t 3966 Enola Road, Newville, Cumberland County, Pennsylvania, its contents ana at the same time handing to her personally the said true the same. . and correct copy of Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 0.05 o clock AM, he served a true copy of the w/thin Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: E. Jade Janesko, by making known unto E. Jade Janesko, personally, at 3966 Enola Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2003 at 7:15 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael J. Janesko and E. Jade Janesko located at 3966 Enola Road, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the acti . . named defendants, to wit: Mic .. on to one of the w~thin of 3966 Enola Road, hael J. Janesko by regular mini to his last known address Newville, PA 17241. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sher/ffmailed a notice of the pendency of the action to one of the within named defendants, to wit: E. Jade Janbsko by regular mail to her last known address of 3966 Enola Road, Newville, PA 17241. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me So Answers: This _ day of 2003, A.D. Prothonotary R. Thomas Kline, Sheriff Real Estate Deput--~ -- United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff's Costs: Docketing 30.00 Poundage 270.00 Surcharge 30.00 Law Library Prothonotary 1.00 Mileage 13.80 Certified Mail 3.10 Levy 15.00 Posting Handbills 15.00 Advertising 15.00 Postpone Sale 20.00 Law Journal 446.75 Patriot News 375.25 Share of Bills 25.21 $1260.11 paid by attorney 6/11/03 Swom and subscribed to before me So Answers: This /~'~ day of R. Thomas Kline, Sheriff 2003, A.D. (~ t~ t~_ '~,_~b_,~, i.~B ~ Prothonotary ~ I.a9 ~ F~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff. Yo ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (s) : NO. 01-1251 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address Michael J. Janesko 3966 Enola Road, Newville, PA 17241 E. Jade Janesko, Mortgagor 3966 Enola Road, Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Greenwood Trust Co., Novus PO Box 25010, Newark, NJ 19726 Services, Inc & Discover Card Carrie E. Roush Saturday's Market 4118 Green Court, Harrisburg, PA 17110 3751 E. HBG Pike, Middletown, PA 17057 4.' Name and address record: Name Plaintiff herein. of the last recorded holder Address See Caption above. of every mortgage of United Credit Card Bank N.A. A National Bank 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 Martson Deardorff Williams & Otto 10 East High Street, Carlisle, PA 17013 5. Name and address of property: Name every other person who has . Address any record lien on [he None 6. Name and address of every other person who has any record the property and whose interest may be affected by the sale: Name Address interest in Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlise, PA 17013 13 N. Hanover St., Carlise, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 3966 Enola Road, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 25, 2002 MARK J. UDREN & ASSOCIATES ~Udren, ESQ. Attorn~r Plaintiff ~ ~% 3. O&302 ~E 500 ~. ~z~' ~ uo-- ': ~ p~~s~°~ ~ co~P~n~=~ : Cu~~ O~a~ ~d~e ~ ~ite : _.~m~G~ = 909 ~ 200 7503B ~ ~0. A S The the t Sched if You YOU SHOI AFFORD C HELp. tl~e Co~ -ne court 3 ~f t ~ortgage.~ the ~e~ '~elistea 1. The _ costs ~;'~ court L r =~e to stop the our r~g ' (See no 3. you ~ay ~e obtafn a ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTy, PENNSYLVAi~k; MORE PARTICb~y BOUNDED AND DESCRIBED' AS FOLLOWS, TOGETHER WITH THE IMPROVEMENTS ERECTED THEREON: BEGINNING AT AN IRON PIN AT CORNER OF LAlgD NOW OR FORMERLy OF HAROLD T. SHOFFNER AND LAND NOW OR FORf4ERLy OF RAy A. ORNER -(WHICH IRON PIN IS NORTH 22 DEGREES 49 MINUTES 38 SECONDS WEST 881.57 FEET FROM PA. ROUTE 944); THENCE ALONG I2kND NOW OR FORi4ERLy OF.. RAy A. ORNER ikND THROUGH A 10.5 FOOT DIRT LANE, NORTH 22 DEGREES 32 .MINUTES 09 SECONDS WEST 864.29 FEET TO AN IRON PIN; THENCE ALONG LANDs NOW OR FORMERLy OF RAY Al OR_N-ER, NORTH 24 DEGREES 45 MI/gu'rEs 00 SECONDS WEST 1,993.'20 FEET TO AN IRON PIN AT AN EXISTING P~T AT THE EDGE OF TOWNSHIP ROAD T-423; THENCE ALONG THE EDGE OF TOWNSHIP ROAD T-423, NORTH 43 DEGREES 59 MINUTES 46 SECONDS WEST 32.51 FEET TO A/~ IRON PIN AT A TREE AND CORNER OF LANDS NOW OR FORMERLy, OF LEROY H. HAUDABAUGH; THENCE BY LANDS NOW OR FORMERLy OF LEROY H. · RAUDA~AUGH AlVD LANDS NOW (gR' FORMERLy OF MARVIN L. RUTH, SOUTH 77 DEGREES 07 MINUTES 