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Home My WebLink About01-1814MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 043 02 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ .08034 856-482 -6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) COURT OF COMMON PLEAS CIVIL DIVISION -Cumberland County i o. COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in tho following pagos, you must take action within tWenty (20) days after this Complaint and Notice are served, by enterin~ a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims sot forth against you. You aro warned that if you fail to .do so the case may proceed without you and a judgment may be onterod against-you by the Court without furthor notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff.. 'You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20). dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiereque usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DE.Ah-DA A UN ASO~ADO I~EDIAT~NTE, SI NO TIENE ABO~ADO 0 ST NO TIENE EL DINERO SUFTCTENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLA~E POR TELEFONO A LA OF'rCINA CUYA DIRECCTON SE ENCUENTI~,. ESCRTTA ABAJO PARA AVERIC, UAR DONDE SE PUEDE CONSEGUIR ASTSTENCTA LEGAL. Cumberland County Bar Association- 2 Liberty Avenue 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 obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (8S6) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a precedin~ pa~e. If Plaintiff is an assignee then it is such by virtue of the followin~ recorded assignments: Assignor: Aegis Mortgage Corporation dba New American Financial Assignee- Mortgage Electronic Re~. Systems Recordin~ Date- 4/27/00 Book- 643 Pa~e: 170 2. Defendant (s) is the individual designated as such on the caption on a precedin~ pa~e, 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 bein~ foreclosed. 3. On or about the date appearin~ 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 appearin~ on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for 'the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (~) . The information re~ardin~ the Mortgage bein~ foreclosed is as follows: MORTGAGED PREMISES: 332 Old Stonehouse Road MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Monroe COUNTY: Cumber 1 and DATE EXECUTED: 12 / 23 / 99 DATE RECORDED: 12/29/99 BOOK: 1589 PAGE: 687 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, to~ether with other char~es 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 failin~ or refusin~ to pay the installments of principal and interest when due in the amounts indicated below; (b) by failin~ or refusin~ to pay other char~es, if any, indicated below. 6. The followin~ amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 8.00% from 9/1/00 to 3/15/00~ (the per d±em £nterest ~ccru±n~ on this~debt is $16.32 and that sum Should be added each day after Title Report $73,455.96 3,198.72 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) '(The monthly escrow on this account is $94.93 and that sum should be added on the first of each month after 3/15/01) 237.58 Late .Charges (monthly late charge of $25.48 should be added on the fifteenth of each month after 3/15/01) 153.04 Pro Rata MIP/PMI Recordin9 Fees Property Inspections/Preservation Other Fees 89.16 14.00 60.00 200.00 Attorneys Fees (anticipated and actual to 5% of principal) 3.672.80 TOTAL $81,611.26 7. The attorney's fee set forth above are in conformity with the mort[la~e documents a.nd 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 char~ed in accordance With the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Pro~ram, Act 91 of 1983, has not been sent because the Mortgage is insured by the Federal Housin~ Administration ("FHA") and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, a~ainst the Defendant(s) herein in the sum of $81,611.26 plus interest, , costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Ma dren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE OF CHURCH OR WATER STREET~ THENCE ALONG LANDS NOW OR FORMERLY OF A.S. BLACK AND DORORTHY I. BLACK, HIS WIFE, SOUTH 77 DEGREES 30 MINUTES WEST, 66.5 FEET TO AN IRON PIPE~ THENCE BY THE SAME, NORTH 15 DEGREES 45 MINUTES -WEST, 65 FEET TO AN IRON PIPE~ THENCE BY THE SAME, NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A POINT IN THE CENTER OF SAID MAIN STREET~ THENCE BY THE CENTER OF SAID MAIN STREET, SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 4,780 SQUARE FEET AND HAVING THEREON ERECTED A FRAME DWELLING HOUSE, BEING NUMBERED AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA. VERI F I CAT ION Mark J. Udren, Esquire, hereby states tha~ ..... ~ .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 re~ardin~ this matter, and because Plaintiff must verify much of the information' through .a~ents, and because he has personal knowledge of. some of the facts averred in the foregoin~ pleading; and that the statements made in the fore~oin~ pleadin~ 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 a~ents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Section 4904 relatin~ to unsworn falsification to authorities. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES CT. . .... ... · ..;.._' -; SHERIFF' S RETURN - REGULAR CASE NO- 2001-01814 p COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS GOODRICH DARRELL R STEVEN M WHISTLER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT _ MORT FORE was served upon ' GOODRICH DARRELL R DEFENDANT , at 1657.00 HOURS, on the at 322 OLD STONEHOUSE ROAD 3r____~d day of April the 2001 BOILING SPRINGS, PA 17007 DARRELL R. GOODRICH by handing to a true and attested copy of COMPLAINT _ MORT FORE together wi th and at the same time directing Hi_~s attention to the contents thereof. Sheriff,s Costs- Docketing 18.00 Service 3.72 Affidavit .00 Surcharge 10.00 .00 31.72 04/04/2001 MARK j. UDREN So Answers. R. Thomas Kline Sworn and Subscribed to before me this _~ g ~-~ day of . By- "MAR~ J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 . Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS 'CIVIL DIVISION . Cumberland County 'MORTGAGE FORECLOSURE Ye Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 NO. 01-1814 Civil De f endant ( s ) ~ PRAECIPE FOR JUDGMENT FOR FAILURE TO ~NSWER ~ ASS~.SSM~.NT OF DAMAGES 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 $81,611.26 Interest per Complaint 1,354.56 From 3/16/01 to 6/6/01 Late charges per Complaint 50.96 From 4/15/01 to 6/6/01 Escrow payment per Complaint _ 284.79 From 4/1/01 to 6/6/01 TOTAL $83,301.5 7 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in which is attached hereto. copy of UDREN & ASSOCIATES ~a Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED accordance with Rule 237.1, a MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 8S6-482-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff v. Darrell R. Goodrich 332 Old Stonehouse Road Boilin~ Springs, PA 17007 Defendant ( s ) ATTORNEY FOR pLAINTIFF ~ COURT OF COMMON PLEAS ]CIVIL DIVISION Cumberland County i NO. 01-1814 Civil DATED- TO: April 26, 2001 Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 IMPORTANT' NOTICZ 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 Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANT~ 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 DEN=fRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED.EN CORTE O ESCUCHAR PREUBAALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO 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 ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UD~EN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 10~0 N. KIN~S HIGHWAY, SUITE CHE~Y HILL, NJ 0803~ 856-482-6900 ATTORNEY FO~ PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R' Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) i COURT OF COMMON PLEAS ~CIVIL DIVISION ~Cumberland County i MORTGAGE FORECLOSURE 01-1814 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF ~~ : COUNTY OF F-] : 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: Darrell R. Goodrich Age- Over 18 Residence: As captioned above Employment- Unknown De f endant: Age: Over 18 Residence: As captioned above Employment- Unknown · Title: Sworn to and subscribed Company: before me this ~~day of ~~.~ 200t . fa~' PUblic -- ,. A Notary Public ol ~ uommmsmn [x~ires 4/~/2003 MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. N~. 0~302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-%82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332. Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF ,, 'COURT OF COMMON PLEAS CIVIL DIVISION . Cumberland County ' MORTGAGE FOREC'r,OSUR~. ' NO. 01-1814 Civil TO- DA/~RELL R. GOODRICH 332 Old Stonehouse Road Boiling. Springs, PA 17007 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 De fault Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration -. Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL- ATTORNEY Mark J. Udren, Esquire At this telephone number- 856-482-6900 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482 - 6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 'COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 . NO. 01-1814 Civil De f endant ( s ) ' PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMRNT OF DAMAGES TO THE PROTHONOTARY- .. . Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff,s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff,s damages as follows- As set forth in Complaint Interest per Complaint From 3/16/01 to 6/6/01 Late charges per Complaint From 4/15/01 to 6/6/01 Escrow payment per Complaint From 4/1/01 to 6/6/01 $81,611.26 1,354.56 50.96 284.79 TOTAL · $ 83:301.5~ 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 cop~ of which is attached hereto. UDREN & ASSOCIATES Ma~k ,J.! Udren - ESQUIRE Attorney for ~laintiff ~ _ _ P ROT-HY - ~ MARK J. UDREN & ASSOCIATES BY.- Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-~82-6900 Wells Fargo Home Mortgage ' Inc. ' 5024 Parkway Plaza Blvd. Charlotte, NC 28217 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS . CIVIL DIVISION : Cumberland County Plaintiff Vo Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) MORTGAGE FORECLOSURE NO. 01-1814 Civil TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter- Amount due Interest From ~ to Date of Sale per diem @$16.32 (Costs to be added) MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF MARK j. UDREN & ASSOCIATES ~Y-' Mark j. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KINGs }{IGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boilin~ Springs, PA 17007 Defendant (s) ATTORNEy FOR PLAINTIFF ~ COURT OF COMMON PLEAS . CIVIL DIVISION ' Cumberland County : MORTGAGE FORECLOSURE . NO. 01-1814 Civil 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- (x) ( ( An FHA insured mortgage Non-owner occupied Vacant ( ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C S Sec. 4904 relating to unsworn falsification to authorities.- · UDREN & ASSOCIATES Mark' j. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF c ~' cz MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-%82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Vo Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF -COURT OF COMMON PLEAS 'CIVIL DIVISION . Cumberland County 'MORTGAGE FORECLOSURE . . ' NO. 01-1814 Civil . . AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, 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- 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s)- Name Address DARRELL R. GOODRICH 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 2. Name and address of Defendant (s) in the judgment- Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property- Name Address NONE 6. Name and address of the property and whose Name e. very other person who has any record · nterest may be affected by the sale. Address interest in knowledge who has the sale. Name Tenants/Occupants REAL ESTATE TAX DEPT. 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has any interest in the property which may be affected by Address DATED- June 6, 2001 332 Old Stonehouse Road Boilin~ Springs, PA 17007 , I verify that the statements made in this affidavit to the best of my person understand that . al knowled e o ' a. re true and c of 18 Pa.c.s false statements herei~n r lnf_ormatlon and bel' orrect · sec. 4904 r~ ...... are mad~ =~uzng ~o unsworn ~: -., -, - -. -- .'""""" J .= ~ '- uo the penalt~o ~~s~lca~ion to authoritieS.~ MARK ~UDREN & ASSOCIATES Attorney for Plaintiff MARK j. UDREN & ASSOCIATES BY: Mark j. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KINOS }{IOHWAY, SUITE 500 C~{ERRY ~{ILL, NJ 0805~ Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boilin~ Sprin~s, PA 17007 Defendant ATTORNEY FOR PLAINTIFF · : COURT OF COMMON PLEAS . CIVIL DIVISION ..' Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-1814 Civil TO: DARRELL R. GOODRICH 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house. (real estate) at 332 Old Stonehouse Road, Boilin~ Sprin~s, PA 17007 is scheduled to be sold at the Sheriff,s Sale on September 5, 2001, at 10-00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) a~ainst you. If the sale is postponed the property will be relisted for the Next Available Sale., To prevent this Sheriff,s Sale, you must take 1. The sale ~ will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable you may call: ~~k_4~~. attorney,s fees. To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered You may also ask the Court to postpone the sale for 9ood 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. to obtain an attorney.)(See notice on page two on how ! h~' ' 1. If the Sheriff,s Sale is not stopped, your property will be Sold to the · gnest 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. may bring legal proceedings to evict you. At that time, the buyer 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 CJtNNOT 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 Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013_3387 717-249-3166 or 800-990-9108 .. -. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. N~. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-~82-6900 ,, , Wells Fargo'Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS . CIVIL DIVISION :Cumberland County 'MORTGAGE FORECLOSURE . NO. 01-1814 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, 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- 332 Old Stonehouse Road, Boiling. Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s) - Name Address DARRELL R. GOODRICH 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 2. Name and address of Defendant (s) in the judgment- Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor 'whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property- Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale- Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128- 0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale- Name Address Tenants/Occupants 332 Old Stonehouse Road, Boilin9 Spring.s, PA 17007 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 relatin~ to unsworn falsification to authorities. DATED- June 6, 2001 MARK J. UDREN & ASSOCIATES Mar~ J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-482-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF -COURT OF COMMON PLEAS ' CIVIL DIVISION . . Cumberland County ' MORTGAGE FORECLOSURE ' NO. 01-1814 Civil . NOTICE OF_SHEBIFF'S SALE OF ~RAL PROPERTY TO: DARRELL R. GOODRICH 332 Old Stonehouse Road Boiling Springs, PA 17007 Your. house~ (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 5, 2001, at 10-00 AM in the CUMBER~ COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ~LE TO PREV~.NT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take /&~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) 482-6900L 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.) ][OU MAY _~TILL BE ABLE TO SAVF~ PROPERTY AND YOU HAVE OTHER RIG~LT~ EVEN IF THEoSHERIFF,S SAT.E DOE~ TAK~ PT.~CE~ 1. If the Sheriff,s Sale is not stopped, your property will be sold to' the highest bidder. You may find out the Price bid by calling 856-482-6900. 2. You may be able to petition-the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff you will remain the owner of the property as if the sale never happened. ' 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. LAWYER REFERRAL SERVICE ' Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILJUDELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN ~HACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE OF CHURCH OR WATER STREET; THENCE ALONG LANDS NOW OR FORMERLY OF A.S. BLACK AND DORORTHY I. BLACK, HIS WIFE, SOUTH 77 DEGREES 30 MINUTES WEST, 66.5 FEET TO AN IRON PIPE; THENCE BY THE SAME, NORTH 15 DEGREES 45 MINUTES WEST, 65 FEET .TO AN IRON PIPE; THENCE BY THE SAME, NORTH 70 DEGREES 30 MINUTES EAST, 61.8 FEET TO A POINT IN THE CENTER OF SAID MAIN STREET; THENCE BY THE CENTER OF SAID MAIN STREET, SOUTH 16 DEGREES 45 MINUTES EAST, 73 FEET TO A POINT THE PLACE OF BEGINNING. ' CONTAINING 4,780 SQUARE FEET AND HAVING THEREON EI~ECTED A FRAME DWELLING HOUSE, BEING' NUMBERED AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA. BEING KNOWN AS PROPERTY ID# 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 22-28-2401-015 TITLE TO SAID PREMISES IS VESTED IN DARRELL. R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAXINE A. KLINEDINST, NOW KNOWN AS MAXINE A. KLINEDINST FRY AND GUY FRY, HER HUSBAND DATED 12/23/99 AND RECO~ED 12/29/99 IN DEED BOOK 213 PAGE 1132 ' ' ° WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-1814 CIVIL 1]~ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW ----- TO THE SHERIFF OF Cunberland .COUNTY' To satisfy the debt, interest and costs due H INc. PLAINTIFF(S) from Darrell R. Goodrich, 332 Old Stonehouse Road, Boilings, PA 17007 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell (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/am 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/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,301.57 frc,]~ 6/7/01 to 915101 Interest ~Per diem__ @$1 Atty's Corem % A~y Paid $103.72 L.L. $.50 Due Prothy Other Costs Sl. O0 Plaintiff Paid Date: June 13, 2001 REQUESTING PARTY- Name Mark J. Uclren, Esq. Address. 1040 N. Kings Highway, 'Suite 500 Cherry Hill, NJ 08034 Attorney for." Telephone: Pla ~ ntiff 856-482-6900 Supreme Court ID No. 04302 Curtis R. Long Prothonotary, Civil Division REAL ESTATE SALE N:o. '~(~ the snentt levied Ul~On the amenaa~,. interest in the real 13rol3ertv ~itu~tP.r~ ~.. Cumberland County, Pa., ~ .-~~-.-~-, and more ..,mbered as' this writ and by this reference incorporated herein. Date ~(~~.,/~7. ,~ o o_/ By. MARK J. UDREN & ASSOCIATES BY.' Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-~82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Vo Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION . Cumberland County '~ORT~~ ~OR~CBO8IJR~ ' NO. 01-1814 Civil pRAEcIPE TO ~ISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due Interest From June 7:2001 to Date of Sale March 6:2002 Per diem @$16.32 (Costs to be added) $83:301.57 4,455.36 MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-%82-6900 Wells Fargo Home Mortgage, Inc. 'COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. ]CIVIL DIVISION Charlotte, NC 28217 'Cumberland County ATTORNEY FOR PLAINTIFF Plaintiff V. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 - MORTGAGE FORECLOSURE ' NO. 01-1814 Civil De f endant ( 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- (x) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant · ( ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ REN & ASSOCIATES ~ /~rk J ren, ESQUIRE -~ ATTO~~.Y F~~' PLAINTIFF MARK J. UDREN & ASSOCIATES BY.- Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482 - 6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. COURT OF COMMON PLEAS . 5024 Parkway' Plaza Blvd. CIVIL DIVISION Charlotte, NC 28217 ' Cumberland County Ve Plaintiff Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) - MORTGAGE FORECLOSURE NO. 01-1814 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, 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- 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s) · Name Address Darrell R. Goodrich 332. Old Stonehouse Road, Boiling Springs, PA 17007 2. Name and address of Defendant (s) in the judgment- Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property- Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale- Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale- Name Address Tenants/Occupants 332 Old Stonehouse Road, Boiling Springs, PA 17007 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 falsificition to authorities. DATED- October 24, 2001 ssoc T .S rk J. · ESQ. Attorney for Plaintiff Mld~K J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-~82-6900 _ Wells Fargo Home Mortgage, Inc. 'COURT OF COMMON PLEAS 5024 Parkway Plaza Blvd. 'CIVIL DIVISION Charlotte, NC 28217 'Cumberland County ATTORNEY FOR PLAINTIFF Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 ' MORTGAGE FORECLOSURE ' NO. 01-1814 Civil Defendant (s) . NOTICE OF SHmRIFF'S SAT.~. OF ~.A?. PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10- 00 AM in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER' S RIGHTe YOU MAY BE ARLE TO PREVRNT THIS SHERIFF'S SAI.E To prevent this Sheriff's Sale, you must take £mmediate actions 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) 482-6900~ 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.) ~OU NA~ y~ ~ YO~_~~~ OT~~~~]~ FA~N_IF THE SHERIFF'S S~LE DOHS TAKE_p~ 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 qives a deed to the buyer. At that time, the buyer may bring legal proceedings to evic~ you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHEREYOUCA~ GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY'. Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Ve Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS .~ CIVIL DIVISION :: Cumberland County .-" NO. 01-1814 Civil SUggESTION OF BANKRUPTCY To the Prothonotary- Kindly note on the record that the above Defendant, Darrell R. Goodrich has filed Chapter 7 Bankruptcy in the Middle District of Pennsylvania on October 15, 2001, Bankruptcy Case No. 01-03519.. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Wells Fargo Home Mortgage, Inc. VS Darrell R. Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1814 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark Udren. Sheriffs Costs: Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library Prothonotary 1.00 Share of Bills 24.20 Mileage 13.00 Levy 15.00 Advertising 15.00 Certified Mail Poundage 2.6~6 Postpone Sale Law Journal Patriot News $135.86 paid by attorney 3-07-02 Sworn and subscribed to before me This ['/~ day of '~ 2001, A.D._ -~] -],,t~, - L'~__ '-)')Ld/.t~, ~- Prothonotary So Answers: R. Thomas Kline, S6eriff BY \~~ ~5~~-~ Real Estate Deputy MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire- ATTY I.D. NO. 0%302 10%0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-~82-6900 Wells Fargo Home Mortgage, Inc. 'COURT OF COMMON PLEAS' 5024 Parkway Plaza Blvd. 'CIVIL DIVISION Charlotte, NC 28217 - Cumberland .Count~ Plaint i f f - MORTGAGE FORECLOSURE Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s ) ' NO. 01-1814 Civil ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE"3129.1 Wells Fargo Home Mortgage, 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: 332 Old Stonehouse Road, Boiling Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s): Name Address ., Darrell R. Goodrich 332. Old Stonehouse Road, Boiling Springs, PA 17007 2. Name and address of Defendant (s) in the judgment- Name Address · SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name 'and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every othe'r person who has any record lien on the property: .. Name Address NONE 6. Name and address of' every other person who has any record interest in the property and whose interest may be affected by the sale- Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128 - 094 6 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 ~he sale- Name Address Tenants/Occupants 332 Old Stonehouse Road, Boiling Springs, PA 17007 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- October 24, 2001 MARK J. U ¢Pr~4'r; & ASSOCIATES ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ' BY: Mark J. Udren, Esquire , ATTY I.D. NO. 0~302 10~0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-%82 - 6900 Wells Fargo Home Mortgage,Inc. 502.4 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Vo Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De fendant ( s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION- Cumberland County MORTGAGE FORECLOSURE NO. 01-1814 Civil NOTICE OF SHERIFF'S SALE OF ~.a?. PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10- 00 AM in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER' S RIGHTS YOU MAY BE ARLE TO PRRV~.NT THIS SHF. RIFF, S SA?.F 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) 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 ABLE TO SAVE YOUR PROP~.RTY AND YOU _~AVE OTHER RIGHTS EVEN IF' THE SHERIFF'S SAT.R DO~.S TAK~ PT.~CE. 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 saIe. 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 w~thin 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, C,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 Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN ~P. ACT OR PARCEL OF LARD AND P~EMISES, SITIIATE, LYING AND BEING IN THE TOWNSHIP OF MON~OE IN THE COUNT"f OF CUMBERLAND AND COMI~O~~ OF PENNSYLVANIA, MORE pA/~TIC~LY DESCRIBED AS FOLLOWS: ~EGINN'ING AT A POINT IN THE CENTER OF MAIN STREET, SAID POINT BEING 58 FEET FROM THE BUILDING LINE OF CHII~CH OR WATER STREET; THENCE ALONG LANDS NOW OR FORMERLY OF A. S . BLACK AND DORORTHY I. BLACK, HIS WIFE, SOUTH 77 DEGP~EES 30 .MINI~TES WEST, 66 . 