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Home My WebLink About01-1498MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road !CIVIL DIVISION Wayne, NJ 07470 : Plaintiff : Cumberland County v. Dee A. Weigle 160 J%unper Road Newburg, PA 17240 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 LAW~ER 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 HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 Le hah demandado a usted en la corte. $i usted quiere defenderse de estas demandas expuestas en las paginas si~uientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda ¥ la notifica¢ion. Hace falta ascentar una comparen¢ia escri~a o en persona o con un aDogado y entre~ar a la ¢orte en forma escri~a sus defensas o sus ohjeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la torte tomara medidas ¥ puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corse puede decidir a favor del demandan~e ¥ requiere que us~ed cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos impor~antes para usted. LLEVEESTA DEMANDA A UNABO~ADO IMMEDIATAMENTE, SI NO TIENEABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PA~AR TAL SE~VICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESC~ITA ABAJO PA~A AVE~I~UAR DONDE SE PUEDE CONSE~UI~ ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 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 against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obta'med 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: Harris Savings Association Assignments of Record to: VNB Mortgage Services, Inc. Recording Date: 9/5/00 Book: BK654 Page: 73 2. Defendant(s) is the individual desig-nated 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 be±ng 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.RoC.P. 1019 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 45 West Baltimore Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 6/13/89 DATE RECORDED: 6/13/89 BOOK: BK942 PAGE: 205 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 3/14/01: Principal of debt due and unpaid $35,888.41 Interest at 10.25% from 8/1/00 to 3/14/01 (the per diem interest accruing on this debt is $10.08 and that sum should be added each day after 3/14/01) 2,276.87 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $87.44 and that sum should be added on the first of each month after 3/14/01) (38.93) Late Charges (monthly late charge of $38.08 should be added on the fifteenth of each month after 3/14/01) 152.32 Property Inspections 15.00 Attorneys Fees (anticipated and actual to 5% of principal) ~ TOTAL $40,618.09 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff,s Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $40,618.09 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J.~Ud eh, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 DATE:_November 9. 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature, of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) ~nay be able to help to save yonr home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also ~vant to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL'~ANIA HOUSING FINANCE AGENCY) SIN CARGOS ALNUMERO~vlENCIONADOARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A Consumer Loan Center Collection Department 1460 Valley Road Wayne, New Jersey 07470 Tel: (973) 305-8800 Fax: (973) 305-9509 Outside New Jersey: 1-800-226-5201 IIOMEOWNER'S NAME: Dee Thoml)son PROPERTY ADDRESS: 45 W. l~altimore Street Carlisle. PA 17013 LOAN ACCOUNT #: 17203295 ORIGINAL LENDER: CURRENT LENDER: VNB Morteage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAbI YOU bIAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICII CAN SAVE YOUR HOME FRObl FORECLOSURE AND HELP YOU blAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY bIORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR blORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days t¥om the date of this Notice. During that time you must arrange and attend a "face-to~face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALL, ED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MO£CFGAGE UP 'FO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have thc right to apply financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATIONPRObIPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TI.ME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTiON--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, ng foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITIOh' IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFOILMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED. AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply t'or Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date) NATUI~E OF THE DEFAULT--The IVIORTGAGE debt held by the above lender on your property located at: 45 W. Baltimore Street Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENT tbr the following months and the following amounts are now past due: Sem. 2000 thru Nov. 2000 @ $ 468.29 each Total: $1,404.87 Late Charges: $76.16 Escrow Advance: Other charges (explain/itemize): $I5.00 Prot~erW Insr~ection Less Unapplied Balance: -0- TOTAL AIMOUNT PAST DUE: $1.496.03 ~ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,496.03 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: VNB Mortgage Services, Inc. 1460 Valley Road Wayne, New Jersey 07470 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date o~' this letter. (Do not use if not applicable) N/A IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthIy installments. If tull payment or'the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off t.ke mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifyoa cure the default within th~ THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES---The lender may also sue you personally for the unpaid principal balance and ail other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cored the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the SherifFs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sherifl's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the