16 ~SECONDS EAST 1,824.37 FEET TO AN IRON PIN AT AN EXISTING POST; THENCE 'STILL BY LANDS OF MARVIN L. RUTH FOLLOWING COURSES AND DISTANCES; SOUTH 61 DEGREES 16 MINUTES 02 SECONDS EAST 375.47 FEET TO AN IRON PIN AT AN EXISTING POST; SOUTH · 14 DEGREES 45 MINUTES 12 SECONDS EAST 99.32 FEET TO AN IRON PIN AT AN EXISTING POST; SoLrrH 27 DEGREES ~6 MINUTES 01 SECOND EST 324.81 FEET TO AN IRON PIN AT A_N EXISTING POST; SOUTH 10 DEGREES 16 MINUTES 37 SECONDS EAST ~213.45 FEET TO AN IRON PIN AT AN'EXISTING POST; SOUTH 21 DEGREES 15 MINI/rES 43 SECONDS EAST 320.30 FEET TO AN IRON PIN; SOUTH 29 DEGREES 55 MIl'KITES 00 SECONDS EAST 511.S0 FEET TO AN IRON PIN AT CORNER OF IJLNDS NOW OR FORf4ERLy OF MARVIN L. RL~rH ~ LANDS OF EDGAR E. HOOVER; THENCE BY .LAi~DS NOW OR FORMERLy OF EDGAR E. HOOVER AND LANDS NOW OR FORMERLy OF HAROLD T. SHOFFNER, SOUTH 65 DEGREES 25 MINUTES 01 SECONDS WEST 1,705.08 FEET TO AN IRON PIN AT CORNER .OF LANDS NOW OR FORMERLY OF H3L~OLD T. SHOFFNER ikND RAy A. ORNER, THE PI,ACE OF BEGI1TNING. CONTAINING 86.0677 ACRES AND SAID DESCRIPTION BEING IN ACCORDANCE WITH SURVEy OF C_ARL D. BERT, R.S., DATED FEBRUARy 20, 1975. TOGETHER WITH T~E ..RIGHT OF WAY FROM. A PRIVATE. ROAD 0~R LAND EXTENDING FROM SOUTHWESTERN CORNER OF SAID TRACT .OF LAND OVER, THROUGH A_ND ACROSS THE I2kNDs NOW OR FORbXERLY OF PHOEBE A. 'WA/LNER TO .-HIGHWAY ROUTE NO. 944 ANrD NOW AS A M~EA/gS OF ACCESS TO AND FROM TRACT OF LAND. BEING KNOWN AS 3966 ENOLA ROAD, NEWVILLE, PA TAX ID NO. 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JD/FESKO BY DEED FROM · MAURICE G. AND ELIZA.BETH B. HILLI~kRD, HUSBAND /kNI) WIFE, DATED 2/18/1994 RECORDED 2/18/1994 IN DEED BOOK 101 PAGE 846. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-1251 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORP., MacARTHUR RIDGE II Plaintiff (s) From MICHAEL J. and E. JADE JANESKO, 3966 ENOLA ROAD, NEWVILLE PA 17241. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 3966 ENOLA ROAD, NEWVILLE PA 17241 (SEE ATTACHED LEGAL DESCRIPTION). (2) Y°u are als° 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 pr°perry °f 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 $268,790.83 L.L. Interest FROM 6/6/01 TO 3/5/03 ~ $41.72 per diem $26,617.36 Atty's Corem % Due Prothy $1.00 Arty Paid $1,267.12 Other Costs Plaintiff Paid Date: DECEMBER 3, 2002 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL NJ 08034 Attorney for: PLAINTIFF Telephone: (856) 482-6900 Supreme Court ID No. 47741 CURTIS R. LONG P ot,ota Real Estate Sale # 43 On December 9, 2002 the sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA known and numbered as 3966 Enola Rd., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 9, 2002 Real Estate Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller 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 ~ and Th un Patti t-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 28th day(s) of January and the 4th and 11th day(s) of February 2003. That neither he 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 he 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 orn ,o and subs ri~ be)ore, is 14t~'~ay~ _F'.eb~u~,~ 2003 A.D. My ~ ~r~ J~e 6, 2~ [ OT~R~PUBLIC ~,~~~ My commiss[0n expires June 6, 2006 CUMBER~ND COU~ SHERIFFS OFFICE CUMBERED COU~ ~R~OUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 373.20 $ 1.75 $ 375.25 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of ~and T_~und P i - , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (UnderAct No. 587, approved May 16, 1929), p. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State was established January 2, 1952, and designated by the local courts as the official legal aforesaid, 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 o£the said Cumberland Law Journal on the following dates, viz: -._.