5 FEET'TO A~ IRON PIPE; THENCE BY THE SAME, NORTH 15 DEGREES 45 MINUTES WEST, 65 FEET .TO AN IRON PIPE; THENCE. BY THE SAME, NORTH 70 DEGREES 30 MINUTES FAST, 61.8 FEET TO A POINT IN THE CENTER OF SAID MAIN STI~EET; THENCE BY THE CENTER OF SAID MAIN STREET, SOUTH 16 DEGI~EES 45 MINUTES EAST, 73 FEET TO A POINT, THE PLACE OF BEG II~"I~IING. · CONTAINING 4,78O SQUAP, E FEET AND HAVING THEREON E~tECTED A FI~%F~E DWELLING HOUSE, BEING' NUMBERED AS 331 OLD STONEHOUSE' ROAD, BOILING SPRINGS, PA. ,. BEING KNOWN AS 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 PROPER. TY ID# ...... 22-28-2401-015 · .. TITLE TO SAID'PRESSES IS VESTED IN DARRELL. R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAX.12q'E A. KL~ED~ST, NOW' KNOWN AS.MAXINE A. KL~ED~ST FRY' AND GUY FRY, HER' HUSBAND DATED 12123/99 AND RECO~ED 12/29/99 IN DEED BOOK 213.PAGE 1132 ALL THAT CERTAIN ~P, ACT OR PARCEL OF LAND AND p~EMISES, SITIIATE, LYING AND BEING IN T~E T0WNSaZP OF ~O~OE ZN ~E CO~~ OF ~E~~ ~ CO~O~~~ OF p~S~LV~IA, MOaE p~TIC~Lt DESCaIB~ ~ FOLLOWS= BEGI~ING AT A POI~ IN TaE C~Ea OF ~IN ST~ET, SAID POI~ BEING 58 FEET FaOM ~E BUI~ING LI~ OF C~CH Oa WATEa ST~ET~ ~~CE ~ONG ~S NOW Oa Fo~aL~ OF A.S. B~CK ~ DOaOaTa~ I. B~CK, HIS WIFE, SO~ 77 DEGaEES 30 .MI~TES ~ST, 66.5 FEET'TO ~ IaON PIPE; ~~CE BY ~E S~, NOa~ 15 DEG~ES ~5 MI~ES ~ST, 65 FEET .TO ~ Ia0N PIPE; ~ENCE BY TaE S~, NO~ 70 DEGaEES 30 MI~ES ~T, 61.8 FEET TO A POINT IN ~E C~Ea ~F S~D ~IN ST~ET; ~~CE BY ~E C~~ OF SAID ~IN STaEET, SO~H 16 DEG~ES %5 MI~ES ~ST, 7] FEET TO A POI~, ~E p~CE OF BEGI~ING. . CONTAINING 4,780 SQU~ FEET ~ ~VING ~EREON E~CTED A F~ DWELLING HOUSE, BEING ~E~ED AS 332 OLD STON~OUSE' ~O~, BOILING SP~INGS, PA. ,. BEING KNOWN AS 332 OLD SToNEHOUSE ROAD, BOILING SPRINGS, PA 17007 PROPER.. TY ID# ...... 22-28-2401-015 · .. TITLE TO SAID PRESSES IS VESTED IN DARRELL. R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAXINE A. KL~EDINST, NOW KNOWN AS.MAXINE A. KLINEDINST FRY' AND GUY FRY, HER' HUSBAND DATED 12/23/99 AND RECORDED 12/29/99 IN DEED BOOK 213 PAGE 1132 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. COUNTY OF CUMBERLAND) TO THE SHERIFF OF C%znberland To satisfy the debt, interest and costs due COUNTY: 01-1814 CIVIL 1]I~: TERVj CIVIL ACTION- LAW --'"-- H Mort a e Inc. ,,----____PLAINTIFF(S) from i h 332 Old Stonehouse Road, Boilings, PA 17007 ,DEFENDANT(S) ('~) You are directed to levy upon the property of the defendant(s) and to sell See Leqal 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 lo notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is/am 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 PO .ssession 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 staled. Amount Due $83,301.57 Interest frc~ 6/7/01 to date of sale 3/6/02 -~z- ...... @"'~ °" "~ 4~ 35 Atty's Comm % Ally Paid $177.07 L.L. Due Prothy Other Costs $!-00 Plaintiff Paid Date- October 30, 2001 REQUESTING PARTY- Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 Curtis R. Long Prothonotary, Civil Division "REAL ESTATE S.ALE No. On November 01,2001, the sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, known and numbered as 332 Old Stonehouse Road, Boiling Springs, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date' November 01,2001 MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 0%302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-~82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff V. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) ATTORNEY FOR PLAINTIFF i COURT OF COMMON PLEAS .:CIVIL DIVISION ..- Cumberland County ! MORTGAGE FORECLOSURE _- . _- _- . i NO. 01-1814 Civil _- TO THE SHERIFF: PRAECIPE TO ISSUE WRIT OF EXECUTION Issue Writ of Execution in the above matter- Amount due Interest From 6/7/01 to Date of Sale September 4, 2002 Per diem @$16.32 $83:301.57 7:425.60 (Costs to be added) & ASSOCIATES · Udre , ESQUIRE TORNEY FOR INTIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1814 Civil CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From DARRELL R. GOODRICH, 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 (1) You are directed to levy upon the property of the defendant (s)and to sell DESCRIPTION. SEE LEGAL (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 $83,301.57 L.L. Interest FROM 6/7/01 TO DATE OF SALE SEPTEMBER 4, 2002 - PER DIEM ~$16.32 - $7,425.60 Atty's Comm % Atty Paid $397.43 Plaintiff Paid Date: MAY 29, 2002 Due Prothy $.100 Other Costs CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 MARK j. UDREN & ASSOCIATES BY: Mark j. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS ~{IGHWAY, SUITE 500 C~ERRY HILL, NJ 08034 856-~82-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Ve Darrell R. Goodrich 332 Old Stonehouse Road Boilin~ Sprin~s, PA 17007 De fendant ( s ) NO. 01-1814 Civil 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- (x) ( ( ) An FHA insured mortgage Non-owner occupied Vacant ( ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S Sec. 4904 relatin~ to unsworn falsification to authorities. · ASSOCIATES J. Udre E Y FOR p .INTIFF uetCaseN°0 +" (" + DktTypeExpand(m.gsDktType) + ,,) Bankruptcy Docket Report 1 01-03519 (Harrisburg) GOODRICH, DARRELL R Docket items entered between 01/01/1931 and 05/10/2002 Filing Date 06/19/01 06/19/01 06/20/01 07/16/01 08/16/01 08/22/01 09/04/01 09/05/01 09/07/01 09/10/01 09/07/01 09/14/01 09/17/01 10/01/01 10/02/01 10/15/01 1 O/15/01 10/15/01 .0/15/01 0/15/01 Docket Entry · VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Plan and Summary [EOD 06/~ 9/0 ~ ] [C^J MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR [Disposed] [EOD 06/20/01 ] O~ wi ORDER to pay trustee. Re: Item # 2. [EOD 06/20/01] [B CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days atler meeting held. [EOD 07/16/01J [CA] 341 meeting held. [EOD 08/16/01 ] [CA] OBJECTION to Plan by Trustee. [Disposed] [EOD 08/22/01] [BW] OBJECTION to plan by WELLS FARGO HOME MORTGAGE, INC. Re: Item # 1. [Disposed] [EOD 09/04/01 ] [BW] . CORRESPONDENCE SETTING HEA~G on 11/16/01 at 10:00 A.M. at FED.BLDG., BKR~TCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 7. [Rescheduled] [EOD 09/05/01 ] [BW] MOTION for relief from stay filed by WELL rec. #573801-CA · S FARGO HOME nr:r~,mo,.. ) [D~sposed] [EOD 09/07/01] rnun MORTGAGE, INC. (fee pek $75.00, CERm~ ....... sszon [EOD 09/07/01 ] [BWi · ~r~,.