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HomeMy WebLinkAbout10-7240UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A., as ::COURT OF COMMON PLEAS Trustee for ABFC 2002-OPT1 :CIVIL DIVISION C C Trust, ABFC Asset-Backed =Cumberland County -ox 0 .? Certificates, Series 2002-OPT1 Zrn rrn rn- Plaintiff "0 € NO. 10-7240 w off' V. r --to Rodney W. Anderson ?c Sharon S. Anderson y. c? C:? -?t rv ` Defendant(s) c..n PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: December 2, 2010 UDREN LAW OFFICES, P.C. S.? BY: Attorneys for Plaintiff 0"M S. Slodma-, bquire . PA 10 306534 pab lilbp ?, less SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank NA vs. Sharon S. Anderson (et al.) IL1011„1,, of i/, 7. t? ,FILED-QFFIC, , r• ? ? 1 + I f' 3 I 2 9 > Syr i', '`s i A Case Number 2010-7240 SHERIFF'S RETURN OF SERVICE 12/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Rodney W. Anderson, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Sharon S. Anderson, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/13/2010 02:29 PM - York County Return: And now December 13, 2010 at 1429 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rodney W. Anderson by making known unto Sharon S. Anderson, Wife of defendant at 594 Old York Road, Trailer 33, Etters, Pennsylvania 17319 its contents and at the same time handing to her personally the said true and correct copy of the same. 12/22/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sharon S. Anderson, but was unable to locate her in hi; bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Sharon S. Anderson. Request for service at 668 State Street, Lemoyne,) Pennsylvania 17043 i; currently for sale and vacant. The Lemoyne Postmaster has confirmed, Sharon S. Anderson's new address is 594 Old York Road, Trailer 33, Eters, Pennsylvania 17319. 12/22/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he Made a diligent search and inquiry for the within named defendant to wit: Rodney W. Anderson, but was uihable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as',not found as to the defendant Rodney W. Anderson. Request for service at 668 State Street, Lemoyne, Pennsylvania 17043 is currently for sale and vacant. The Lemoyne Postmaster has confirmed, Rodney W. Anderson's new address is 594 Old York Road, Trailer 33, Eters, Pennsylvania 17319. 12/27/2010 02:29 PM - York County Return: And now December 13, 2010 at 1429 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that: I served a true copy of the within t Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sharon S. Anderson by making known unto herself personally, at 594 Old York Road, Trailer 33, Etters, Pennsylvania 17319 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $109.40 SO ANSWERS, .01 December 27, 2010 RON R ANDS SON, SHERIFF _i -ys to 3 ?;: SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber Sheriff Reuben B Zeager Chief Deputy, Operations PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration WELLS FARGO BANK, N.A. Vs. Case Number RODNEY W. ANDERSON (et al.) 10-7240 SHERIFF'S RETURN OF SERVICE 12/13/2010 02:29 PM - DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LA , SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) BY HANDI G A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE SHARON S. ANDERSON, S OUSE, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR RODNEY W.. ANDERSON T 594 OLD YORK ROAD, TRAILER 33, ETTERS, PA 17319. _X a A ? ?\,&\ T01515 TA L, E UTY 12/13/2010 02:29 PM -DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LA , SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) BY "PERSO LLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFE DANT, TO WIT: SHARON S. ANDERSON AT 594 OLD YORK ROAD, TRAILER 33, ETTERS, PA 17319. X . & I ? ?\ L\ O TA L, E SHERIFF COST: $51.00 December 22, 2010 ----------- -------- ------------------------------ Affirmed and subscribed to before me this NOTARY 22nd day of DECEMBER 2010 C T" c. 077 (c)CountySuteSheriff Teleosoft Inc LISRCi TH0717 NCT,'iRY t-21'.201 CITY OF YCRK, YCRi< COMY COMMlISSION EXPIR?SAG UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS Trustee for ABFC 2002-OPT1 :CIVIL DIVISION G ° Trust, ABFC Asset-Backed Cumberland County -0:r - -? Certificates, Series 2002-OPT1 € ern 11 rn r- _ Plaintiff z? v M ;0 C, € NO. 10-7240 co Rodney W. Anderson yr-, :X ?e Sharon S. Anderson x? C) Defendant (s) en -G rn _< PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED : :??- 12 6 111 UDREN LAW OFFICES, P.C. C BY: Attorneys for Plaintiff ChWWM M. Arkema, Esquii M ID•203437 V E R I F I C A T I O N The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: FEB 11 2011 N Joseph Kapffnski Title: AsslsMt Setrettry Company: Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 by American Home Mortgage Servicing, Inc., as attorney in fact Rodney W. Anderson Sharon S. Anderson MJU #10110228-1 (Cumberland County, Pennsylvania) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A., as Trustee for ABFC :COURT OF COMMON PLEAS 2002-OPT1 Trust, ABFC Asset-Backed :CIVIL DIVISION Certificates, Series 2002-OPT1 Cumberland County P.O. Box 961730 Irving, TX 75063 Plaintiff V. f~ 1_0 ?x Rodney W. Anderson Sharon S. Anderson NO. 10-7240 - : ?.•- 594 Old York Road, Trlr 33 tnr -- } , Etters, PA 17319 Defendant(s) 3> h AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129 arc .-1 :z - or; Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 1- 7 -t( UDREN LAW OFFICES, P.C. BY Afto eys for Plaintiff Alan M. Minato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS Trustee for ABFC 2002-OPT1 :CIVIL DIVISION Trust, ABFC Asset-Backed :Cumberland County Certificates, Series 2002-OPT1 € Plaintiff :MORTGAGE FORECLOSURE V. Rodney W. Anderson :NO. 10-7240 Sharon S. Anderson Defendant(s) zco CD'-x c C-) Z O AMENDED AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.1 and 76 Wells Fargo Bank, N.A., as Trustee for Backed Certificates, Series 2002-OPT1, its attorney, Udren Law Offices, P.C., Praecipe for the Writ of Execution was concerning the real property located a 668 State Street, Lemoyne, PA 17043 ABFC 2002-OPT1 Trust, ABFC Asset- Plaintiff in the above action, by sets forth, as of the date the filed, the following information t: 1. Name and address of Owner(s) or reputed Owner(s): Name Address Rodney W. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 Sharon S. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 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 North Star Capital ACQ, LLC 6851 Jericho Turnpike, #190 Syosset, NY 11791 c/o James C. Warmbrodt, Esquire Weltman, Weinberg, & Reis Co., LPA 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 Capital one Bank 6851 Jericho Turnpike, #190 Syosset, NY 11791 c/o James C. Warmbrodt, Esquire Weltman, Weinberg, & Reis Co., LPA 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 Michaels, Louis & Associates PO Box 1062 Moon Township, PA 15108 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank, N.A., as P.O. Box 961730 Trustee for ABFC 2002-OPT1 Irving, TX 75063 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 668 State Street Lemoyne, PA 17043 The statements are true and correct, based upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED : Zt' 7'(( UDREN LAW OFFICES, P.C. BYE-? Attorney fo P1 intiff 41an A. Minato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset- Backed Certificates, Series 2002-OPT1 Plaintiff V. Rodney W. Anderson Sharon S. Anderson Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7240 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Rodney W. Anderson & Sharon S. Anderson PROPERTY: 668 State Street, Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on May 20, 2011, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A O a CD `G D 7 0- (D O 90 U) sy O Cf) C1 CD O_ O N N 00 C cr CD Q (n 0 3 W co V V (D 6 C D) c-o Co A O 3 C N n O !Z c 1 7 W M (D 7 r? - -+ W N O O O v O cn A. W N s r Z ? CJ1 A (D az (n 3 c. CD , 0 6 C (3 CZ> - 7(D CL Cn 0) CDV,O V mm 32 a C LO CD SR; fD N ? N rnn TN 0 0) Z -0 PI) O-i 2-U Ca0 Z o ') * 0D m ? OO OCi : 0) c n aj(D O O in 0 ( A0 = «?CD O O X ? v OCO 3 C 0 0 °L o ?w 30) 9 ? c 30) cnD W o mM ° D 00 m Z x y ? 0 . ° ? m 0 v CCDD d 1 O m Z C NCO D -1 MO M n CD . o z scD ? ? m m m<C7cD < M. n tro O >' (A D 0 ?C? 0 cn W 0 OW ° Z _ Z< 0 C o ° O 2 ? z m O N c O 00 0? D y CD ao O N -0 m >("A m.? - m n -o N-1 y w m N w m 09 c ? (D c m ?W??d cn c. II C7 - - _por ? m 3 =N? 0 o° 0 D B. N)- a.D " y r 0 ??