___________ JANUARY 31, FEBRUARY 7, 14, 2003 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. REAL F-,STATE SALE NO. 43 Writ No. 2001-1251 Civil United Cornpemles Lending Corporation Michael d. danesko and E. ,Jade ,Janesko Atty.: Mark ,J. Udren ALL THAT CERTAIN piece or par - cci of land, situate in Upper Fra~lk- ford Town~hlp. Cumberland Coma ty, Pennsylvania. more particularly bOundedltand described as follows. together with the improvements erected thereon: BEGINNING at an Iron pin at corner of land now or formerly of Harold T. Shoffner and lands now or forme?y of Ray A. Orner [wh/ch iron pin ~s North 22 degrees 49 min- utes 38 seconds West 881.57 feet from Pa. Route 944); thence along land now or forinerly of Ray A. Orner and through a 10.5 foot dirt lane. --Li~sa~ari~~r 'WOS~ ~aAl ND' SUBS~d~ before me this 14 day of FEBRUARy 2003 Washington Mutual Home Loans, f/k/a PNC Mortgage Corp of America VS Kiran Kumar Dandapat In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3821Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions fi.om Attorney Kfistine Anthou. Sheriff's Costs: Docketing 30.00 Poundage 15.62 Surcharge 20.00 Law Library Prothonotary 1.00 Mileage 20.70 Certified Mail 1.95 Levy 15.00 Posting Handbills 15.00 Advertising 15.00 Postpone Sale 20.00 Posting 6.00 Law Journal 344.45 Patriot News 272.53 Share of Bills 25.21 $ 802.46 paid by attorney 6/11/03 Sworn and subscribed to before me This_/f>~ dayof ~ ! · Prothonotary So Answers: R. Thomas Kline, Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, WASHINGTON MUTUAL HOME CIVIL DIVISION LOANS, f/k/a PNC MORTGAGE CORP. OF AMERICA, PENNSYLVANIA Plaintiff, NO.:01-3821 Civil Term vs. KIR3kN KUMAR DA/gDAPAT, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Kiran Kumar Dandapat, located at 852 Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully described as follows: ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRA/~ KUMAR DA-NDAPAT, OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PEN-NSYLVAigIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO, PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER 09-17-1044-060. 1. The name and address of the owner or reputed owner: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, PA 17011 2. The name and address of the defendant in the judgment: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, PA 17011 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Home Plaintiff Loans, Inc., et al. Travelers Bank PNC Mortgage Corp. of America East Pennsboro Township 11436 Cronhill Drive Owings Mills, MD 21117-2285 539 South Fourth Street Louisville, KY 40202-2531 98 South Enola Drive Enola, PA 17025-2796 4. The name and address of the last record holder of every mortgage of record: Washington Mutual Home Loans, Inc., et al. Plaintiff Dauphin Deposit Bank and Trust Company PO Box 4800 Harrisburg, PA 17111-0800 5. The name and address of every other person who has any record lien on the property: PA Dept. Of Revenue ~ureau of Individual Taxes Domestic Relations Office Tax Assessment Office Department of Welfare Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 P. O. Box 320 Carlisle, PA 17013 Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Commonwealth of Pennsylvania P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant (s) or Current Occupant (s) 852 Erford Road East Pennsboro, PA 17011 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: BY: K~ine M~Anthou, Esquire Attorney for Plaintiff SWORN to and subscribed before me this ~day of Notary Public IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, WASHINGTON MUTUAL HOME LOANS, f/k/a PNC MORTGAGE CORP. OF AMERICA, CIVIL DIVISION PENNSYLVANIA Plaintiff, N0.:01-3821 Civil Term vs. KIRAN KUMAR DANDAPAT, Defendant. TO: NOTICE OF SHERIFF'S SALE OF REAL ESTATV KIRAN KUMAR DANDAPAT 852 Erford Road East Pennsboro, PA 17011 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE COMMISSIONERS' HEARING ROOM, SECOND FLOOR ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17103 on March 05, 2003, at 10:00 A.M., the following described real estate, of which Kiran Kumar Dandapat is the owner or reputed owner: ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT, OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO, PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965 TAX PARCEL NUMBER 09-17-1044-060. ' The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of WASHINGTON MUTUAL HOME LOANS, f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff, vs. KIPJkN KUMAR DANDAPAT, Defendant. at Execution Number 01-3821 Civil Term in the amount of $81,330.30. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be' filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the time and place of sale. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PENNSYLVANIA 17013 (717)249-3166 (800)990-9108 You may have legal rights to prevent the Sheriff,s Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortqaqe Foreclosure an~ Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff,s Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. By: GRENEN & BIRSIC, P.C. Kri t~_~e M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, WASHINGTON MUTUAL HOME CIVIL DIVISION LOANS, f/k/a PNC MORTGAGE CORP. OF AMERICA, PENNSYLVANIA Plaintiff, N0.:01-3821 Civil Term KIRAN KUMAR DANDAPAT, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point at the line dividing Lots Nos. 16(x) and 17; thence along said dividing line South 0 degrees 10 minutes West 150 feet to a point; thence North 89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees 50 minutes West 37.5 feet to the line dividing Lots Nos. 16(s) and 16; thence along said dividing line North 0 degrees 10 minutes East 150 feet to the point of BEGINNING. BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the Cumberland County Recorder's Office in Plan Book 22, Page 64. HAVING thereon erected a dwelling house known and numbered as 852 Erford Road. UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on the aforesaid plan. TOGETHER with all and singular, the tenements, hereditaments and appurtenances to the same, belonging or in any way appertaining, and the reversion and reversions, remainder and remainders, rents, issues, and profits thereof; And Also, all the estate, right, title, interest, property, claim and demand whatsoever, both in law and equity, of the said Parties of the First part, of, in, to or out of the said premises, and every part and parcel thereof. BEING the same premises which Pin Hui Kuo and Kuei Yin~ Kuo (a/k/a Kuei Hui Kuo), his wife, by deed dated March 29, 1996 and recorded on April 1, 1996 in the Office of the Recorder of Deeds for Cumberland County in Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar Dandapat. By: GRENEN & BIRSIC, P.C. K~t~ne M.'--~thou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 DBV 136 Page 965 Tax Parcel No. 09-17-1044-060 5VRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PEN]'*JSYLVANIA) NO01-3821 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS f/k/a PNC MORTGAGE CORP OF AMERICA Plaintiff (s) From KIRAN KUMAR DANDAPAT 852 ER.FORD ROAD, EAST PENNSBORO PA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Y°u are als° directed t° attach the property of the defendant(s) not levied upon in the possession ofl GARNISHEE(S) as follows: and.to notify the garnishee(s) that: (a) an attachraent 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) Ifpr°perty °f the defendant(s) not levied upon an subject to attachment is found in the possessinn 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 $73,592.67 L.L. Interest $7,737.63 Atty's Comm % Atty Paid $1010.02 Plaintiff Paid Date: DECEMBER 3, 2002 Due Prothy $1.00 Other Costs (Seal) REQUESTING PARTY: Name KRISTINE M ANTHOU ESQ CURTIS R. LONG Prothonotary Deputy Address: ONE GATEWAY CENTER, 9 VOgST, PITTSBURGH PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 Real Estate Sale # 30 On December 5, 2002 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA known and numbered as 852 Erford Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 5, 2002 By:; ', ~ ,t~ I ' i ~ ~,~ ! [, Real Estate Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller 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 ~ and The Sunday Patri0t-New~ newspapers of genera~ 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 28th day(s) of January and the 4th and 11th day(s) of February 2003. That neither he 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 he 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. COPY .............................. SALE #30 £ Sworn t~o~ar~:, :~sc is ~'~.D. L Y~E~r~Jme6,~ ~ N~ARY PUBLIC ~m~, ~nns~an~ ~n ~s My commission expires June 6, 2006 ~ ~ CUMBERED ~U~ SHERIFFS OFFICE ~ ~ CUMBERED COU~ ~R~OUSE ~ . CARLISLE, PA. 17013 ~ Statement of Advertising Costs E~ ~ ~ To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached ~ ~ ~ ~ ~ ~ ~ ~ hereto on the above stated dates ~.~ ~, t~=)~ I1; ~ ~ Probating same Notary Fee(s) $ 1.75 .