~ 115 OF N - ON CONCURRENCE lEOn.09/07/01 ] [BW] ORDER that answers aredue on 10/01/01 Re: Item # 9. [EOD 09/10/01 ] [BW] Amendment to Schedule(s): I AND J. Re: Item # 1. [EOD 09/10/01] [CR] CERTIFICATE of service Re: Item # 10. [EOD ;9/14/01] [JC] Praecipe/Withdraw Re: Item # 7. rE'OD 09/17/01] [BW] APPROVED by the court. Re: Item # 7: [EOD 09/17/01] [BW] This entry cancels the previous due date. Re: Item # 8. [EOD 09/17/01] [BW] MOTION for default judgment Re: Item # 9. [Disposed] [EOD 10/01/01 ] [BW] ORDER granting default judgment Re: Item # 14. [EOD 10/02/01 ] [BW] ORDER granting relief l~om stay Re: Item # 9. [EOD 10/02/01 ] [BW] MOTION to convert from chapter 13 to chapter 7 filed b (requested Original signatures) (received · · · _ y Debtor (fee pd. $15.00, rec. #575034-CR) [B WI original s~gnature) Re: Item # 1. [Disposed] [EOD 10/15/01] CERTIFICATE of service Re: Item # 16. [EOD 10/15/01] DEBTOR(S) affidavit of disbursement of Trustee funds upon Dismissal and/or Conversion prior to conf'mnation. [EOD 10/16/01J [BW] Amendment to Schedule(s): I & J Re: Item # 1. [EOD 10/16/01 ] [KZ] Debtor's Statement of Intentions [EOD 10/16/01 ] [KZ] None None None None None None None None None None None None None None None None None None None P ://pacer. para b. usco urts. gov/cgi_ bin/foxweb, exe/npac er/nPacer?Exec This=docket&puid=0102104720... 05/10/2002 Page 1 of 2 View document None Docket for Case: "+ GetCaseNo0 +" C + DktTYpeExpand(m. gsDktType) + ") 10/16/01 ORDER directing Trustee to file Final Report:due on 11/15/01 [EOD 10/16/01] [BW] 10/16/01 ORDER converting chapter 13 to chapter 7 Re: Item # 16. [EOD 10/16/01] [BW] ALL FURTHER ENTRIES ARE UNDER CHAPTER 7 [EOD 10/16/01] [BW] This entry disposes of motion. Re: Item # 6. [EOD 10/16/01] [BW] 11/13/01 12/05/01 12/06/01 12/06/01 12/06/01 12/12/01 01/08/02 CERTIFICATE OF MAILING of notice of 341 meeting. [EOD 11/13/01] [KZ] Amendmeni to Schedule(s):.F. Re: Item # 1. [EOD 12/06/01] [BR] FEE PAID Receipt #576875, '$20.00. Re: Item # 25. [EOD 12/07/01] [CA] NOTICE TO DEBTOR(S) OF DEFECTIVE AMENDMENT Request $20.00 fee. due by .12/21/01 Re: Item # 24. [Complied] [EOD 12/06/01] [BR] 341 meeting held. [EOD 12/06/01] [KZ] FINAL REPORT of Trustee in No Asset Case [EOD 12/06/01] [KZ] FINAL REPORT of Ch. 13 Trustee Re: Item # 21. [EOD 12/12/01] [NP] MOTION to terminate wage attachment. Re: Item # 2. [Disposed] [EOD 01/09/02] [DR] 01/09/02 02/15/02 02/15/02 04/1 $/02 ORDER terminating wage attachment Re: Item # 29. [EOD 01/09/02] [DR] DISCHARGE of Debtor(s). Certificate of Mailing. [EOD 02/15/02] [DR] FINAL Decree. Certificate of Service. [EOD 02/15/02] [DR] . FINAL REPORT of Ch. 13 Trustee Re: Item # 21. [EOD 04/18/02] [DR] Printed: 05/10/02 12:14:11 Page 2 of 2 None None None None None None None None Doc~ None None None PACER Service Center · · IDescription: |~ocket ]ic se Number: 1[1 2001-03519 Need help? Try the PACER User's Guide ~acer Service Center http://pacer.pamb.uscourts.gov/cgi-bin/f°xweb'exe/npacer/~aeer?Exec~s=d°cke~p~d~ 102104720... 05/10/2002 ' MARK J. UDREN & ASSOCIATES · BY'. Mark J. Udren, Esquire · ATTY I.D. NO. 0~302 10~0 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-~82-6900 . Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff V& Darrell R. Goodrich 332 Old Stonehouse Road Boiling springs, PA 17007 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS ~ CIVIL DIVISION -Cumberland County 'MORTGAGE FORECLOSURE ' NO. 01-1814 civil AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, 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- 332 Old Stonehouse Road, Boiling Springs, PA 17007. 1. Name and address of Owner(s) or reputed Owner(s) - Name Address Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment- Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property' Name Address Monroe Township 1220 Boiling Springs,Mechanicburg, PA 17055 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, 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 Tenant s/Occupant s 332 Old Stonehouse Road Boiling Springs, PA 17007 DATED- May 14, 2002 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 f ication to authorities. & ASSOCIATES J. Udren, SQ. orney for P1. .ntiff MARK J. UDREN & ASSOCIATES BY'. Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, 'COURT OF COMMON ' CIVIL DIVISION Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 ATTORNEY PLEAS : Cumberland County ' MORTGAGE FORECLOSURE Plaintiff . Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De f endant ( s )' : NO. 01-1814 civil FOR PLAINTIFF ~RIFF ' S S~J~~'&L PROP~ TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 4, 2002, at 10-00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~OF OWNEr'S RIC6~TS Y~OU MAY BE ARLE TO~RREVF. NT THIS S~.RIFF'S SAL~ To prevent this Sheriff's Sale, you must take /~te 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 cal 1: /~56 ) 482 - 69_0_0_~ 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. ) ~ MAY_~/T~LL BF~BLE~TO S~RTy AND YOU~HAVE OT~F~ EVEN IF THE SH_~IFF,S SA~.~ ~ 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 qives a deed to the buyer. At that time, the buyer may bring legal proceedings to evic~ you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~0 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER I~EFE~ SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 MARK J. UDREN & ASSOCIATES BY.- Mark J. Udren ATTY I.D. NO. 04302 1040 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-~82-6900 Wells Fargo Home Mortgage ' Inc. ' 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS . CIVIL DIVISION - Cumberland County Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 De fendant ( s ) · .. . NO. 01-1814 Civil AFFIDAVIT OF SERVICE PURSU~ 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". Dated- August 12, 2002 All Notices were served within the time l~its set forth by Pa Rule C.P. 3129. This Affidavit is made subject to~~ l~ies . relating to unsworn falsification ~ties.Of 18 Pa.C S. Section 4904 MAR . UDREN & ASSOCIATES Mark J. Udren, Esquire -- Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY.- Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803~ 856-~82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff v. Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) ATTORNEY FOR PLAINTIFF · i COURT OF COMMON PLEAS ..: CIVIL DIVISION i Cumberland County i MORTGAGE FORECLOSURE _- . .- ..