_ (n 3 r? CD 0 -? cn m cos -? ?? co 9-? O 3 Z aO r- m Z O m 00 - ? N m- r r A;O R: D- r > (n "3 Z -u W m O -1 0- M O =r w Oy an WL rnvj mC) (D - o n °7 mD v (a N 19 40 o y CD OC ? Imoc D y (D to w _-3 T (n C D c(n j ° Tm mC) U) y D 1 ro f 1 rm V m ;- N _ w (D 5 n ;D =r 0 W CD O 0 O Ui D D D o °D Z m Z m ? a C C m < m - v CD v CD m Z m ? ? ?? o c n n In Cl) O c?c ° 0 m = m a a N .. ... ' 0 a j ?O ,• 17 1 N O1 3 m F X -'- ° m m r. m CD ID 1 f'. +R f i ? - o ?? o X Sr 1 " - O --3- ?3 6 m POSTAGE om: ? w&OC N7 d ? <9 mm ,gm a .(1C) ??? n3=05 _> > > ' o N? Q _. n "D p m m vi 7 S fD O ? - g?d 0 c av °g0mmm 3mo w m <D ?Oo C ai O N F-°v O m'O OiN m m :tn? Q.G jj "pip C. N Cl) N N .O. - O O N fD wwo?nm' ? C Q m c O 0 m WO Z@c m _ma mm ( ) ? o ? vfD?m?a = 9 3 O y N CD n O (D c .my mommay ? >> 3 a 3 3an _ 0CC C? D) n o O.m ?nN3y^ SJj?ym CD O(n ° 1y cax 1j N 00 01n"mo;im CD n O m gFrRoa0z v00?c? 0) .0 0 v3-m S 4 fD ?&2 O ID n - T ?o CD 0 '? 07?` ON o y.o m 3 • O . 5:0 U) a am %N - ad.? 2 = c m ? " T(n N m co o C = _a mmo o., , , m . C D N a• 53 ar.M. 0=0 m3 mtD? c m os,D 3 fD 2 OW-3 OC 3, u?cim pea CD 0 , 3: N 3 . v =. EX IBI ,Q XH QI- m y p `° 12 -, od mo CD X O a. CD ?C G Q (D CID O 90 cn fl) O U) D a CD (n O O C) N N n C v' (D m Q (n T O 3 W OD v V -n m or C G7 cfl m O 3 C to 0 O CL iT 1O <D W 3 pr O W O tD CO W -l O 0 A W N ? r Z N O U1 A W N O O Oam c CD ?? ? Q ZD cz m ° a gyp (n N (D 3 0 0 CL C N N j Wp ?ry ;7--4 Z3 o m N ?C CD O 0 m CD =? C y ? m O D C)OD o <Z od a m m CDC o < CD y m a Z ;Doz N D1 I CD y x y m (R ?;U? m N° WO m? c ° m m `° m ? v> > -n r ? ? m CD oa - 0 C M Z - D w o N D y L n O p D y N D N 3 4 o M. Cn o CD O (D W W O ? m a n m 2 y N ? ? ? ? ? CD o n 0 SX (D C) w CD m N. (D 2 n N o m 0 I I I .. ' ??9? °? t Ei 16 HL iiy l) j m 3 8? N '.. 1, ` °? ? j/ ) $ 300 -n CD CD 'x0 ?» C ;o - _O W CD V S VL., y o N y?] C?l1db ,? ?• ,-,, i1411e_lJ rfll m N ~ T n ! I Mailed From 08003 C ;03m?> i!Svi-rvi sc O (nca0a n2 " m W =.a ? m 0 W? N 7 ?n ? ? .oC? ON _ 3 z "> ao CD(0 C :E :E > . 0 ? O,o y F 7 N y -2 o v - 0 g d ° J-- J- . Oa K p J Qpa a Nn O ;?pp 'O N 33ya°.m m Nm y g -N m fna Qn ?j(N °a?. N Cn m j C U T 3 ROFi a OC°.0 3 C O O = O o?co J a o D n x N 7 (Am m? ! v a• y 0 N C C ? O o f o J- o ?mnm 0 CD o ?Ja3?c. d -nm ° ny3"'c? a)0> 0Oy 3 mN= CL aa? Cn ?ma5,.D a °?m E 3 OW o 7 c mmm . o DR63 Z can O ?.n c 1 N 1 C, D a v m v 0 a3=? 0 .E a'O m eD .N on CD 0 .. o ?ocn o C ? m n m 0-610 x n3yo2_ (D -n ?n O n -gym W Cn aJ 01J N j? 01 C D 0 ???3 ? d In c x, ?_mmw3 -n CD? Jc ygs?3 vc3 A a y af O e D a' pv [ r CD ZZ !{ [ J J ?V.Q d CD CD o mmo UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 P.O. Box 961730 Irving, TX 75063 Plaintiff V. Rodney W. Anderson Sharon S. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7240 PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: 7 I-/( UDREN LAW.__OFFFICEB-,--?P5. Attorney for Plaintiff Alan M. Minato, Esquire PA ID 75860 EXHIBIT B Wells Marro Bank, M as Trustee, et al-, Plaintiff(s) Rodney W. Anderson, et. aL, Defendant(s) Service of Process by APS International, Ltd.- 1-800-328-7171 AXIS EKT%2? 7IONAL APS International P122a ` 7800 Glenroy Rd. Minneapolis. AM 55439-3122 APS File #: 1096660001 " AFFIDAVIT OF SERVICE -- Individual Service of process on: UDRE:\ LAM' OFFICES I --Sharon S. Anderson Court Case No. 10-7240 NU. Samantha Torres 111 Wooderest Rd., Ste. 200 f Cherry Will, NJ 080033620 State.of: ---Pfd ------------------.--------------- - County of:__ y/'o dame of Server: undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action. Date/rime of Servicc: that on the _LLTday of 177 9,24 ?- '20 •4L2 at V-44-o'clock _,_PM Place of Service: at 594 Old York Road, Trailer 33 011 Etters, rA 17319 Documents Served: the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property Sehrice of Process on: A true and correct copy of the aforesaid document(s)was served on: SO Sharon S. Anderson 1'+erson Served, and iV?ethod of 5e an By personally delivering them into the hands of the person to be served. i.: By delivering them into the hands of , a person?. of suitable age, who verified, or who upon questioning stated, that he/she resides with Sharon S. Anderson 1)escription of Person lReceiving Documents: ?ei''.:t • Signature of Server: i i` 53 Ft°? at the place of service, and whose relationship to the person is: The person receiving documcnts is described as follow-v J? Sex Skin ColorHair Color Facial Hair- Approx. Age Approx. Height; Approx. Weight _ C To the best of my knowledge and belief; said person -vas not engaged in the US Military ai the time of cervice_ Undersigned declares under penalty of perjury that the fore oing is true and correct. Signature of Sen•er APS International, Ltd. Sub bed and sworn to before me this - ' E day of 720- NO tary Polic 1 7Cominission Expires) 06TARIAL REAL - JAYNE'L ENGLAN!