nmuner set Ibrth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such Sheriff's Sale of the mortgaged property could be held would be approximately _6 months from the date of this Notice. A notice of thc actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: VNB Mortgage Services, Inc. 1460 Valley Road Wayne, New Jersey 07470 1(800) 226-5201 Ext. 3541 Enza Scarpulla EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may or __X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. NOTICE The amount o~'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 noti~, 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 xvill assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission ofliability 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. ,, The lender 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. VNB MORTGAGE SERVICES, INC. 1460 Valley Road Wayne, NJ 07470 1-800-226-5201 Ext. 3541 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT h/O CURE YOR DEFAULT MORE THAN THREE TIMES IN ANY CALANDER YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. COLUMBIA C,_~I,r~NTy CCCS of Narth~t~m 31 W. M~ S~e~ 14~ Abi~o~ ~x~ugve P~k P.O. Bo~ 1127 Sui~ 1 Wi~s-Ba~e, PA 18702 C~S~ PA lg411 ($70) 821~837 O~ 1-800-9~-9537 (570) 58~-916~ or 80~922-9537 F~ (570) 821-1785 F~ (570) 587-9134~135 Co~s~n ~ ~cs of L~e C0~ W~kes-B~ PA 18702 (570} 826~10 OR 1-8~82243~9 (570} 4554994 F~ 070) 455-5631-~L BEFO~ (570) ~364090 T~~ Booker T. W~lfington Cent~rr ~a~r ~d~ Co~u~ A~on Co~ 1720 Hol~ S~c~ 18 We~t 9~ S~t E~e, PA 1650~ Erie, PA 1~01 (814) 453-~7~ (814) 4~94581 F~ (814) 4~3-$749 F~ (814) 4~6-0161 John F. ~y Con.r, ~c. $he~go V~]~ U~ ~g, Inc. 2021 E~t 20~ $mct 601 h~ Avmm Ede, PA 16510 F~I[ PA 16121 (S~4) 8~S-0400 (4~) 9S]-5310 F~ (814) 898-1243 CIJ~B_ERLAND COUNTY CCCS of Western P~nn~ylva~ia, Ink Fin~ci~ Coupling S~c~ of F~I~ 2000 L~l~to~ Road 31 West 3rd H~b~g, PA 17102 Wa~esboro, PA 17268 (717) 541-1757 (717) 762-3285 F~ UIT) N. 6~S~t 301 G SUeet ~b~, ~A 17101 ~]~a, PA 17013 ~17) 23~592~ (717) F~ (717) 234-9459 F~ (717) -9- ~0,5721 I~. 17 2000 I1:12A~1 VA!' 'J. UBR£N & ASSOC, 8564821i~99 ;-'- Commun~ Action Co~ o~the C~pi~ Re§ion ^d~ Co~ Hou~J~ 1514 De~ S~ 139-143 ~:b~g, PA 17104 ~e~b~, PA 17325 (717) 232-9757 (71~ 33~1518 F~ (717) 234-~227 F~ ~17) 33~8~26 DAUPHIN CO~ 20~0 L~o~ ~d 2107 ~, H~b~ PA 17102 H~b~, PA 1710I (717) ~41-1757 ~17) C~un~ Aeaoa of~e C~i~ 1514 D~ H~b~g PA iT1M (717) ~2-~757 F~ (717) 23~2227 D..._ELAW A ?.E Acorn Hou~ing Corporation Northwest Co~clln~ ~ No~ Broad S~eet 5001 No~ B~d Philaddp~ PA 19130 Pbfladelp~ PA 19141 (21~) 765-1221 (215) ~2~7500 F~ (215) 765-1427 F~ (21~} CCC$ ofD~la~ Vall~ 1515 M~I S~t-Sui~e 1325 167 W, AIIe~ Ave., 2nd Hoer Phihdelp~a, PA 19107 Phfladelphi~ PA 19140 (215) 563-56~5 (215) 426-8025 F~ (215) ~64-2666 F~ (21~) 426~122 3~ S. ]~ou S~eet P.O. B~ 244 M~i~ PA ~0~3 Ke~Squ~ PA 1934~ (610) 565~846 (610) ~3682 F~ (610) 5654567 FA~ (610) 4~8243 Phi{ariSta Co. all Fur Co~i~ Adv Co~uniW Devil Co~ of F~ord S~te 600 ~20 ~om Phil~eip~ PA 1910~ PhUa~lp~ PA 19124 F~ (21~) 963-9~41 F~ (21~) 744-2012 ~c~ Red Cross of ~¢:~r C~S of Delaw~e Valley 172~ Edmont Argue 280 No~ P~vidence Ro~ Chest~, PA 19013 M~ PA 19063 (610) 874-I484 (215) 563-5fi65 -10- RUG-09-2000 12:48 856 482 1199 95Z P,I? VERIFICATION 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. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES SHERIFF'S RETURN - REGULAR CASE NO: 2001-01498 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VNB MORTGAGE SERVICES INC VS WEIGLE DEE A ET AL GEP~ALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WEIGLE DEE A the DEFENDANT , at 0019:10 HOURS, on the 21st day of March , 2001 at 160 JUMPER ROAD NEWBURG, PA 17240 by handing to DEE ANN WEIGLE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Service 13.02 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41,02 03/22/2001 Sworn and Subscribed to before me this 2¢~ day of Deputy S~riff ~i _g~o f A.D. Fothonot ary SHERIFF'S RETURN - REGULAR CASE NO: 2001-01498 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VNB MORTGAGE SERVICES INC VS WEIGLE DEE A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WEIGLE DEE ANN the DEFENDANT , at 0019:10 HOURS, on the 21st day of March , 2001 at 160 JUMPER ROAD NEWBURG, PA 17241 by handing to DEE ANN WEIGLE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 03/22/2001 MARK J. UDREN & ASSOC. Sworn and Subscribed to before Byi~ ~7~ me this 2~ ~ day of - Deputy S~riff ~ ~/ A.D. honotary ' MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 . Cumberland County Plaintiff i MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) : PRAECIPE TO ISSIIE A NEW WRIT OF EXECUTIO~ TO THE SHERIFF: Issue A New Writ of Execution in the above matter: Amount due Interest From June 7, 2001 ~255.52 to Date of Sale September 3, 2003 per diem @$10.08 (Costs to be added) $ MARK J. UDREN & ASSOCIATES WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-1498 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due VHB MORTGAGE SERVICES, INC., Plaintiff (s) From DEE A. WEIGLE, DEE ANN WEIGLE, 160 JUMPER ROAD, NEWBURG, PA 17240 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $41,841.37 L.L. Interest FROM 6/7/01 TO DATE OF SALE 9/3/03 PER DIEM ~ $10.08 - $8,255.52 Atty's Corem % Due Prothy $1.00 Atty Paid $928.59 Other Costs Plaintiff Paid Date: .ILrNE 3, 2003 CURTIS R. LONG Prothonota~ Deputy REQUESTING PARTY: Name MARK .lt. UDREN, ESQUIRE Address: MARK J. UDREN & ASSOCIATES 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 IN RE: Dee A. Thompson CHAPTER 13 CASE NO. 01-04782 11 U.S.C. SEC. 362 VNB Mortgage Service, Inc. ...... ', ~.'. -,~.~.~"~.M ' la, M, ¥8. Dee A. Thompson " Debtor(s) Charles J. DeHart, III, Esquire ~...~.~. :~ Trustee RESPONDENTS ORDER MODIFYING SECTION 362 AIJTOMATIC STAY ~ Now, this / ~ day of )~ ~ ,20 ~, upon Motion.of Movant above, it is ORDERED AND DECREED TItAT: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform'Act of I [}79, as mended {The Code), 11 U.S.C. 3~2, is modified with respect to premises: 45 W. Baltimore Street Carlisle, PA 17013 as to allow the Movant to foreclose on it~ mortgage and allow the purchaser of said premises at Sheriff's Sale (or purchasers ~$ignee) to take any legal action for :enforcement of i~ fight to possession of said premises; and it is further ORDERED TttAT: The relief granted by this order shall survive the convemion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. l~/MARY D. FPU~NgE Bankruptcy MARK J. UDREN & ASSOCIATES ATTOP/~EY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road ! CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff · MORTGAGE FORECLOSURE v. Dee A. Weigle : Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 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: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES MARK. J. UDREN & ASSOCIATES ATTOP-NEY FOR PLAINTIFF P~: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VATB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road ! CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff -MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle ~ NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) : AFFIDAVIT PURSUANT TO RULE 3129.1 VNB Mortgage Services, Inc., 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: 45 West Baltimore Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Dee A. Weigle 160 Jumper Road, Newburg, PA 17240 Dee Ann Weigle 160 Jumper Road, Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: Name Address Same as No. 1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. American General Finance 6 South Hanover Street, Carlisle, PA 17013 Incorporated Wells Fargo Home Mortgage 5024 Parkway Plaza Blvd., Charlotte, NC 28217 Inc. 5. N~me 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 Department 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Steret, 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 45 West Baltimore Street, Carlisle, PA 17013 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: May 29, 2003~ark J.~ '~ /~Udren, ESQ. Attorney for Plaintiff M~RK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) NOTICE OF SHERIFF'S SAL~_0 TO: Dee A. Weigle 160 Jumper Road Newburg, PA 17240 Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 3, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $41,841.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~F OW]~EP~SS RI~HTS IQU MAY BE ARLE TO PREVENT THIS SHW. RIFF'S SAI.E To prevent this Sheriff's Sale, you must take im/,-diate ac~ 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-690~ 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. ) Y~O/J MAY STILLu BE ARLR TO SAVE YOI~_PROP~E~&T][~A~D_ YOU HAVE OTHER R~ TJ~E_ SHERIFF ' S S~T.E DOES TAKE PT,~CF.~ 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 amou/%t 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 C/tNNOT AFFORD ONE. ~o TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013~3387 717-249-3186 or 800-990-9108 MA~K J. UDREN &ASSOCIATES ATTORNEY FOR pLk~NTIFF BY: Mark J. Uclren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER/~Y HILL, N~ 0803~ 856-482-6900 %%1B Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road : CIVIL DIVISION Wayne, NJ 07470 :Cumberland County Plaintiff - MORTGAGZ FOR~CLOSI3RE v. i Dee A. Weigle Dee Ann Weigle ~ NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 : Defendant(s) : NOTICE OF SHRRIFF,S SAT,~ OF R~T, PROPERTy TO: Dee Ann Weigle 160 Jumper Road Newburg, PA 1724~ Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17013 scheduled to be sold at the Sheriff,s Sale on September 3, 200~, at 10:00 A~ in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, enforce the court judgment of $41,841.37, obtained by Plaintiff above (th mortgagee) against you. If the sale is postponed, the property will b relisted for the Next Available Sale. NOTICE OF OWI~E~,~ Y~OUMAY BE ARLE ~O P~V~.NT T~IB SHF. RIFF,S To prevent this Sheriff,s Sale, you must take i~-~4&te 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charg~ costs and reasonable attorney,s fees. TO find out how much you must pay, you may cal 2. You may be able to stop the sale by filing a petition asking the Court to strike open the Judgment, if the judgment was improperly entered. You may also ask the Co to postpone the sale for ~ood cause. 3. You may also be able to stop the sale through other legal ~roceedings. You may need an attorney to assert your rights. The sooner you contact one, the chance you will have of stoppin~ the sale. (See notice on pa~e two on how to ob' an attorney.) YOU MAY STILT, BE ~L~ TO SAVE YOUR PROPERTY AND YOU HAVE OT~.R P?GHTS ~ IF TI~ S~R~TFF,S S~T.R DOES TAKR PLACE. 1. If the Sheriff's Sale is not stopped, y~ur proper~y 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 PAPE~ TO YOD~ LAW%~E~t AT ONCE. IF YOU DO NOT HAVE A I~%W~EI~ OR CANNOT AFFOF. D ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FI1ND OUT WHERE YOU CAN~ET LEC. AL HELP. LAWYE~REFEP~.~L SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~ J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 . Cumberland County Plaintiff i MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) : PRAECIPE FOR JUDGMENT FOR FAILUR~ TO 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 $40,618.09 Interest 846.72 From 3/15/01 to 6/06/01 Late charges per Complaint 114.24 From 3/15/01 to 6/06/01 Escrow payment per Complaint From 4/01/01 to 6/06/01 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. i UDREN & ASSOCIATES DAMAGES ARE HEREBY ASSESSED AS IND TED, PRO PROTHY MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. COURT OF COMMON PLEAS 1460 Valley Road CIVIL DIVISION Wayne, NJ 07470 Cumberland County Plaintiff Dee A. Weigle Dee Ann Weigle NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) DATED: Agril 24, 2001 TO: Dee Ann Weigle 160 Jumper Road Newburg, PA 17240 CE 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 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 Plaza 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 ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PP, ACTICES ACT, THIS LAW FIRM IS DE~D TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DHBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. F~%RK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 R~-4R2-~900 VNB Mortgage Se~rvices, Inc. COURT OF COMMON PLEAS 1460 Valley Roaa CIVIL DIVISION Wayne, NJ 07470 Cumberland County Plaintiff v. Dee A. Weigl9 Dee Ann Welqle NO. 01-1498 Civil Term 160. Jumper Road NewDurg, PA 17240 Defendant(s) DATED: April 24, 2001 TO: Dee A. Weigle . 160~ Jumper Roaa NewDurg, PA 17240 IMPOR~ YOU D~RE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPFJLRANCE 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 Countv Bar Association 2 Liber%y Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTLF3LCACIQN~IHRO~TAN~E 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 PEP/DER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENEABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PAR3~ AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRN 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. MARK J. UDREN & ASSOCIATES ATTOR/~-EY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 .Cumberland County Plaintiff . MORTGAGE FORECLOSURE v. Dee A. Weigle : Dee Ann Weigle ' NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) : AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY : : SS COUNTY OF CAMDEN : THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Dee A. Weigle Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Dee Ann Weigle Age: Over 18 ~ ^ Residence: As captioned above Employment: Unknown Name: Mar~ J. Udren, Esquire Title: Attorney for Plaintiff Sworn to and subscribed Company: Mark J. Udren & Associates before me this 6th day O~ June, 2001. ~, No}~ry Public o! New Jersey My Commlssio~ E[plres 4/7/2003 MARK J. UDREN & ASSOCIATES ATTOR/~-EY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road : CIVIL DIVISION Wayne, NJ 07470 . Cumberland County Plaintiff ! MORTGAGE FORECLOSURE Dee A. Weigle Dee A~nn Weigle ! NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) TO: Dee Ann Weigle 160 Jumper Road Newburg, PA 17240 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 ATTOR/~EY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 . Cumberland County Plaintiff i MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) : PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest @6% From June ~ 2001 to Date of Sale f~ap~emb~r_5, _2001 Per diem @$10.08 (Costs to be added) $ MARK~REN & ASSOCIATES AM~okp~J~yUt~n~ iS Q~iI FREF M3~RK J. UDREN & ASSOCIATES ATTOR/~EY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP, RY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff -MORTGAGE FORECLOSURE Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 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: An FHA insured mortgage Non-owner occupied Vacant X ) Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MAR~REN & ASSOCIATES Mark J. ~dren, ESQUIRE ATTORNEY; FOR PLAINTIFF MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle ! NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 VNB Mortgage Services, Inc., 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: 45 West Baltimore Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Dee A. Weigle 160 Jumper Road, Newburg, PA 17240 Dee Ann Weigle 160 Jumper Road, Newburg, PA 17240 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 Wells Fargo Home Address Being Searched Mortgage, Inc. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. American General Finance 6 South Hanover Street, Carlisle, PA 17013 Incorporated 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 Department 13 N. Hanover Steret, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Steret, 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 45 West Baltimore Street, Carlisle, PA 17013 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: June 6, 2001 Mar~ J/. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) NOT~CE~O~HERIFF~F ~ PR~ TO: Dee A. Weigle 160 Jumper Road Newburg, PA 17240 Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17013 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, PA, to enforce the court judgment of $41,841.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTI~0F O~ YOU , TO prevent this Sheriff's Sale, you must take i~mneCl~e ac~ 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: 185~) 4-82~6~900. 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.) ][O_I/~MAX~_TILL~BF~_ABLE TO SAVE YO/~K PROJ~R~Y AND 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 OH CANNOT AFFOI~D ONE, C.O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHER~ YOU CAN GET LEGAL HELP. LAWYER HHFERI~AL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800~990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: M~rk J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff v. Dee A. Weigle Dee Ann Weigle ! NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) 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, then proof of compliance with said Order is attached hereto as Exhibit "B". Ail Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalt'~ 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~~ Dated: August 17, 2001 I MARK & ASSOCIATES BY: Mark J. Ud eh, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTOP. NE¥ FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 VNB Mortgage Services, Inc., 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: 45 West Baltimore Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Dee A. Weigle 160 Jumper Road, Newburg, PA 17240 Dee Ann Weigle 160 Jumper Road, Newburg, PA 17240 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 Wells Fargo Home 5024 PARKWAY PLAZA BLVD., CHARLOTTE, NC Mortgage, Inc. 28217 4. Name and address of the last recorded holder of every mortgage of reco~d: Name Address Plaintiff herein. See Caption above. American General Finance 6 South Hanover Street, Carlisle, PA 17013 Incorporated 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 Department 13 N. Hanover Steret, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Steret, 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 45 West Baltimore Street, Carlisle, PA 17013 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 ~made subject to the penalties of 18 Pa.C.S. sec. 4904 relatin~ to uns~rn~al~s/~f~ication to authorities. MARK J~UDR~N & ASSOCIATES DATED: AUGUST 14, 2001/ ! .. ! Mamk J. bdren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTOR/FEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. COURT OF COMMON PLEAS 1460 Valley Road CIVIL DIVISION Wayne, NJ 07470 Cumberland County Plaintiff v. NO. 01-1498 Civil Term Dee A. Weigle Dee Ann Weigle 160 Jumper Road Newburg, PA 17240 Defendant(s) DATE: June 22, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF ~AT, PROPERTY OWNER(S): Dee A. Weigle Dee Ann Weigle PROPERTY: 45 West Baltimore Street Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the C~mberland_ County Sheriff's Sale on September 5. 2001, 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. XHIBIT A VNB Mortgage Services, Inc. In The Court of Common Pleas of VS Cumberland County, Pennsylvania Dee A. Weigle Writ No. 2001-1498 Civil Term Dee Ann Weigle R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.66 Mileage 14.95 Levy 15.00 Advertising 15.00 Certified Mail 1.75 Poundage 15.43 Postpone Sale 20.00 Law Journal 330.50 Patriot News 272.28 $787.07 paid by attorney Sworn and subscribed to before me So Answers: This 7~ day of ~ ~'~~ R. Thomas Kline, Sherit'f 2OOl, A.D.Q BY Pro~onot~ Re~ Estate Deputy MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VATB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. i Dee A. Weigle Dee Ann Weigle ! NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) ~ AFFIDAVIT PURSUANT TO RULE 3129.1 ~ Mortgage Services, Inc., 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: 45 West Baltimore Street Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Dee A. Weigle 160 Jumper Road, Newburg, PA 17240 Dee Ann Weigle 160 Jumper Road, Newburg, PA 17240 2. Name and address of ~efendant(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 Wells Fargo Home Address Being Searched Mortgage, Inc. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. American General Finance 6 South Hanover Street, Carlisle, PA 17013 Incorporated 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 Department 13 N. Hanover Steret, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Steret, 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 45 West Baltimore Street, Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and beIief. 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: June 6, 2001 MarA J./ Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTOR/~EY FOR PLAINTIFF BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road ! CIVIL DIVISION Wayne, NJ 07470 :Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) NOTICE OF SHERIFF'S SA?.~ OF pRaT. PROPERTY TO: Dee Ann Weigle 160 Jumper Road Newburg, PA 17240 Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17013 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, PA, to enforce the court judgment of $41,841.37, 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~RICq~T~ XOU MAY BE ABLE TO PREVENT THIS SHRRIFF'S SAT,E To prevent this Sheriff's Sale, you must take imm~.~/~e_ac~:/~k[ 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: 1856)-482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. YOU may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY S~.E~ABLE~TO~VE~0_UR PROPJ~RTY AND YOU~BAVE_O~IGHTS E~I~HE SHERIFF' S SA?.E DOES TAKE~PJ~AC~ 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 AFFOP, D ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERI~AL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN THE THIRD WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, THE FOLLOWING TWO TRACTS OF LAND: TRACT NO. 1: BEGINNING IN BALTIMORE STREET AT A POINT ON CORNER OF LANDS NOW OR FORMERLY OF MRS. L.R. BRENNEMAN; THENCE IN A NORTHERN DIRECTION ALONG LINE OF LANDS OF SAME, 102 FEET, MORE OR LESS, TO LINE OF LANDS NO OR FORMERLY OF SHAPLEY HEIRS; THENCE ALONG LINE OF LANDS OF SAME IN A WESTERN DIRECTION, 30 FEET, MORE OR LESS, TO LINE OF LANDS FORMERLY OF HARRY G. BEETEMAND NOW PROPERTY KNOWN AS 47 WEST BALTIMORE STREET, NOW OR FORMERLY OF MRS.. MELANIE D. COOPER; THENCE ALONG LINE OF LANDS OF SAME IN A SOUTHERN DIRECTION, 103 FEET, MORE OR LESS, 103 FEET, MORE OR LESS, TO BALTIMORE STREET; THENCE ALONG BALTIMORE STREET IN AN EASTERN DIRECTION 29 FEET 06 INCHES, MORE OR LESS, TO THE PLACE OF BEGINNING. CONTAINING ON BALTIMORE STREET 29 FEET 06 INCHES, MORE OR LESS, AND RUNNING NORTHWARDLY AT AN EVEN WIDTH OF 30 FEET, MORE OR LESS, 102 FEET, MORE OR LESS, AND KNOWN AS 45 WEST BALTIMORE STREET. TRACT NO. 2: BOUNDED ON THE NORTH BY PROPERTY NOW OR FORMERLY OF THE SHAPLEY HEIRS, ON THE EAST BY TR3tCT NO. 1, ABOVE; ON THE SOUTH AND WEST BY PROPERTY JOHlq H. HIGHLANDS, ET AL., NOW OR FORMERLY OF CARLISLE OPPORTUNITY HOMES; HAVING A DISTANCE OF 16 FEET, MORE OR LESS, ON THE NORTH AND SOUTH BOUlqDARY LINES AND A DISTANCE OF 51 FEET, MORE OR LESS, ON THE EAST AND WEST BOUNDARY LINES, SAID TRACT LYING AND BEING IMMEDIATELY NORTH OF THE PROPERTY KNOWN AS 47 WEST BALTIMORE AVENUE. BEING KNOWN AS 45 WEST BALTIMORE STREET, CARLISLE, PA TAX ID NO. 0421-0320-617 TITLE TO SAID PREMISES IS VESTED IN DEE ANN WEIGLE BY DEED FROM BETTY F. NELSON DATED 6/13/1989 AND RECORDED 6/13/1989 IN DEED BOOK BKZ-33 PAGE 782. MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 : Cumberland County Plaintiff - MORTGAGE FORECLOSURE v. Dee A. Weigle Dee Ann Weigle !NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) NOTICE OF SHERIFF'S SAT,E OF pRkL PROPERTY TO: Dee A. Weigle 160 Jumper Road Newburg, PA 17240 Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17013 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, PA, to enforce the court judgment of $41,841.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER' S RIGHTS ~OU MAY BF, ARLE TO PREV~.NT THIS SHW. RIFF' S SAT.R To prevent this Sheriff's Sale, you must take ~mm-diate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 482-~900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) YOU MAY S~.JSL BE ARLE TO SA~E YOUR RRQPERT¥ AND YOU ~ OT~ER RIGHTS EVEN IF THE-SHERIFF'S SAT.E DOF~ TAKE P?.ACEL 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAxNNOTAFFOP~ ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHEP~ YOU CA~ GET LEGAL HELP. LAWYER REFERR~tL SERVICE cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN THE THIRD WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, THE FOLLOWING TWO TRACTS OF LAND: TRACT NO. 1: BEGINNING IN BALTIMORE STREET AT A POINT ON CORNER OF LANDS NOW OR FORMERLY OF MRS. L.R. BRENNEMA/q; THENCE IN A NORTHERN DIRECTION ALONG LINE OF LANDS OF SAME, 102 FEET, MORE OR LESS, TO LINE OF LANDS NO OR FORMERLY OF SHAPLEY HEIRS; THENCE ALONG LINE OF LANDS OF SAME IN A WESTERN DIRECTION, 30 FEET, MORE OR LESS, TO LINE OF LANDS FORMERLY OF HARRY G. BEETEM AND NOW PROPERTY KNOWN AS 47 WEST BALTIMORE STREET, NOW OR FORMERLY OF MRS.. MELANIE D. COOPER; THENCE ALONG LINE OF LANDS OF SAME IN A SOUTHERN DIRECTION, 103 FEET, MORE OR LESS, 103 FEET, MORE OR LESS, TO BALTIMORE STREET; THENCE ALONG BALTIMORE STREET IN AN EASTERN DIRECTION 29 FEET 06 INCHES, MORE OR LESS, TO THE PLACE OF BEGINNING. CONTAINING ON BALTIMORE STREET 29 FEET 06 INCHES, MORE OR LESS, AND RUNNING NORTHWARDLY AT AN EVEN WIDTH OF 30 FEET, MORE OR LESS, 102 FEET, MORE OR LESS, AND KNOWN AS 45 WEST BALTIMORE STREET. TRACT NO. 2: BOUNDED ON THE NORTH BY PROPERTY NOW OR FORMERLY OF THE SHAPLEY HEIRS, ON THE EAST BY TRACT NO. 1, ABOVE; ON THE SOUTH AND WEST BY PROPERTY JOHN H. HIGHLANDS, ET AL., NOW OR FORMERLY OF CARLISLE OPPORTUNITY HOMES; HAVING A DISTANCE OF 16 FEET, MORE OR LESS, ON THE NORTH AND SOUTH BOUNDARY LINES AND A DISTANCE OF 51 FEET, MORE OR LESS, ON THE EAST AND WEST BOUNDARY LINES, SAID TRACT LYING AND BEING IMMEDIATELY NORTH OF THE PROPERTY ENOW-N AS 47 WEST BALTIMORE AVENUE. BEING KNOWN AS 45 WEST BALTIMORE STREET, CARLISLE, PA TAX ID NO. 0421-0320-617 TITLE TO SAID PREMISES IS VESTED IN DEE ANN WEIGLE BY DEED FROM BETTY F. NELSON DATED 6/13/1989 AND RECORDED 6/13/1989 IN DEED BOOK BKZ-33 PAGE 782. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALIH OF PENNSYLVANIA) NO. 01-1498 CIVIL ~ TER~ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due VNB MORTGAGE SERVICE, INC. ; 1460 Valley Road, Wayne, PA 07470 PLAINTIFF(S) fromDER. A. WETGT.V.; DEE A~ WEIGLE; 106 JumDer Road; Newburq, PA 17240 DEFENDANI(S) (1) You are directed to levy upon the property of the defendant(s) and to sell SEE A~ACHED 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/arc enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or othenNise disposing thereof; (3) If property olthe 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/he r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due 41,841.37 L.L. .50¢ Interest @6% From June 7, 2001 to Interest date of ~,-~1¢, S~L~,ber 5, 2001, ~ d_~a'n LaS10.0~Due Prothy $1.00 Atty's Corem % Other Costs Arty Paid 329.02 Plaintiff Paid Date: ~ 13, 2001 ~ R. [cr,::3, ~ Prolhon~otar¥, Civil Division REQUESTING PARTY: Name Me~k J. LL~, Ebqd~e Address: 1040 N. ~ HIGq~Y, S[/ri~ 500 Attorney for: p'i~'irfl-i eF Telephone: (856) 482-6900 Supreme Court ID No. 043~ REAL ESTATE SALE No. Oum~fland County, ~ ,~,. ,,¢ numbered as: ¢¢ ~. ~ 4¢/~¢~¢ ~- ~r~ and more ~ :ribed on ~hJbit "A" filed witf this writ and by this referem:, qnnmorated herein ,/ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : · ' SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Joumai, 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. REAL E~TATE 8ALE NO. 40 er M./Morgenthal, Editor Writ No. 20014498 Civil Rog . VNB Mortgage Service, Inc. vs. SWORN TO AND SUBSCRIBED before me this Dee A. Welgle: Dee Ann Weigle 3 .day of AUGUST, 2001 Atty.: Mark d. Udren c RT N house and 1of of ground situate ha the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, ,; ~~taty bounded and described as follows. the following two tracts of land: tm~e Street at a point on ~o~ner or lands nov/ or formerly of Mrs. L.R. Brenneman; thence in a northern direction along line of lands of same, 102 feet. more or less, to lhae of lands now or formerly of Shapley heirs: thence alon~[ line of lands of same THE PATRIOT NEWS THE SUNDAY 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-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 ware 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 24th 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 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 M~cellaneous Book "M", Volume 14, Page 317. / PUBLICATION .................................. .L_/. .~.~.. ................................................. ~ ' COPY sworn te amd st~,~(.,;b,~d b~,E,,~Ci'~'~lls 21st d~of A~t 2001 A.D. S A L E ~40 / Terw L. n~, ~ P~ [ //~ ~ / ~ ~ ~ : / MyCo~t~E~r~Ju~ I N~TARY PUBLIC My commission expires June 6, 2~2 -- ~ CUMBERED COU~ SHERI~S ~F~E ~' ~ CARLISLE, PA. 17013 A~ ~AT ~ ~ ~ ~ Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. ~ For publishing the notice or publication attached hereto on the above stated dates $ 270.78 i~a, Probating same Nota~ Fee(s) $ 1.50 ~' ~ Total $ 272.28 ~.ew ~blisher's Receipt for Advertising Cost Fol~en. ~; ,~a'ew. ~ 47 W,~a .l~a~ ;blisher $[ree~owm-feern~y:e~.~.D; r of The Patriot-News and The Sunday Patriot-News, newspapers of general c r Coel~r;, ~'he~-..e along lir, e(x'l~same ce pt of the aforesaid notice and publication costs and certifies that the same have been duly pa~o~ a-.~ MARK J. UDREN & ASSOCIATES ATTOP-NEY FOR PLAINTIFF BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. COURT OF COMMON PLEAS 1460 Valley Road CIVIL DIVISION Wayne, NJ 07470 Cumberland County Plaintiff v. NO. 01-1498 Civil Term Dee A. Weigle Dee Ann Weigle 160 Jumper Road Newburg, PA 17240 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Dee A. Thompson has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 4, 2001, Bankruptcy Case No. 01-04782. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff MA~K J. UDREN & ASSOCIATES ATTOPdgEY FOR PLAINTIFF BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 . Cumberland County Plaintiff v. Dee A. Weigle Dee Ann Weigle ! NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) 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, yen pr~f of compliance with said Order is attached hereto as Exhibit "B"./ // / / ! All Notices were served within the ti~e kim~tW set forth by Pa Rule C.P. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: July 24, 2003 MAR~ B~f Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 VNB Mortgage Services, Inc. COURT OF COMMON PLEAS 1460 Valley Road CIVIL DIVISION Wayne, NJ 07470 Cumberland County Plaintiff v. NO. 01-1498 Civil Term Dee A. Weigle Dee Ann Weigle 160 Jumper Road l Newburg, PA 17240 Defendant(s) DATE: June 23, 2003 TO: ALL PARTIES IN INTEP. EST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF ~R%?. PROPERTY OWNER(S): Dee A. Weigle a/k/a Dee Ann Weigle PROPERTY: 45 West Baltimore Street Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~ County Sheriff's Sale on ~ptem~er 3. 200~, at 10:00 AM, in the Commisioners Hearing Room, 2nd floor, Courthouse, Carllsle, 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. VNB Mortgage Services, Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Dee A. Weigle, Dee Ann Weigle Writ No. 2001-1498 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 16, 2003 at 7:00 o'clocl~ PM, 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: Dee A. Weigle, Dee Ann Weigle, by making known unto Dee Thompson (formerly Weigle), personally, at 160 Jumper Road, Newburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2003 at 2:37 o'clock P.M., he posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dee A. Weigle, Dee Ann Weigle located at 45 West Baltimore St., Carlisle, 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 Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Dee A. Weigle, Dee Ann Weigle, by regular mail to her last known-address of 160 Jumper Road, Newburg, PA 17240. This letter was mailed under the date of July 07, 2003 and never returned to the Sheriff's Office. Sworn and sUbscribed to before me So Ans~wer~, ~ ~ This__ day of ~R~. oTh~mas~l~n~? 2003, ^.D. Prothonotary Real Estate Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Zieeler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Home Loan Mtg Corp is the grantee the same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ Execution issued on the 3rd day of June, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 1498, at the suit ofVNB Mtg Serv Inc against Dee A Weigle aka Dee Ann is duly recorded in Sheriff's Deed Book No. 259, Page 3335. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 3/ud~ day of ~ , A.D. 2003 '/'!qod~ ~. ~ ~'~orderofDeeds VNB Mortgage Services, Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Dee A. Weigle, Dee Ann Weigle Writ No. 2001-1498 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 16, 2003 at 7:00 o'clock PM, 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: Dee A. Weigle, Dee Ann Weigle, by making known unto Dee Thompson (formerly Weigle), personally, at 160 Jumper Road, Newburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2003 at 2:37 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dee A. Weigle, Dee Ann Weigle located at 45 West Baltimore St., Carlisle, 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 Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Dee A. Weigle, Dee Ann Weigle, by regular mail to her last known address of 160 Jumper Road, Newburg, PA 17240. This letter was mailed under the date of July 07, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for Federal Home Loan Mortgage Corporation. It being the highest bid and best price received for the same, Federal Home Loan Mortgage Corporation of 8200 Jones Branch Drive, McLean, VA 22102, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $954.69. Sheriff's Costs: Docketing $30.00 Poundage 18.72 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 15.87 Levy 30.00 Surcharge 30.00 Law Journal 335.15 Patriot News 300.55 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $ 954.69 Sworn and subscribed to before me So Answers: ,)~ dayof ~-o~ .~-~, R. Thomas Kline, Sheri~'f 2003, A.D. (~.~f: '~:Z~., '~"<" d~ t~rdthonotary BY Real Estate ~)eputy MARK J. UDP~EN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 0%302 1040 N. KINGS HIGHWAY, SUITE 500 CHE~RY HILL, NJ 08034 856-%82-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road ! CIVIL DIVISION Wayne, NJ 07470 :Cumberland County Plaintiff -MORTGAGE FORECLOSURE v. i Dee A. Weigle : Dee Ann Weigle ~ NO. 01-1498 Civil Term 160 Jumper Road : Newburg, PA 17240 Defendant(s) : AFFIDAVIT PURSUANT TO RULE 3129.1 VNB Mortgage Services, Inc., 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: 45 West Baltimore Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Dee A. Weigle 160 Jumper Road, Newburg, PA 17240 Dee Ann Weigle 160 Jumper Road, Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: Name Address Same as No. 1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. American General Finance 6 South Hanover Street, Carlisle, PA 17013 Incorporated Wells Fargo Home Mortgage 5024 Parkway Plaza Blvd., Charlotte, NC 28217 Inc. 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 Department 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Steret, 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 45 West Baltimore Street, Carlisle, PA 17013 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: May 29, 2003 ~/~Udren,ark J.~ ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTOP~NEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUiTE 500 CHERRY HILL, NJ 0803~ 856-482-6900 VNB Mortgage Services, Inc. : COURT OF COMMON PLEAS 1460 Valley Road i CIVIL DIVISION Wayne, NJ 07470 :Cumberland County Plaintiff ~ MORTGAGE FORECLOSURE : v. Dee A. Weigle Dee Ann Weigle i NO. 01-1498 Civil Term 160 Jumper Road Newburg, PA 17240 Defendant(s) NOTICE OF S~RRTFF'S S~?.R OF pRa?. PROPERTY TO: Dee A. Weigle 160 Jumper Road Newburg, PA 17240 Your house (real estate) at 45 West Baltimore Street, Carlisle, PA 17O13 is scheduled to be sold at the Sheriff's Sale on September 3, 2003, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $41,841.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTIC~ OF OWNER'S RTGHTS YOU MAY BE ARL~ TO PI~W. lr~NT T~IS SH~.RIFF'S S~?.~. TO prevent this Sheriff's Sale, you must t~ke ~-z~-~ate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. TO find out how much you must pay, you may call: (866) 482-6900. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) YOU MAY STILL BE ~LE TO SAVE YOUR PROPERTY AN~ YOU ~VE OTH~ RIGHTS EVeN IF T~R S~TFF'S S~?,E DOES TAK~ P~.ACE. 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 he 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 T/%KE THiS pAP~ TO YOUR LAW~R AT ONCe. IF YOU DO NOT ~AVE A LAWYER OR CANNOT AFFORD ONe, ~0 TO OR TKLEPHONE T~ OFFICE LISTED BELOW TO FIND OUT WHEP~ YOU CAN ~ET LEGAL LAWYER P..EFEP..P, AL SERVICE Cumberland County Bar Association 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Associatio~ 2 Liberty Plaza Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN house and lot. o£ ground s~tust'e in the Third Ward of the Borough of ~rllsle, ~erlan~ Pennsylvania, Bounded and descried as foll~s, ~e fo11~ing two tracts o~ 1~ T~ NO. 1: ~G~ING o~ ~lt~re Stre~ at a ~nt on corner of l~ds now or [o~erl~ o~ ~s. L.R. Br~n~ ~ce ~n a northern dire=t~on alo=.g l~ne o~ lands o~ s~e, 102 fee~, ~re or- less, ~ l~ne of lands n~ or fo~rly ~ Shapley ~e.irs~ ~h~e along l~ne of · l~s of same ~n a wes~er~ d~re~lon, 30 fee=, ~re or less, ~o l~ne of lands ~o~erl~' oE Har~ G. Bee~em and n~ proper=y. ~ as 4~ Wes= ~lt~re S2reet,. n~ or ~o~erly o~ '~s. Melange DZ Coop~ thence along l~ne. of l~ds-of s~e. ~n ~- souther~ d~rection, 103 fee=, ~re or less, to ~l~re Stre~t~ th~ce along line of Balt~re Stree= ~n ~ easter-direction 29 lee= 0S %nches, ~re or less, ~o the Place oE B~IHNlH=. CO~AIN~G un hl=~ore Street 29 feet 06 ~nches, less, and ~ng nort~ardly ~= an even w~dth of 30 fee=, ~re ~r less, 102 fee=, ~re or less, and kn~.as 45 Wes= ~l~re Street.. ~ NO. 2~ BONDED on 2he north by property n~ or fo~erly o~ ~he Shapley He~rs~ on the' east ~ Trac= on ~e south and west by property fo~erly of Jo~ H. · Highlands, eU al., n~ or fo~erly of Carlisle Homesl having a d~s~ance of 16 feet~ ~re or less; on north and south bounda~ l~nes and a ~is~ance of ~re or less, on the ~s~ and wes~ ~ lying and being '~ed~ately nor~ o~ ~e .prope~y kn~ as 47 West h~re Avenue. -BEING the s~ praises, which ~et~y P. N~lson, '~an2ed.and conve~d to ~e A,. ~igle, Single W~, Bo~r herein. BEING ~0~ ~ 45 ~ST B~TIMO~ S~ET, ~ISLE, PA 17013 PROPER~ ID NO. 04-21-0220-617 TI~E TO SAID P~ISES IS ~ST~ IN DEE ~ ~IGLE, BY DE~ ~OM BE'i-fl F. ~LSON, SINGLE WO~, DAT~ 6/13/89, ~ 6/12/89, IN DE~ BOOK 33 PAGE 782. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-1498 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due VHB MORTGAGE SERVICES, INC., Plaintiff (s) From DEE A. WEIGLE, DEE ANN WEIGLE, 160 JUMPER ROAD, NEWBURG, PA 17240 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You axe also directed to attach the property of the defendant(s) not levied upon in the possession of GA1LNISHEE(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 anyune 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 $41,841.37 L.L. Interest FROM 6/7/01 TO DATE OF SALE 9/3/03 PER DIEM ~ $10.08 - $8,255.52 Atty's Corem % Due Prothy $1.00 Atty Paid $928.59 Other Costs Plaintiff Paid Date: JUNE 3, 2003 CURTIS R. LONG Prothonotary ~,~ff,,~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: MARK J. UDREN & ASSOCIATES 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale # 44 On June 6, 2003 the sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA known and numbered as 45 West Baltimore St., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 6, 2003 By: , 6d~ ~D'I.L~2~q Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : 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 primed notice or publication attached hereto is exactly the same as was primed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statemem 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. Writ No. 2001 1498 Civil .~-----~ VNB Mortgagers.Services, Inc. / Lisfffarie C~yne, Ediy Dee A. Weigle, Dee Ann weigle Atty.: Mark J. Udren SW ~0~I~O AND SUBSCRIBED before me this ALL THAT CERTAIN house and I day of AUGUST, 2003 lot of ground situate in the Third Ward of the Borough of Carlisle. Cumberland County, Pennsylvania, bounded and described as follows, the following two tracts of land: . . /Iff TRACT NO. 1: BEGINNING on Bal- timore Street at a point on corner of LO~ E. lands now or foralerly of Mrs. L.R. Brennenmn; thence in a northern direction along line of lands of same. My 102 feet. more or less. to line of lands now or formerly of Shapley Heirs: thence along line of lands of same in a western direction. 30 feet, more or less, to line of lands for merly of Harry G. Beetem and now property known as 47 West Balti 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 July and the 5th day(s) of August 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 Sworn to da~bs_cr~bArl hnf m~,,.,tf11~ 13th day of ~u.qus~03 A.D. N~a~a S~ ,/ j / ................... ----'-'- -- My ~ Expires June ~, ~Jo NOT'ARY PUBLIC I~'A~E~'~4Ml~II~'44 Member, l~nnay~vanta'~°~f'c"~O~N°~C~SMy commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE ~· . CUMBERLANDCOUNTYCOURTHOUSE At~: CARLISLE, PA. 17013 ,~to~.~~o~ Statement of Advertising Costs ~ .a~ ~ ~f.~ e~ fo~ To THE PATRIOT-NEWS CO., Dr. ~ ~0, ~: For publishing the notice or publication attached ~ hereto on the above stated dates $ 298.80 ~,~m~. Probating same Notary Fee(s) $ 1.75 Ii, of Total $ 300.55 . ~= 'ublisher's Receipt for Advertising Cost ublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general cir . ~, to , ~ of 'eceipt of the aforesaid notice and publication costs and certifies that the same have