-' NO. 01-1814 Civil _- . _- _- . AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, 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- 332 Old Stonehouse Road Boiling Springs, PA 17007. , 1. Name and address of Owner(s) or reputed Owner(s) - Name Address Darrell R. Goodrich 1225 Peffer Road, Mechanicsburg, PA 17055 2. Name and address of Defendant (s) in the judgment- Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property- Name Address Monroe Township 1220 Boiling Springs,Mechanicburg, PA 17055 every mortgage of 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 "Addre s s Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale- Name Address Tenant s / Occupant s 332 Old Stonehouse Road Boilin9 Springs, PA 17007 DATED- August 12, 2002 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 are of 18 Pa.C.S. sec. 4904 relatin9 to unsw~r~falsification to authorities. & ASSOCIATES ~ark ~ren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage Inc. ' 5024 parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant (s) DATE- June 5, 2002 ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS .: . .-: CIVIL DIVISION : .- : Cumberland County . · ~ NO. 01-1814 Civil .- : .- . TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF,S SALE QF_REAL pRQp~ OWNER(S): Darrell R. Goodrich PROPERTY: 332 Old Stonehouse Road, Boiling Sprin~s, PA 17007 Improvements: RESIDENTIAL DWELLING The' above captioned property is scheduled to be sold at the ~-county Sheriff,s Sale on ~4' 20~, at 10:00 AM, at the Commissioners Hearing Room, 2nd Fl, 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. n-_co DE]DE] LLI OwZz Wells Fargo Home Mortgage, Inc. VS Darrell R. Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1814 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2002 at 9:10 o'clock AM, she served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Darrell R. Goodrich, by making known unto Darrell R. Goodrich personally, at 1225 Peffer Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and cq~rrect copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2002 at 9:30 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and' Description, in the above entitled action, upon the property of Darrell R. Goodrich located at 332 Old Stonehouse Road, Boiling Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Darrell R. Goodrich, by regular mail to his last known .address of 332 Old Stonehouse Road, Boiling Springs, PA 17007. This letter was mailed under the date of July 10, 2002 and never returned to the Sheriffs Office. Sworn and subscribed to before me This~ day of 2002, A.D. Prothonotary R. Thomas Kline, Sheriff Rca~-ta e~D~puty - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS' I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Home Mtg Inc is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 29th day of May, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 1814, at the suit of Wells Fargo Home Mtg Inc against Darrell R Goodrich is duly recorded in Sheriff's Deed Book No. 253, Page 3689. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A.D. 2002 day of ecorder of Deeds Wells Fargo Home Mortgage, Inc. VS Darrell R. Goodrich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1814 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2002 at 9:10 o'clock AM, she served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Darrell R. Goodrich, by making known unto Darrell R. Goodrich personally, at 1225 Peffer Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said tree and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2002 at 9:30 o'clock A.M., she posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Darrell R. Goodrich located at 332 Old Stonehouse Road, Boiling Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Darrell R. Goodrich, by regular mail to his last known address of 332 Old Stonehouse Road, Boiling Springs, PA 17007. This letter was mailed under the date of July 10, 2002 and never returned to the Sheriff's 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, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren for Wells Fargo Home Mortgage, Inc. It being the highest bid and the best price received for the same Wells Fargo Home Mortgage, Inc. of One Home Campus, DesMoines, IA 50328, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $689.63, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 13.52 Posting Handbills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 8.28 Certified Mail 2.28 Levy 15.00 Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 20.00 256.10 193.75 25.20 25.00 29.50 $ 689.63 paid by attomey 9/19/02 Sworn and subscribed to before me This 9 ~ day of ~eZg9~..., 2002, A.D. ~n~._a ~-~~~ ~r6thonotary R. Thomas Kline, Sh6riff Real Estat~ Deputy MARK J. ,UDREN & ASSOCIATES BY: Mar.k J. Udren, Esquire ATT~' ~.D. NO. 04302 1040 N. KIN~S HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home M0rt~a~e, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff V~ Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Defendant ( s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION 'Cun~erland County - MORTGAGE FORECLOSURE 'NO. 01-1814 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Well~ Fargo Home Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for th~ Writ of Execution was filed the following information concerning the real 'Property located at- 332 Old Stonehouse Road, Boiling Springs, PA 17007. 1. Name and address of Owner(s) or reputed Owner(s) · "Name Address Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 2. Name and address of Defendant (s) in the judgment- Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold- Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record- Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property- Name Address Monroe Township 1220 Boiling Springs,Mechanicburg,._.PA 17055 0 6. 'Name and address of every other person who has any record interest in the proPerty and whose interest may be a~Eected by the sale Name~ . Address Real Estate Tax Dept. i Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover'St., Carlisle, PA 17013 Commonwealth oE PA, Bureau o~ 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 Tenant s / Occupant s 332 Old Stonehouse Road Boiling Sprin~s, PA 17007 I yerify 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 f ication to authorities. DATED- May 14, 2002 \ \ \ & ASSOCIATES J. Udren, ',SQ. torney for P1 .ntiff · MA~ J..,UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 0~302 10~0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-~82-6900 Wells Fargo Home Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS CIVIL DIVISION ~ Cumberland County m - MORTGAGE FORECLOSURE Vm Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 m m 'NO. 01-1814 Civil Defendant (s)' NOTICE OF SHERIFF'S SAT.~. OF ~RA?. PROPERTY TO: Darrell R. Goodrich 332 Old Stonehouse Road Boiling Springs, PA 17007 Your house (real estate) at 332 Old Stonehouse Road, Boiling Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on September 4, 2002, at 10-00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $83,301.57, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER, S RIGHTS YOU MAY BE ARLE TO PREVR. NT THIS SHERIFF, S 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) 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. ) IOU MAY .SdTJJJ~_~ .AB~_L.~ SAVE YQIIR PROPERTY AND YOU ~AVR. OTHW. R RIGHTS EVeN IF THE SHERIFF'S SA?,E DO~.S TAK~_ P?.~C_. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to 'set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will 9o 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 Sherif~ 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, ~0 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue C~arlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN TRACT OH PARCEL OF LARD AND. PPJ~M. ISES, SITUATE, LYING AND BEING' IN THE TOWNSHIP OF MONt~OE IN THE CO.UN~Y OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MOP~E PA~TI~LY-DESCaIBED AS "FOLLOWS: BE.GINNING AT .A POINT IN 'THE CENTER OF MAIN STREI~T, SAID POINT BEING. 58 FEET F~OM · . THE BUILDING LINE- OF CHURCH" 01~ WATER S'TI~E~T; TH~NC.E ALON~ LANDS NOW OR FORMERLY OF A.S. BLACK ,AND DO.RORTHY I. BLACK,' HIS WI'FE, SOUTH 77 DEG~J~ES 3:0 MINUTES W~S'T, 66.5 FEET TO .AN II, ON PI~E; THENCE' BY THE SAME, NOH.TH 115 .DEGP, E~S 45 MINUTES WEST, 65 FEET TO AN I~tO'N PIPE'; THENCE BY THE SAME, NO~TH 7.0 DEGItEES .30 MINUTES EAST', 6'1.8 FEET TO · A POINT IN THE C.~'TE~t O.F SAID MAIN STPJEET; THENCE BY THE CENTE~t 0.F SAID MAZN .STI~EET, SOUTH 1'6 DE~EES 45 MINUTES EAST, 73 FEET TO A POINT, THE PI, ACE OF BEGINNING. CONTAINING 4., 780 SQUARE FEET AND HAVING .THEREON ERE~ A FRAME DWELLING HOUSE, BE.I.N~ NUMBEHED AS 332 .OLD S'TONE~OUSE HOAD, BOILIN~ SPI~IN~S, PA. BEING KNOWN AS- 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 PROPERTY ID NO.- # 22-28-2401-015 TITLE TO SAID PREMISES IS VESTED IN DARRELL R. GOODRICH, SINGLE INDIVIDUAL BY DEED FROM MAXINE A. KLINEDINST DATED 12/23/99 RECORDED 12/29/99 BOOK 213 PAGE 1132. WRIT OF EXECUTION and/or ATTACHMENT ,..: .COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1814 Civil CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From DARRELL R. GOODRICH, 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007 (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 $83,301.57 L.L. Interest FROM 6/7/01 TO DATE OF SALE SEPTEMBER 4, 2002 - PER DIEM ~$16.32 - $7,425.60 Atty's Comm % Atty Paid $397.43 Plaintiff Paid Date: MAY 29, 2002 REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Due Prothy $.100 Other Costs CURTIS R. LONG Prothonotary, Civil Division Real Estate Sale # 33 On May 30, 2002 the sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as 332 Old Stonehouse Road, Boiling Springs, and. more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date' May 30, 2002 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA · COUNTY OF CUMBERLAND · SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. REAL ESTATE SALE NO. 33 Writ No. 2001-1814 Civil Wells Fargo Home Mortgage, Inc. VS. Darrell R. Goodrich Atty.: Mark Udren ALL THAT CERTAIN tract or par- cel of land and premises, situate, ly- ing and being in the Township of Monroe in the County of Cumberland and Commonweath of Pennsylvania, more particularly described as fol- lows: BEGINNING at a point in the cen- ter of Main Street, said point being 58 feet from the building line of Church or Water Street; thence along lands now or formerly of A.S. Black and Dorothy I. Black, his wife, South 77 degrees 30 minutes West, 66.5 feet to an iron pipe; thence by the same, North 15 de- aree,.q 45 min~t..e.s We.qt. 65 feet to SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST, 2002_ ! THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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 t° 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 23rd and 30th day(s) of July and the 6th day(s) of August 2002. 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 'i~~_. ............... co.¥ ;;' ...... ......... ;;'; ;Y comNmiOssTo~~~lr~~J~~:~, 2006 REAL F,~rATE 8ALE..No, 33 · ~ Writ No. 2001-1814 · CMl Term ~111 Flrgo Home Darrell FI. DESC'~ON. ALL ']3-IA? C'ER1'A]N tmct~ or'~.], of land arid p~mi~, situate, l:)~ng and bdn8 in the ']'owmhip of-' Monroe. ia the CoLmt), o~ (3Jmba'lud and Commonwealth Of Pams~lvuja, mom ~az']), cl~becl u follows: ' BF.,6~O at a point in' tl~ c=at~ of Main · ,S. tr~t,. ~d IX)iht !~ing _58 feet_from tl~ building ~m~ ot c:nurch or Wata' Strut; ~ along lands now or forma'ly of A.$, B~k and I)om~y'I.. Black, his wife, g)uth 77 dqg~ 30 minum · mt, ~ fm to an'iron aam~ north 1~ (~ 45 minum ~iq0~'30 ainum ~ 61.8 ~m' of ~d Main Sam;.. tlm~ by fha a~n~ of CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 192.00 $ 1.75 $ 193.75 Publisher's Receipt for Advertising Cost &aid Main' St~.t, re.th 16 dngra= 45 minum .CONT~omt'73feett°aF)int"theplace°fl}EalNNINa'4,780-atttam ~ and having ~'' publisher of The Patriot-News and The_ Sunday Patriot-News, newspapers of general ' ~__~...=~!~l..___a ~ dwelling houm Ix, ing ge receipt of the aforesaid notice and publication costs and certifies that the same have peen au~y I~ai'a. ' ...... ~ ~TATE SAL~ NO. 33 Writ No. 2001-1814 Civil Wells Fargo Home Mortgage. Inc. VS. Darrell R. Goodrich Atty.: Mark Udren ALL THAT CERTAIN tract or par- cel of land and premises, situate, ly- hug and being in the Township of Monroe in the County of Cumberland and Commonweath of Pennsylvania, more particularly described as fol- lows: BEGINNING at a point in the cen- ter of Main Street, said point being 58 feet from the building line of Church or Water Street; thence along lands now or formerly of A.S. Black and Dorothy I. Black, his wife, South 77 degrees 30 mutes West, 66.5 feet to an iron pipe: thence by the same, North 15 de- grees 45 minutes West. 65 feet to an iron pipe; thence by the same, North 70 degrees 30 minutes East, 61.8 feet to a point in the center of said Main Street; thence the center of said Main Street. South 16 de- grees 45 mutes East. 73 feet to a point, the place of begirmtng. CONTAINING 4.780 square feet and having thereon erected a frame dwelling house, being numbered as 332 Old Stonehouse Road, Boiling Springs, PA. BEING KNOWN AS: 332 OLD STONEHOUSE ROAD, BOILING SPRINGS, PA 17007, PROPERTY ID NO.: #22-28-2401- 015. TITLE TO SAID PREMISES IS VESTED IN Darrell R. Goodrich, single individual by Deed from Maxine A. KJinedinst dated 12/23/ 99 recorded 12/29/99 Book 213 Page 1132,