~~5~m Publisher's Receipt for Advertising Cost ~ ~ ~ ~ ~ N~ 0 ~ ~0 publisher of ~and ~he Sunday Patri0t-New~, newspapers of general ~ ~ 1~ ~ ~ ~ of receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of 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: JANUARY 31, FEBRUARY 7, 14, 2003 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 tree. REAL ESTATE SALE NO. 30 Writ No. 2001-3821 Civil Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of America VS, Kiran Kumar Dandapat Atty.: Krlstine Anthou LONG FORM DESCRIPTION ALL ~iAT CERTAIN tract of land situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and lglxl on the here inafter mentioned Plan of Lots: thence along said Erford Road South 89 degrees 50 minutes East 87.5 feet to a point at the line divid- ing Lots Nos. 16(x} oz~d 17; thence along said dividing line South 0 de grees 10 minutes West 150 feet to S/~/I~WORN To~AM~C°S~C'p~EdBiti~ before me this 14 day of FEBRUARY, 2003 Countrywide Home Loans, Inc. VS Kelley S. Betton In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6190 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Poundage 10.23 Surcharge 20.00 Law Library Prothonotary 1.00 Mileage 15.18 Levy 15.00 Posting Handbills 15.00 Advertising 15.00 Law Journal 177.05 Patriot News 197.83 Share of Bills 25.24 $ 521.53 paid by attorney 6/11/03 Sworn and subscribed to before me So Answers: This ]~ day of~_~ R.~.'T~~ . omas Kline, 2003, Prothonotary BY~ COUNTRYWIDE HOME LOANS, INC. Plaintiff, KELLEY S. BETTON Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 01-6190-CV AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) COUNTRYWIDE HOME LOANS~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information conceming the real property located at ~70 WEST BIG SPRING AVENUE~ NEWVILLE~ PA 17241 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KELLEY S. BETTON 70 WEST BIG SPRING AVENUE NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder'ofevery mortgage of record: Name HOUSEHOLD REALTY CORPORATION, INC. C/O C T CORPORATION SYSTEM Last Known Address (if address cannot be reasonably ascertained, please indicate) 1635 MARKET STREET PHILA, PA 19103 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Nanle Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address caimot be reasonably ascertained, please indicate) 70 WEST BIG SPRING AVENUE NEWVILLE, PA 17241 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and beliefi 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. December 31, 2002 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff cOUNTRYWIDE HOME LOANS, INC. Plaintiff, KELLEY S. BETTON Defendant(s). TO: KELLEY S. BETTON 70 WEST BIG SPRING AVENUE NEWVILLE, PA 17241 CUMBERLAND COUNTY No. 01-6190-CV December 31, 2002 * *THIS FIRM IS A DEBT COLLECTOR .4 TTEMPT1NG TO COLLECT A DEBT AND ANY 1NFORMA TION OB TA1NED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT [VAS NOTREAFFIRMED, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINSTPROPERTE ** Your house (real estate) at ~ 70 WEST BIG SPRING AVENUE, NEWVILLE, PA 17241, is scheduled to be sold at the Sheriffs Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of.$75,022.54 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SA!,~ To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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 of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL. TI-I.~'kT CERTA)N proimcty' SITUATE in thc IIorougB of Ncwvillc. County oF Cumberland. in thc Commonwealth o£ Pennsylvania. Being more fully dc~cribc'd in ~m Dccd datecl 08/03/1993. and recorded in Cumberland County. Pa.. on 08/03/1993, among thc L,lnd Records of the County and State set forth above, in Deed Book L36, page 298, and ADDRESS: 70 West Big Spring Avcnuc, Ncwville, PA 17241 BEING Parc=l blo. 28-20-17§4-012 BEING thc ~mc premises wltich John F. Heberlig 8nd Alice Faye Heberlig, his wilE. by deed 0areal August 3. 1993. ant~ r~ord~ in ~m~rla~ County, Pennsylvania on Auguat 3. in D~d BOOR ~6, page 298, granted a~ convey~ unto Kelley S. ~etton, single ~rson. SUBJ~ th Ibc same conditions, exceptions, r~e~atiom a~ r~rictions as are cmlaincd prior de~s foxing ~ain of title. WRIT OF EXECUTION a. nd/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-6190 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From KELLEY S. BETTON, 70 WEST BIG SPRING AVENUE, NEWVILLE, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Y°u 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 $75,022.54 L.L. Interest FROM 12/11/01 TO 6/11/03 (PER DIEM - $12.33) - $6,756.84 AND COSTS Due Prothy $1.00 Other Costs Atty's Comm % Atty Paid $805.46 Plaintiff Paid Date: JANUARY 6, 2003 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE CURTIS R. LONG Prothono~ [~ Deputy Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale # 22 On February 6, 2003 the sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA known and numbered as 70 West Big Spring Ave., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2003 By: ~ Real EstateUDeputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller 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 22nd and 29th day(s) of April and the 6th day(s) of May 2003. That neither he 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 he 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. ........................c', .......................... PUBLICATION COPY Sworn tO and sub~nyuu uu~ore m~'~ 14th day o~a~ 2x003x003x003x003x00~~. Temj L. Russell, Notary Public /~-.'