} NpteypAblie WEST MANCHESTER TYVP.1009 GouNTy - My commkslon Expires etc 17.2013 ' Exi- BIa B Wells Fargo Bank, NA as Trustee, et. al., Plaintiff(s) is. Rodney W. Anderson, et. al., Defendant(s) S. Service of Process by APS International, Ltd. 1-800-328-717.1:., ` APS TEWIu-Ttovtt, i APS international PIa2a 7800 Glenroy Rd. \ NUnneapolis, MN 35439-3122•-.k ?--/ APS File fl: 1096664001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: ' VDREN LAW OFFICES -Rodney W. Anderson Court Clue No. 10-7:40 Ms. Samantha Torres 111 Woodcrest Rd ., Ste. 200 tS Cherry Hill. NJ 08003-3620 t?41l+i i ?. -_ R - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - w 3 state of-, SL % a•County of• 0 f ... ? .. Name of Server: ° l r undersigned, being duly sworn, deposes and says. that at the time of service, s/he was of legal age and was not a party to this action; Datefrime of Service: that on the -(?day of 20 L/ -at , •&"'o clock Z_t'?_M Place of Semee: at 594 Old York Road, Trailer 33 in Etters. PA 17319 Documents Served: the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property "Service of Process on: A true and correct copy of the aforesaid document(s) was served on: g.. Rodney W. Anderson - ' s person Served, and ' Method of Service: X By personally delivering them into the hands of the person to be served. By delivering them into the bands of , a person of suitable age, who verged, or who upon questioning stated, that he/she resides with 1 Rodney W. Anderson at the place of service, and whose relationship to the person is: i Description of Person e; i D t The person receiving documents is eseribed as follows: / e r h v 4ec ng ocumen s: 01 Hair Color ?C` Facial Hair l - Sex j4_; Skin Color O 2 Approx. Age Approx. Height E Approx. Weight 1 ? To the best of my knowledge and belief, said person was not engaged in the US Militar,-nt the time of service. ' Signature of Server: Undersigned declares under penalty of perjury Subspribed and sworn to before me this that the foregoing is true and correct. da-y of .20 ?J P t?? t ? Signature of Server Notary Pub (Co scion Expires) , APS International, Ltd. L:. T- NoriiRllusl:Al:. - JAXMNAND WEST MANCHESTER TWP., YORK WMTY . my Cw0magon EvIres Die 17, 2013 F-XHII[31T B y? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Al pp L ,?PA Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank NA V& Case Number Sharon S. Anderson (et al.) 2010-7240 SHERIFF'S RETURN OF SERVICE 03/18/2011 07:01 PM - Deputy Michael Barrick, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 668 State Street, Lemoyne, PA 17043, Cumberland County. 06/01/2011 Ronny R. Anderson, Sheriff, 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 Cumberland County, Courthouse, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 56,500.00 to Family First Financial LLC, 3315 Market Street, Camp Hill, PA 17011, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $2,437.72 July 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF SCHEDULE OF DISTRIBUTION Date Filed: June 23, 2011 Writ No. 2010-7240 Civil Term Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 -vs- Rodney W. Anderson Sharon S. Anderson 668 State Street Lemoyne, PA 17043 Sale Date: Buyer: Bid Price: Real Debt: Interest: Attorney V June 1, 2011 Family First Financial LLC $ 56,500.00 $ 67,840.63 1,679.60 Jrit Costs: 251.90 Total Due: $ 69,772.13 DISTRIBUTION: Receipts: Cash on Account (03/04/2011): $ 1,500.00 Cash on Account (06/01/2011): 5,625.00 Cash on Account (06/13/2011): 54,046.00 Total Receipts: $ 61,171.00 Disbursements: Sheriffs Costs $ 2,137.72 Legal Search 300.00 Transfer Tax (Local) 858.00 Transfer Tax (State) 858.00 Cumberland County Tax Claim Bureau 803.77 Faith Nicola, Lemoyne Borough Tax Collector 391.21. Faith Nicola, Lemoyne Borough Tax Collector 772.20 (2011 School Taxes) Attorney Mark Udren 1,500.00 Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OP T1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 53,550.10 Total Disbursements: Balance for distribution: So A Awers: ($61,171.00) 00.00 Ronny R. Anderson Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-7240 Held June 1, 2011 EFFECTIVE DATE: June 1, 2011 PREMISES: 668 State Street, Borough of Lemoyne, Cumberland County, Pennsylvania, Tax Parcel No. 12-21-0267-422 (the "Premises") RECITAL: Being the same Premises which First Union National Bank, as Trustee for Pennsylvania House Finance Agency, by its deed dated March 7, 2002 and recorded March 27, 2002 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 250, Page 4775, granted and conveyed unto Rodney W. Anderson and Sharon S. Anderson, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. Any environmental liens or claims filed or on record in the Federal District Court. 6. ' Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. IT Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2011. 20. Mortgage in the amount of $59,999.00 from Rodney W. Anderson and Sharon S. Anderson to Novastar Mortgage, Inc. dated March 25, 2002 and recorded March 27, 2002 in Mortgage Book 1753, Page 1815, assigned January 26, 2011 by Instrument No. 201103288 to Wells Fargo Bank, NA. -2- 21. Judgment against Rodney W. Anderson and Sharon S. Anderson in the amount of $67,840.63 entered February 28, 2011 in favor of Wells Fargo Bank, NA to No. 2010- 07240. 22. Judgment against Sharon S. Anderson in the amount of $1,486.65 entered October 21, 2005 in favor of Northstar Capital ACQ, LLC to No. 2005-4416. 23. Judgment against Rodney W. Anderson in the amount of $2,923.34 entered March 29, 2006 in favor of Capital One Bank to No. 2006-0701. 24. Judgment against Rodney W. Anderson :in the amount of $927.20 entered April 7, 2006 in favor of Michaels Louis & Associates to No. 2006-1991. 25. Subject to unpaid taxes due the Tax Claim Bureau in the amount of $798.65 together with any interest and penalties accruing thereon. 26. Subject to all building set-back lines, easements, restrictions, conditions, notes and all other matters appearing on the Plan of West Shore Radiator Works recorded in Plan Book 40, Page 66. 27. Subject to all building set-back lines, easements, restrictions, conditions, notes and all other matters appearing in Plan Book 6, Page 58. 28. Subject to all conditions contained in Deed Book "J", Volume 4, Page 40 and all notes and other matters appearing in Plan No. 3 of North Riverton. 29. Subject to the rights of others in and to any portion of the Premises lying within or adjoining State Street. 30. Subject to the easement of a partition wall or walls. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: V Keith O. Brenneman -3- Writ No. 2010-7240 Civil Wells Fargo Bank, NA VS. Sharon S. Anderson Rodney W. Anderson Atty.: Alan Minato ALL THAT CERTAIN tract of real estate situate in the Borough of Le- moyne, Cumberland County, Penn- sylvania, bounded and described as follows: BEGINNING at an x-cut on the southern right-of-way line of State Street on the northeastern corner of Lot No. 3 on the final re-subdivision plan for West Shore Radiator Works recorded in Plan Book 40, Page 66, Cumberland County Recorder of Deeds Office; thence along the south- ern right-of-way line of State Street North 51 degrees 35 minutes East, 35.00 feet to an x-cut in the concrete walk; thence South 38 degrees 25 minutes East, 75.00 feet through a partition wall dividing the premises known as 668 and 666 State Street to a point at the northeastern corner of Lot No. 5 on the aforementioned subdivision plan; thence South 51 degrees 35 minutes West, 35.00 feet to a point at the southeastern corner of Lot No. 3; thence along the eastern line point, the place of BEGINNING. BEING LOT NO. 4 on the final re- subdivision plan for West Shore Ra- diator Works recorded in Plan Book 40, Page 66, Cumberland County Recorder of Deeds Office. HAVING THEREON ERECTED a dwelling known as 668 State Street; Lemoyne, PA. BEING THE SAME PREMISES which First Union National Bank As Successor Trustee for Pennsylvania Housing Finance Agency, by their deed to be recorded simultane- ously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Rodney W. Anderson and Sharon S. Anderson. BEING KNOWN AS: 668 State Street, Lemoyne, PA 17043. PROPERTY 1D NO.: 12-21-0267- 422. TITLE TO SAID PREMISES IS VESTED IN Rodney W. Anderson and Sharon S. Anderson, Husband and Wife by deed from First Union Na- tional Bank (As Trustee for Pennsyl- vania Housing Finance Agency) dated 03/07/2002 recorded 03/27/2002 in Deed Book 250 Page 4775. EXHIBIT A UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER :_11 WOODCR2ST ROAD, SUITE 200 CHERRY.HIhL',?NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNFY 70F. 7'.-j L_-NT'FF Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 Plaintiff V. Rodney W. Anderson Sharon S. Anderson Defendant(s) :COURT OF COMMON PLEAS :CIVIL DIVISION Cumberland County :MORTGAGE FORECLOSURE :NO. 10-7240 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., as Trustee for ABFC 2002-OPT1 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at.: 668 State Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Name Address Rodney W. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 Sharon S. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 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 Northstar Capital ACQ LLC C/O James C. Warmbrodt Weltman, Weinberg & Reis Co., L.P.A 436 Seventh Ave., Suite 2718 Pittsburgh, PA 15219 Capital One Bank C/O James C. Warmbrodt Weltman, Weinberg & Reis Co., L.P.A 436 Seventh Ave., Suite 2718 Pittsburgh, PA 15219 Michael Louise & Assoc. Address to Follow 4. Name and address of the last 'recorded holder of every mortgage of record:' Name Address Wells Fargo Bank, N.A., as P.O. Box 961730 Trustee for ABFC 200270PT1 Irving, TX 75063 Trust, ABFC Asset-Backed Certificates, Series 2002-OPT1 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record :interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 668 State Street Lemoyne, PA 17043 I verify that the statements made in this affidavit: are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED : ?'?? • ? ? ? ?V ? I UDREN LAW OFFICES, P.C. BY: Attorneys or Plaintiff Chsndrs M. Arkema, Esquire PA 10 203437 :DREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER ll WOODCREST ROAD, SUITE 200 2I RRY, MILL,' NJ 08003-3620 356-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Jiel ?s Fargo Bank, N.A., as COURT OF COMMON PLEAS 7'rustee for ABFC 2002-OPT1 :CIVIL DIVISION -rust, ABFC Asset-Backed :Cumberland County "ertificates, Series 2002-OPT1 Plaintiff :MORTGAGE FORECLOSURE V. Rodney W. Anderson NO. 10-7240 Sharon S. Anderson Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rodney W. Anderson 594 Old York Road, Trlr 33 Etters, PA 17319 Your house (real estate) at 668 State Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on June 1, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Fl, Courthouse, Carlisle, PA, to enforce the court judgment of $67,840.63, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (see notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 3 400. 2. You may be able to petition the Court to set aside the sale if the !Did price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-540C. 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. 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 -z?o a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17031 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17031 717-249-3166 ALL THAT CERTAIN TRACT OF REAL ESTATE SITUATE IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN X-CUT ON THE SOUTHERN RIGHT-OF-WAY LINE OF STATE STREET ON THE NORTHEASTERN CORNER OF LOT NO. 3 ON THE FINAL RE- SUBDIVISION PLAN FOR WEST SHORE RADIATOR WORKS RECORDED IN PLAN BOOK 40, PAGE 66, CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE; THENCE ALONG THE SOUTHERN RIGHT-OF-WAY LINE OF STATE STREET NORTH 51 DEGREES 35 MINUTES EAST, 35.00 FEET TO AN X-CUT IN THE CONCRETE WALK; THENCE SOUTH 38 DEGREES 25 MINUTES EAST, 75.00 FEET THROUGH A PARTITION WALL DIVIDING THE PREMISES KNOWN AS 668 AND 666 STATE STREET TO A POINT AT THE NORTHEASTERN CORNER OF LOT NO. 5 ON THE AFOREMENTIONED SUBDIVISION PLAN; THENCE SOUTH 51 DEGREES 35 MINUTES WEST, 35.00 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT NO. 3; THENCE ALONG THE EASTERN LINE POINT, THE PLACE OF BEGINNING. BEING LOT NO. 4 ON THE FINAL RE-SUBDIVISION PLAN FOR WEST SHORE RADIATOR WORKS RECORDED IN PLAN BOOK 40, PAGE 66, CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE. HAVING THEREON ERECTED A DWELLING KNOWN AS 668 STATE STREET, LEMOYNE, PA. BEING THE SAME PREMISES WHICH FIRST UNION NATIONAL BANK AS SUCCESSOR TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, BY THEIR DEED TO BE RECORDED SIMULTANEOUSLY HEREWITH, IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, GRANTED AND CONVEYED UNTO RODNEY W. ANDERSON AND SHARON S. ANDERSON. BEING KNOWN AS: 668 State Street Lemoyne, PA 17043 PROPERTY ID NO.: 12-21-0267-422 TITLE TO SAID PREMISES IS VESTED IN RODNEY W. ANDERSON AND SHARON S. ANDERSON, HUSBAND AND WIFE BY DEED FROM FIRST UNION NATIONAL BANK(AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY) DATED 03/07/2002 RECORDED 03/27/2002 IN DEED BOOK 250 PAGE 4775. f ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County `MORTGAGE FORECLOSURE :NO. 10-7240 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sharon S. Anderson. 594 Old York Road, Trlr 33 Etters, PA 17319 Your house (real estate) at 668 State Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on June 1, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Fl, Courthouse, Carlisle, PA, to enforce the court judgment of $67,840.63, obtained by Plaintiff above (the mortgagee) against: you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Tc prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. Tc find out how much you must pay, you may call: 1856)-669-5400. -. 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. 1JDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY.HILL,-NJ 08003-3620 856-669-5400 pleadings@udren.com wells Fargo 'T'rustee for Trust, ABFC Certificate Bank, N.A., as ABFC 2002-OPT1 Asset-Backed s, Series 2002-OPT1 Plaintiff V. Rodney W. Anderson Sharon S. Anderson Defendant(s) 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. if-the Sheriff's Sale is not stopped, your property will be sold -,e the,highest bidder. You may find out the price bid by calling 856-669- -.?400. 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 =ull amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for vour house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17031 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17031 717-249-3166 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-7240 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. AS TRUSTEE FOR ABFC 2002-OPTI TRUST, ABFC ASSET-BACKED CERTIFICATES, SERIES 2002-OPT1 Plaintiff (s) From RODNEY W. ANDERSON and SHARON S. ANDERSON (I ) 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 $67,840.63 L. L.$.50 Interest From 2/26/2011 to Date of Sale June 1, 2011 ongoing per diem of $17.68 to actual date of sale including if sale is held at a later date Atty's Comm % Due Prothv $2.00 Arty Paid $251.90 Other Costs Tj i3 $?l?lt c? Plainti{f'Paid Date: 2/28/11 avid D. Buell, rothonotary (Seal) By: Deputy REQUESTING PARTY: Name: CHANDRA M. ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 TRUE COPY FROM RECor In Testimony whereof, I here unto, ?-- and the I of said Court at Carlisla. This day of ??IUICQ ?? UvYi ay On \4arch . a 2`0 Hic ')hen it levied upon the defendant's interest. in tne real property situated in Lemoyne Borough, Cumberland County, PA, Known and numbered as, 668 State Street, Lemoyne, more dully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March ' ) , 2011 By 1 s o l Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-7240 Civil Wells Fargo Bank, NA VS. Sharon S. Anderson Rodney W. Anderson Atty.:.Alan Minato ALL THAT CERTAIN tract of real estate situate in the Borough of Le- moyne, Cumberland County, Penn- sylvania, bounded and described as follows: BEGINNING at an x-cut on the southern right-of-way line of State Street on the northeastern corner of Lot No. 3 on the final re-subdivision plan for West Shore Radiator Works recorded in Plan Book 40, Page 66, Cumberland County Recorder of Deeds Office; thence along the south- ern right-of-way line of State Street North 51 degrees 35 minutes East, 35.00 feet to an x-cut in the concrete walk; thence South 38 degrees 25 minutes East, 75.00 feet through a partition wall dividing the premises known as 668 and 666 State Street to a point at the northeastern corner of Lot No. 5 on the aforementioned subdivision plan; thence South 51 degrees 35 minutes West, 35.00 feet to a point at the southeastern corner of Lot No. 3; thence along the eastern line point, the place of BEGINNING. BEING LOT NO. 4 on the final re- subdivision plan for West Shore Ra- diator Works recorded in Plan Book 40, Page 66, Cumberland County Recorder of Deeds Office. HAVING THEREON ERECTED a dwelling known as 668 State Street, Lemoyne, PA. BEING THE, SAME PREMISES which First Union National Bank As Successor Trustee for Pennsylvania Housing Finance Agency, by their deed to be recorded simultane- ously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Rodney W. Anderson and Sharon S. Anderson. BEING KNOWN AS: 668 State Street, Lemoyne, PA 17043. PROPERTY ID NO.: 12-21-0267- 422. TITLE TO SAID PREMISES IS VESTED IN Rodney W. Anderson and Sharon S. Anderson, Husband and Wife by deed from First Union Na- tional Bank (As Trustee for Pennsyl- vania Housing Finance Agency) dated 03/07/2002 recorded 03/27/2002 in Deed Book 250 Page 4775. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 22, April 29, and May 6 2011 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. isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 6 day of May, 2011 Q-Z-4??4- I Notary i NOTARIAL. SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 _ ie Flatriot-Dews Co. 21) 201 echnology Pkwy Suite-360 Me,,hanicsburg,`PA 17050 Inquiries - 717.,255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ZbePatriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 05/06/11 Sworn to and su6scri ed before me this 23 day of May, 2011 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Sherrie L Kisner, Notary public lower pa,, nvp. dauphin County _ MY Commission Expires Nov, 26, 2011 Member, Pennsylvania AssoCiatior of Notaries) 2070-7240 ChrA Tom Wbft Fargo'Bodt, KA Vs Sharon S. Anderson Rodney W. Anderson Atty: Alan Minato All That Certain Tract Of Real Estate Situate In The Borough Of Lemoyne, Cumberland County, Pennsylvania, Bounded And Described As Follows: Beginning At An X-Cut On The Southern Right-Of-Way line Of State Street On The Northeastern Comer Of Lot No. 3 On The Final Re-Subdivision Plan For West Shore Radiator Works Recorded In Plan Book 40, Page 66, Cumberland County Recorder Of Deeds Office; Thence Along Fhe Southern Right-Of-Way Line Of State Street North 51 Degrees 35 Minutes East, ,5.00 Feet To An X-Cut In The Concrete Walk; Thence South 38 Degrees 25 Minutes East, 75.00 Feet Through A Partition Wall Dividing The Premises Known As 668 And 666 State Street To A Point At The Northeastern Comer Of Lot No. 5 On The Aforementioned Subdivision Plan; Thence South 51 Degrees 35 Minutes West, 35A) Feet To A Point At The Southeastern Corner Of Lot No. 3; Thence Along The Eastern Line Point, The Place Of Beginning. Being Lot No. 4 On The Final Re- Subdivision Plan For West Shore Radiator Works Recorded In Plan Book 40, Page 66. Cumberland County Recorder Of Deeds Office. Having Thereon Erected A Dwelling Known As 668 State Street, Lemoyne, Pa. Being The Same Premises Which First Union National Bank As Successor Trustee For Pennsylvania Housing Finance Agency, By Their Deed To Be Recorded Simultaneously Herewith, In The Office Of The Recorder Of Deeds Of Cumberland County, Granted And Conveyed Unto Rodney 'J Anderson And Sharon S. Anderson. ',,eing Known As: 668 State Street I emoyne. Pa 17043 Properly Id No- 1.2-21-1267-421 Title To Said Premises Is Vested In Rodney W Anderson And Sharon S. Janderson, Husband And Wife By Deed From First Union National Bank (As Trustee For Pennsylvania Housing Finance Agency) Dated 03/07/2002 Recorded 03127/2002 In Deed Book 250 Page 4775. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Family First Financial LLC is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 28 day of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7240, at the suit of Wells Fargo Bank NA as Trustee for ABFC 2002-OPT 1 Trust against Rodney W. Anderson & Sharon S. Anderson is duly recorded as Instrument Number 201118970. IN TESTIMONY WHEREOF, I have hereunto set my hand and wal of said office this z day of A.D. d 011 Recorder of Deeds 9ecmer of Deeds, Cm bmW C=ft Csrlbls, pA Ay commission Expires the First Monday of Jan. 2014