/~_~//' ~ ~-~J~ '~'Y'~"~ . ?. ~," ~ ~,."'-.~ [ NOTARY PUBL C My Commission ~xp~res June t), zuuo . .j .- . . -, Member, Pennsylvania As.~nciation Of Nota~e~COmmiSsiOn expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) $ 196.08 $ 1.75 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and ce~ifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS· Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of 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 25, MAY 2, 9, 2003 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. REAL ESTATE K~E NO. 22 Writ No. 2001-6190 Civil Countrywide Home Loans, Inc. Kelley S. Betton Atty.: Frank Federman ALL THAT CERTAIN property, SITUATE in the Borough of New ville, County of Cumberland, in the Commonwealth of Pennsylvania, Being more fully described in a Deed dated 08/03/199g. and recorded in Cumberland County, Pa., on 08/ 0,3/1993, among the Land Records of the County and State set forth above, in Deed Book I26, page 298, and ~f~ a Ma~'e C(;yne,~ditor SWORN TO AND SUBSCRIBED before me this 9 day of MAY, 2003 MAR~ J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Midden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant (s) ATTOR/TEy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-1251 Civil Term To the Prothonotary: Kindly note on the record that the above Defendant, Michael J. Janesko & Ellen J. Janesko has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on August 31, 2001, Bankruptcy Case No. 01-04746. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff MARK J. DDREN& ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation Mac/Lrthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 ATTOP~NEy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION i Cumberland County MORTGAGE FORECLOSURE Plaintiff : v. Michael J. Janesko : NO. E. Jade Janesko, Mortgagor 3966 Enola Road : Newville, PA 17241 Defendant(s) : 01-1251 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Janesko 2. Name and address Name 3966 Enola Road,Newville, PA 17241 of Defendant(s) in the judgment: Address E. Jade Janesko, Mortgagor 3966 Enola Road,Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Carrie E. Roush Saturdays Market Greenwood Trust Co. Novus Services Inc. Discover Card Address 4118 Green Court, 3751 E. HBG Pike, Harrisburg, PA 17110 Middletown, PA 17057 P.O. Box 25010, Newark, NJ 19726-0010 P.O. Box 25010, Newark, NJ 19726-0010 P.O. Box 25010, Newark, NJ 19726-0010 4. Name and address of the last recorded record: Name Address holder of every mortgage of Plaintiff herein. See Caption above. United Credit Card Bank, NA Martson Deardorff Williams & Otto 8550 United Plaza Blvd., Ste. 203 Baton Rouge, LA 70809 10 East High Street, Carlisle, PA 17013 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 the property and whose interest may be affected by the sale: Name Address in Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 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 3966 Enola Road, Newvilte, PA 17241 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. MARK J. UDREN & ASSOCIATES DATED: August 7, 2003 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 ATTORNEy FOR PLAINTIFF Plaintiff : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County i MORTGAGE FORECLOSURE Vo Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s} : : : . NO. 01-1251 Civil Term PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From6~6~Ol to Date of Sale D~. per diem @$42.42 (Costs to be added) MARK J. UDREN & ASSOCIATES MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 ATTORREy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-1251 Civil Term Defendant(s) CERTIFICATE Mark J. Udren, Esquire, hereby states that he is 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: Sec. ( ) ( ( ) (x) ( An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES I t~ o~ DA~ ~ j. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0~302 1010 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, suite 2O0 Irving, TX 75038 Plaintiff ATTORNEY FOR pLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo NO. Michael J. Janesko : E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) 01-1251 civil Term AFFIDAVIT pURsUANT TO RULE 3129.1 United Companies Lending Corporation, 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: 3966 Enola Road, Newville, PA 17241 1 Name and address of Owner(s) or reputed Owner(s): - Address Name Michael J. Janesko 3966 Enola Road,Newville, PA 17241 2 Name and address of Defendant(S) in the judgment: · Address Name E. Jade Janesko, Mortgagor 3966 Enola Road,Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Address Name Carrie E. Roush Saturdays Market Greenwood Trust Co. Novus Services Inc. Discover Card 4118 Green Court, Harrisburg, PA 17110 3751 E. HBG Pike, Middletown, PA 17057 P.O. Box 25010, Newark, NJ 19726-0010 P.O. Box 25010, Newark, NJ 19726-0010 P.O. Box 25010, Newark, NJ 19726-0010 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAy, SUITE 500 CHERRy HILL, NJ 08034 856-482-6900 ATTORNEy FOR PLAINTIFF United Companies Lending Corporation MacArthur Ridge II 909 Midden Ridge Drive, Suite 2O0 Irving, TX 75038 COURT OF COMMON PLEAs CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff Vo Michael j. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Defendant(s) . NO. 01-1251 Civil Term TO: Michael j. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3~66, Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff s Sal AM~i~n~ Commissioners Hearing Room 2n~e=~-Dec~mber 10, 2003, at 10:00 ib~e =Q~ct~ cou~t Judgment of' $2~ ~3 co~, 3arllsle' PA . -~uzugagee) against vo~ ~= =~' .... =~=u Dy Plaintiff property will be relisted for ~i~7~_~ ~ .~n~. sal~ is postponed, the ~ ~=AU ~vallaDle Sale. To prevent this Sheriff,s Sale, you must take /~e_a~/~/ 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable you may call: ~attorney,s fees. To find out how much you must pay, 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.) 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 856-482-6900. 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 856-482-6900. 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 PAi~ER TO YOUR LAWYER AT ONCH. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C-O TO OR TELEPHONE THE OFFICE LISTED BELOw TO FIND OUT WI~ERE YOU CAN GET LEGAL HELp. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADos DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 WR/T OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1251 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTy: To satisfy the debt, interest and costs due Plaintiff (s) UN/TED COMPANIES LENDING CORPORATION, From MICHAEL j. JANESKO AND E. JADE JANESI(O (1) You are directed to levy upon the property of the defendant (s)and to sell DESCRIPTION. SEE LEGAL (2) Y~u are a~s~ directed t~ attach the pr~perty ~f the defendant(s) n~t ~evied up~n in the p~ssessi~n of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been i . · . . . paying any debt to or for the account of the dec ......... ~ssued, (b) the garmshee(s) ~s en omed fro (s) or otherwise dlsposmg thereoI~ t ) Irom dehvenng any prope~y of the defendant (3) 1f pr~perty ~f the defendant(s) n~t ~evied up~n an subject t~ attachment is f~und in the p~ssessi~n 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 $268,790.83 L.L. Interest FROM 6/6/01 TO DATE OF SALE 12/10/03 - PER DIEM 6542.42 - $38,941.56 Atty's Corem % Due Prothy $1.00 Atty Paid $2842.23 Other Costs Plaintiff Paid Date; SEPTEMBER 10, 2003 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. K/NGS H/GHWAY, SUITE 500 CHERRy HILL, NJ 08034 Attorney for: PLA/NTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 CURTIS R. LONG Prothonotary Deputy United Companies Lending Corporation VS Michael J. Janesko and E. Jade Janesko In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1251 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriffs Costs: Docketing 30.00 Poundage 479.74 Advertising 15.00 Mileage 6.21 Levy 15.00 Surcharge 30.00 Prothonotary 1.00 Share of Bills 28.90 $ 605.85 paid by attorney 10/10/03 Sworn and subscribed to before me So An.~wer~ This /7~ dayof .' ~ R. Thomas Kline, Sheriff 2003, A.D.~,,c~ Prothonotary Real Est~e-Deputy /.trO MAR~ J. UDREN& ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 2O0 Irving, TX 75038 Plaintiff Vo Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS ~ CIVIL DIVISION :Cumberland County · MORTGAGE FORECLOSURE : NO. 01-1251 Civil Term Defendant(s) NOTICE OF SHERIFF'~ SALE OF REAL PROPERTY TO: Michael J. Janesko 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $268,790.83, 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 0WN~.~,S RIGHTS ~OU F~AY RE ABLE TO PREVENT T~IS S~ERIFF,S SA?.~ To prevent this Sheriff's Sale, you must take 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: ~ 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. 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.) 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 856-482-6900. 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 856-482-6900. 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 he 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 TA~E THIS PAPER TO YOUR LA~ER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD OldE, ~0 TO OR TELEPHONE ~ OFFICE LIS~'=D BELOW TO FIND OUT WHERE YOU CAN HET LEC~L HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717~249-3166 or 800-990~9108 MARK J. UDP. EN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 United Companies Lending Corporation MacArthur Ridge II 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTORNEy FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County - MORTGAGE FORECLOSURE Michael J. Janesko E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 NO. . : 01-1251 Civil Term Defendant(s) : NOTICE OF SHERIFF,S SALE OF REAL PROPERTy TO: E. Jade Janesko, Mortgagor 3966 Enola Road Newville, PA 17241 Your house (real estate) at 3966 Enola Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $268,790.83, 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 RI~T~ YOU MAy RE AR?.~ TO PREVENT T~4IS S~ERIFF'E To prevent this Sheriff's Sale, you must take · . 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: - - 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. 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.) ~ ABLE TO SAV~ YOUR PROP~ERTY AND YOU HAVE O'l'~.-'~( RIGa'j-.~ ~ IF THE SHERIFF, S SALE DOES TA~E PYa%C]~ ' 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 856-482-6900. 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 856-482-6900. 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 i~mediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA~/ER AT ONCE. IF YOU DO NOT HAVE A LAW~ER OR C~NNOT APFORD ONE, C,O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FI. ND OUT W~u~E YOU CAN GET LEC~AL HELP. LA~ REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 20, 1975. BEING KNOWN AS: 3966 ENOLA ROAD, NEWVILLE, PA 17241 PROPERTY ID NO.: 43-04-0387-036 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. JANESKO BY DEED FROM MAURICE G. AND ELIZABETH B. HILLIARD, HUSBAND AND WIFE DATED 2/18/94 RECORDED 2/18/94 BOOK 101 PAGE 846. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-1251 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNITED COMPANIES LENDING CORPORATION, Plaintiff (s) From MICHAEL J. JANESKO AND E. JADE JANESKO (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Y°u are als° directed t° 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 gam/shee(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 pr°perty °f the defendant(s) not levied upon an subject to at~:achment 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 garnishee and is enjoined as above stated, a Amount Due $268,790.83 L.L. Interest FROM 6/6/01 TO DATE OF SALE 12/10/03 - PER DIEM 6542.42 - $38,941.56 Atty's Comm % Due Prothy $1.00 Atty Paid $2542.23 Other Costs Plaintiff Paid Date: SEPTEMBER 10, 2003 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 CURTIS R. LONG Prothonot~ Deputy Real Estate Sale # 67 On September 15, 2003 the sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA Known and numbered as 3966 Enola Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 15, 2003 Real Est~e Deputy UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 United Companies Lending Corporation Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVI.q ION Cumberland County Michael J. Janesko 'NO. E. Jade Janesko, Mortgagor : Defendant : 01-125]. Civil Term PRAECIPE TO WITHDRAW ~um~MENT AND DISCONTINUE WITHOUT PREJIJDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: October 12, 2004 Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff