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Home My WebLink About01-2537MARK J. UDHEN & AHSOCZATES EY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. EING8 NZGEWAY, SUITE 500 CKERRY HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff Vo Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAZNTIFF :COURT OF COMMON PLEAS i CIVIL DIVISION : :Cumberland County COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPn TO YOUR LAWYn AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE OFFICE SET FORTE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte to,ara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere clue usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVEESTA D~%I~DA A UNABOGADO ZMMEDIATAMENTE, SZNOTZENEABOGADO 0 SZ NO TIENE EL DINERO Bu~ZCZ~NTE DE PAgAR TAL SERVICZO, VAYA EN PERSONA 0 LLAME ~OR TELEFONO A LA OFZCINA CUYA DZHECCZON BE ENCUENTRA ESC~tITA ABAJO PAPA AV~EZGUAH DONDE SD PUEDE CO~SEGUZ~ ASZST~NCIA LEQAL. 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 ora judgment against you, and marl it to you. If you do not dispute the debt, it is not an adnfission 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 marl it to you. Once we have marled 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 u debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments= Assignor: United Companies Lending Corporation Assignee: Bankers Trust Company of America of California, NA Recording Date: 10/21/97 Book: 560 Page= 27 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 288 Meadows Road MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 4/19/96 DATE RECORDED: 4/25/96 BOOK: Lower Mifflin Township 1315 PAGE: 1101 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 bysaid Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 3/14/01: Principal of debt due and unpaid Interest at 12.65% from 4/1/00 to 3/14/01 (the per diem interest accruing on this debt is $16.71 and that sum should be added each day after 3/14/01) $48,215.70 5,808.20 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $61.09 and that sum should be added on the first of each month after 3/14/01) 303.71 Late Charges (monthly late charge of $5.00 should be added on the fifteenth of each month after 3/14/01) 15.00 Suspense Balance Recoverable Balance (423.12) 501.00 the mortgage documents and Pennsylvania law, Attorneys Fees (anticipated and actual to 5% of principal) 2~.79 TOTAL $57,361.28 The attorney,s fee set forth above are in conformity with and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $57,361.28 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark~J.//Udren, ESQUIRE MARK J. UDREN &ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 A~L THAT CERTAIN PIECE 0F LAND HITUATE IN LOWER MIFFLIN TOWNSRIP, COUNTY OF CUMBERLAND AND 0TATE OF PENI~SYLVANIA, BOUNDED AND DESt".RXEuT~ A~ FOLLOWS, TO WIT: BEGINNING AT A POINT II~ THE C~'J~TER LINE OF TOWNHHIF ROAD T-'418, ON THE LINE OF LAND NOW OR FOILM~mT.T OF WILLY. AM C. ROHTBNBAUDER; THENCE ALON~ THE C~TER LIN~ OF 0AXD TONNSRIP ROAD, SOu'£~ 11 D~RERS 11 MINUTES 47 SECONDS EAHT, & DISTANCE OF 133.28 FEET TO A 8~IER; THENCE ALON~ THE HAME, SOu'z'n 11 DR~U~L'Wq 27 llllu'rfS 17 SECOEDS EAST, A DISTANCE OF 46.82 THET TO A 8PINE; THNN~E'ALO~ LAND NOW OR FOHM~T.y OF RAI~f.-ONO M. ~m'&'~,SON, ET UX, SOUTH 54 D~umES 33 MINUTES 45 SECONDS NEST, A DISTANCE OF 185.78 FEET TO A POINT; THENCE ALON~ ~'~LtsR LANDS NOW OH FOUle~u~r.~ OF RA~MOB~ M. PETERSON, ET DX, NORTH 40 DEGDuuS 31 MIHu'~'EH 39 SECONDS NEST, A DISTANCE OF 147.73 FEET TO A POINT; THENCE ALOH~ THE LAND ~ OH FORMERLY OF WILLIAM C. KOHTENBAUDER, NOiLTH 50 DEgRA'ffH S7 MINUTES 45 HECONO5 EAHT, A DISTANCE OF 273.18 FEET TO THE Cn-~-2sA LINE OF TOWNSHIP ROAD T-418, THE PLA~E OF B~XNNIH~. CONTAIN'&R'G 0.8131 ACNES. DATE: March 14, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thin in nn official notice that the mort_n~_p, on your home ill in default: and the Ipnflpf intendn to fflreelone. ~.~fle information chant the nnhtre of the default in .nrovidorl in thp The HOMEOWNER'S MORTGAGE A~I~/TANCE PROGRAM .~IF~MAP) may be nm~ to hel.n to nnve your home. Thin Notice eT.nlninl how the pro_cram wnrkm_ To nee if flEMAP eau hal.n: you m,,mt MI/~F.T WITH A CON~/UM~.I~ COIJ-NSI~LING A~ENCY WITHIN 30 DA¥~ OF Tl~ DATE OF TflI~ NOTICE. thin Ntlfiee with yeu when you m~t with the Connialina_ A_ap. ney. The nimt. eddr~H nad .shone nnmher of (qfln~Hmpr (~ll~dJt (~ounnplina_ A~n~i~ se~n~ your Cfln~ n~ Iil~d it ~e end ~in Notice. If you hn~ ~y ~lUpEflflnl: yOU miy ~ll' thp Pennsyl~nin Houtin~ ~nnn~ A~pn~ ~ll ~e it 1~Ofl-M2-2~97. ~e~flne ~ hee~n~ enn ~1 (71~ This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DEl/ECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM~ EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DEl/ECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Mil.finish I._ NEInlGH ~O~R~D~SS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: UNITKD C~MPAN]I~.~ L~NDIN~ CORPORATI'ON ~M~ M'I~R'I~.A~II CORPORATION HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAV RE ELIGIRLE FOR FINANCIAl, ASSISTAN~ WHICU CAN fiAVE YOUR HOME FROM FORECLOSURE ANl~ HELP YOU MAKI~ FUTURE MORTGAGE PAVMENTfi IF YOU COM~LY Wrl'H Tug PROVISIONS OF T~I~ HOMEOWNER'S EMI~RGENCY MORTGAGE ASSISTANCE ACT OF 1983 ~ "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING~ ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTEm. R ELIGIBILii'~ REQUIREMENTS ESTABLISHED BY PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSI~I~. -- Und~ &e A~ ~ ~ ~fifl~ to a t~ s~v of ~Io~ on ~ m~,~ ~ (30) da~ ~ ~e ~(e of ~s Notice. ~g you ~ust ~ ~d a~ a ~a~to~hce" m~g ~ one of~e ~ns~ ~t ~eling ag~es hs~ at ~e ~ of ~lS Notice. ~I~ ~T~ ~RT OC~R ~ T~ N~ (~0) DAVS. IF YOU DO N~ APPL~ FOR E~RG~ MOR~AGE ASSISTANCE. ~OU MUST HR~G YOUR MORTGAGE UP TO DATE. ~E PART OF ~IR NOTICE CALLED "HOW TO CURE YOI~ MORTGAGE D~FAUL~': E~LA~ HOW TO ~OUR MORT~AG~ ~ TO CONSUMI~.R CREDIT COIINSF. I,1NG ACENCIR..~ -- If~u m~ x~ one of ~t co--cling ag~ci~ list~ at ~e ~ of~is nofi~,~ l~d~ ~nav NOT ~e ~ f? ~ (30) ~ a~ ~ ~te o!~s m~. ~~% ~d ~l~hnne orflesl~at~ ~nmlm~ ~t ~selln~ ~e~ ~ the ~nn~ in which the nm~ ~ s~ fo~ at ~e ~d afros No6~ l~is o~y n~s~ m s~h~ule one ~-f~e m~ng AO~ yo~ l~d~ imm~stely ofy~ ~nt~fions. ' APPLICATION F~R MO.RT..GAGE ASSI.~TANCK -- Your mortlage is in default for thc .repons s?_f .o~. l_a_tcr in, this N.otice (see following pages for specific in~rmafion about the natur~ ~yo.? cietault.) If you nave hied. and are_unable to r~solve this problem with the lender, you have me nght to apply for financial asszstance titan the Homeowner's Emergency Mortgage Assistance Pm.gram. ..... _To do so,. you. must fi!l out, sign and file a completed Homeowner's Emcig~ ,A. s, si.smn..,cc l-ro, gra~,, .ADpl.l?atio.~n ,with one of thc d.?lgnated.consumor credit counseling agencies nsxea at me ,m,,o ormz.,,s l~o. uce..omy .con.s~n. er creolt counseling al~encies have applicati.ons for the ~t~. gram .aha mey ,w},li ass,st~.ou m submitting a complete applicatton to the Ponnsylvama Housing r_lnance Agency. lrour application MUST be filed or poshnarked within thirty (30) days of your lace- to-face meeting. YOU MI/ST FILE YOUR APPLICATION PROMPTLY. IF YOU FA]T, TO DO SO OR IF YOU DO NOT FOLLOW ~ Olll'l~R TIME PERIODS SET FORTH lIN THiS LE'rrr~R, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE W~.I. BE DENIED. Page 2 of 6 AC. ENCY ACTION -- Available funds for emergency mortgage assistsnce are vel~' limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Fi-,nee Agency has sixty (60) days to make a decision et~er it receives your application. During ~hat time, no fo~closure proceedings will be pumuxl agaimt you if you have met the time requinunents sci forth above. Yon will be notified ~y by the pennsylv:mis Ho,~inS Fi~.nee Agency of its decision on your application. NOTE: IF YOU ARE CURRF2WI'LY PROTECTED BY THE ~'ILING OF A PEtiTiON IN BANKRUFrCY, THE FOLIA)WING PART OF Tills NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN A'i-i's:MPT TO CO1 ,I.~..CT TH s: DEBT. (If you have fled bankruptc~ you can still apply for Emergency MoFtpge Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin~ it up tn date). NA~ GE TI~ DEl:AULT -- The MORTGAGE debt held by the above lender on your properly located at: ilia Mp. sdnwS J~nsd Newville: PA 17~.41 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: -- Mflnthly pt.vm.n*m of $'/35.90 for Moy :2000 throu_ah Mirth 200! = .q8:1 Mfinth~ Iot~ PhsT~_e of ~q_llfl for Mo.v :2000 throu~ah l:ebruo~ 2001 = $1 Otber charl~ (explain/itemize): Escrow tdvsne~ = Sni.n~.ns~ Imlsne~ = TOTAL AMOUNT PAST DUll: s#:OOl,Ag B. YOU HAVE FAILED TO TAKE ~'FOLLOWING ACTION .ff)o n~ use if not appllcnhle): N/A HOW TO CIJI~ ~ DEFAULT -- You may cu~ the default within THIRTY (30) DAYS of thc date of this notice BY PAYING'i'"~. TOTAL AMOUNT PAST DUE TO TItE LENDER, WHICH IS $ ~ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURIN(} THE THIRTY (30) DAY PERIOD. Ps.ymca* must he msd~. ~ith~- by ,.Ash: enabler's ohk,4r, cerlifi~vl nh~lr or m~y. ~'der mst~ .tmyshle Mark J. lldre~ & Associates 10dO N. Kin_os MiaJtwty.. ~luite SOO Ch*try Mill: NJ 080~4 You can cure any other default by taking the following action within THIRTY 00) DAYS of the date of this letter: (Do not use if not a.m)licable.) N/A Fl? YOU DO NOT CURE TI~ DEFAIN~T -- If you do not cure the default within TH~TY 00) DAYS of the date ofthi~ Notice, the Ipnder int~nd~ tn exereise its rlahl~ tn accelerate the mort~_a_ee dehL This means that thc entirc outstandillg b.lsnce of this debt will be considered due ;mmediately end you may lose the eh.nce tO pay the mongege in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends tO instruct its attorneys tO start legal action tO fopuPInse u.n~n your mnfr~m~ _~1 Page 3 of 6 IF THE MORTC. AC.I~I Ii FORRCLO,qEll UPON - The mortgaged property will be sold by the Sheriff to pay off the mo~gaga debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal pwceedings against you. you will still be required to pay the reasonable attorney's fees that were actually inoun'ed, up to $50.00. However. if legal proceedings ate started against you. you will have to pay all reasonable attorney's fi~es actually incu.n~i by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other re/~on~ble en~. ~.~u em~ th~ d~ulf Wil~in the TI~TY (.3fl) DAY .~i~, i~. ~rm wIH nnt h~ e~q. uleed OTIS-3/LENDER REM~DII~q -- The lender may alsu sue you pan~m,lly for thc unpaid principal b~l,nce and all other sums due under the mortgaga. If your debt has been ciischarl~l in benk~ptcy withou~ your havin~ renffixmed it, then lender c~ot pursue this remedy. RIC'.HT TO CI trial TI:fi[ DKI~'ATff,T PRIOR TO ~R~'~ ~AI,~ -- If~ ~ve n~ ~ ~e de~t wi~ ~e ~ (30) DAY ~ ~d f~ ~ ~ ~ ~u ~ili ~ ~e d!ht ~ ~ · e ~,lt ~ ~ the ~e at ~y ~e u~ ~ ~e h~ ~ the ~h~ ~1~ Y~ m~ ~ ~ ~ ~n~ · e to~l nmmmt th~ ~t d~ ?u~ ~y ln~ nr oth~ ch~ ~ du~ ~nnhle ~t~ F~ ~d ~ ~n~ ~th the fa~lol~ =]e ~d ~y nth~ e~t~ ~n~ ~ ~e ~h~ g~e ~ ~ifi~ ~ ~tln~ ~ the I~d~ ~d hy ~a~in~ ~y ~h~ ~ni~t~ und~ &e mo~e. C~ yo~ ~a~ ~ ~e ~ ~ b~ ~ thh nofl~ ~ ~ yo~ mo~e ~ ~e ~m~a ~s ff~u ~d ~ ~u~ed. i~,ART,II~,,~T Po.~gml'.K SI:I~.RIFI~'~ ,qAT,K DATE -- It i.~ e~Jmated that the earliest date that such a Sbedff's Sale of the mortgaSed property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date oftbe Sheriff's Sale will be sent to you before thc sale. Of course, the ~mount needed to core the de/ault will increase the longe~ you walt. You may find out at any time exactly what the required payment or action will be by contacting thc lender. HOW TO CONTACT THR LENDER: N~m~ of T.pndpr/ger~4e~r: Addre~n: phflne Nnmh~ Fnx Number: ~an~et Permn.. EMC Mnrt~_*a_e 909 Midd~n Ridlre l)rlv~ ~ulh~ 200 Irving: TX ?S0~ N/A C'%~t~mer Servlee I~.gFEcYr OF RI~I. RIIi~,~ NAT.V. -- you should realize that a Sheriff's Sale will end your ownership of the mortised pwpen'y and your righI to occupy ik If you continue to live in the property al~er the Sheriff's Sale, a lawsuit to remove you and your fumishings and other belongings could be stamxl by the lender at any time. A.qS~ON OF MORTGAGE -- You may or X may not (CHECK ONE) sell or transfer your home to a buyer ur Wsusferee who will a~ume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requh~nents of the mortgage are satisf~d. Pa~e 4 of 6 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 ora judgment against you, and mail it to you. If you do not dispute the debt, it is not on admission of liability on your po.rt. Also, upon your.written request within the 30 day period, we will provide you with the name and address of the original cr~. ito. r if different from the eurcent 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 marl 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 SO0 Cherry Hill, NJ 08034 (8S6) 482-6900 Paoe 5 of 6 YOU MAY ALgO I:IAV~K ~ RII~ITT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CU~];D BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTOP~n TO THE SAME POS'ITION AS IF NO DEFAULT HAD OCCUI~];r~, W YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN ~ TIMES IN ANY CALENDAR Y~a~) TO ASSERT THE NONF2GSr~CE OF A DEFAULT IN ANY FORECLOSURE PROCF. RDING OR ANY 6THER LAWEU1T INSTI'rD'rP2) UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BEI.~VE YOU MAY HAVE TO SUCH ACTION BY ~ LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONNUMF. R f~Rl/.rlrr COUN~I~.I,ING A/2~NCll~.R gV. RV]Nt4= ¥(~UR COUNTY ( ~11 in a !i~ ~f ail Caun.e~lin~_ Affand~e liet~d in A.~p~ntlte ~.. FOR T~IE CUMRRRLAND COUNTV CCCS of Western Pennsylvania, Inc. 2000 Lin~lestown Rend Harrisburg, PA 17102 (717) $41-1757 FAX (717) 541-4670 Financial Coun~ling Servic~ of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolimn Hnn'isbu~ N. 6th Street Harrisburg, PA 17101 (717) 234=5925 FAX (717) 234=9459 Community Action Corem of I~e Capital Region 1514 Deny Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234=2227 Adan~ County Housing Authority 139-143 CarUsle St. Gettysburg, PA 17325 (717) 334=1518 FAX (717) 334=8326 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Pag~ 6 of 6 ~eoo oo~o ooo~ ~OE ¶TEE :T.I ~i~OO onto BDO& !" V..E_R~L F I.p.~a~T_.I~O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source.of his. information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein, is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE MA~K J. UDREN & ASSOCIATES SHERIFF'S RETURN - CASE NO: 2001-02537 p COMMONWEALTH OF PENNSYLVANIA: COUNTy OF CUMBERLAND EMC MORTGAGE CORPORATION VS NEIDIGH MILDRED L REGULAR BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NEIDIGH MILDRED L the DEFENDANT at 45 1/2 S EARL ST , at 0014:58 HOURS, on the ~5th day of May APT 5 SHIPPENSBURG, PA 17257 MILDRED L. NEIDIGH by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with , 2001 and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 12.40 Affidavit .00 Surcharge 10.00 .00 40.40 Sworn and Subscribed to before me this 23~ day of / ~Prothonotary ' So Answers: · Thomas Kline~ - 05/16/2001 Deputy Sheriff MARK j. UDREN & ASSOCIATEs BY: ~rk J. Uc%ren, Esquire ATTY I.D. NO. 04302 1040 N. EIN~s HIGHWAY, SUITE 500 CHERRy HILL, NJ 08034 8~6-482-8900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff ATTOI~qEy FOR PLAINTIFF 'COURT OF CO~ON PLF~s ~ CIVIL DIVISION :Cumberland County ~ MORTGAGE FORECLOsURE Mildred L. Neidigh : P.O. Box 440 ~ NO. 01-2537 Shippensburg, PA 17257 Defendant (s) : PRAECIpE FOR JUDG~NT FOR FAIL, To TO THE PROTHONOTARy: Kindly enter judgment in fay , Defendant(s) for ' , or of the · within 20 ~=.-- ~- fallur~ to file an Answe Plalntl~f and against th mort a~ed ~f~m service thereof ,~ ~_~ ~ to ?lalntiff,s C m~,~ As set forth in Complaint Interest Per _. Complaint $57,361.28 From 3/15/01 to 8/27/01 2,773.86 Late charges per Complaint From 3/15/01 to 8/27/01 EScrow Payment per Complaint From 3/15/01 to 8/27/01 30.00 TOTAL D _ I hereby certes. ezendant are as sho~n_.a,t_ (1)_.th.e. addresses of · . accordance with Rule 2_~ . ~v_=, an~(2; that n ~-- ~the .Pla~ntaff .... ~, ~ co~ o~h~.~ , nas been =~v.. Att~ey for ~laintiff D~GES ~E H~By ~SESS~ and in MARE J. DDREN& &SSOCZ&TEB BT~ Mark J. Ud~en, Esq'ul~e N. EIGB,,&T. SUITE SOO ~,a¥ EZLL, NJ 08034 ~56-482-6900 EMC Mortgage Corporation 909.Hidden Ridge Drive, Suite 200 IrVing, TX 75038 Plaintiff Mildred L. Neidi-h s. E rl Street, A t. ~nxppensnurg, PA 17257 Defendant(s) DATED: July 31, 2001 TO: Mildred L N~8~--h Shippensburg, PA 172~t 5 ATTOrNEy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-2537 DEBIDADENTRO DE UN ~= CASo AL NO TO 0 LA EL TRIBUN TERMINO DE DIEZ (10 D ' MAR LA ACCION PEP, DER Ev~--~.~/~9~· DICTAR SENTENCIA ~,%TC~.J~~m EN CORTE 0 ~,~o x VTROS DERE ~, ou ~um'A'~(A, USTE NOTIFICACION a ~ a~,~--- - CHOS, IMPORTANTE D PUEDE 0 ~ ~" ~ I~EDIA S. DEBE LLEVAR ES SI NO TIENED TAMENTE SI US TA INERo SUFICI TED NO TIENE O LLAME PO ENTE PARA TAL SE ABOGADO, R TELEFONO A LA RVICIO, VAYAEN ESCRITAABAJO OFICINA, CUYA DI PERSONA UE ....... -uUIRASSISTENCIA SERVICIO DE REFERENCIA LEGAL CumbL~.WY~R REFERRAL SERVICE erlanu qounty Bar Association 2. L~bertyAvenue Carlisle, p~ 17013-3387 717-249-3166 or 800-990-9108 NOTICE= P~SUANT TO TEE FAIR DEBT CO LAW FIHM IS DE LLECTZON p ~ TO BE A DE~T ~ACTICES ACT ~OLLECT A DEBT. ANY ZNF COLLECTOR A~D T~ZS IS AN , TEZB SUPPOSE. O~NATZON OBTAINED ATTemPT TO WILL BE USED FOR THAT C~ L~.WY~R REFERRAL SERVICE umoerlan~d.C.o, unty Bar Association z. ~lnerty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 YOU ARE IN DEFAULT BECAUSE YOU HAVE APPEARANCE PERSON ____ FAILED TO ENTER A WRITTEN ALLY OR BY ATTORNEy AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH A~AINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A J~MAy BE EN~'=P~EDAGAINST YOU WITHOUT A HEARIN~ANDYOUMAY 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, C4D TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEgaL HELP. HT: Mark j. Udreno Hsquire A??¥ I.D. NO. 04302 amy HILL, NJ 08034 ~56'482-6900 EMC ~gage. Corporation 909 laaen Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant (s) ATTOrNey FOE P~AZ~TZFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-2539 AFFIDAVIT OF NON-MILITARy SERVICE COUNTY OF : SS : THE UNDERSIGNED duly sworn, de.pose.s and says ~hat th- averments herein baerien~b :~ asea up.on .~nvestlgatlons ,.~..~_ _ ~- .= maintained by us e~cner as Plm~ __ . ,...=ut unu recoras P.la.intiff herein ~.~ ~ .... ~ uz as servlclng agent of the Military or ~,___~-T' ~-.~,a~. one anove Defenda~-~ . ~. -, ,,.=v=z ~ervlce of the --~ = - -,~ are not in the ?~-s as defined in the Soldie~- -~-~, as ~ended, and ~ emplo~ent ~ --_= - - ~"~ u~e age ~d 1~-~ ~-- 7~ ~uu oz ~--- ~ ==un uezendant are as follo~~ ~u~ residence and Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Mildred L. Neidigh Over 18 As captioned above Unknown Over 18 As captioned ahoy. Unknown Titl, Comp~ MARK j. DDHEH & ASSOCIATES BY: Mark J. Udren, EsqUire ATTY I.D. NO. 04302 1040 N. KIN~s HIGHWAY, SUITE 500 C~ERRy HILL, NJ 08034 8~6-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 ATTORNEy FOR PLAINTIFF :COURT OF CO,oN PLEAS : CIVIL DIVISION :Cumberland County ~ MORTGAGE FORECLOSURE : :NO. 01-2537 : Defendant(s) TO: Mildred L. Neidigh 45 ~ S. · Earl Street, Apt. Shlppensburg, PA 17257 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. x_ Judgment by Default Prothonotary _ 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 CONCEI%NING THIs NOTICE PLEASE CALL: At this telephone number:~ ~ MA~K J. UDREN & ASSOCIATES EY~ Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COF~4ON PLEAS [ CIVIL DIVISION · Cumberland County MORTGAGE FORECLOSURE Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant (s) NO. 01-2537 PRAECIPE FO~WI~IT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From AUg~ to Date of Sale Per diem ~$16.71 (Costs to be added) ~rk J. Udren, ESQUIRE A~ORNEY FOR pLAINTIFF ALL THAT CF~tTAIN PIECE OF LAND SITUATE iN LOWEE MXFFLIN TOWNSEIP, COUNT~ OF CUMB~?.~ND AND STATE OF p~SYLV~, BO~ ~ DESC~IB~ ~ FOLLOWS, TO WIT: BE~I~i~ AT A POINT IN ~E ~ LI~ OF TO,SHIP ~0~ T-418, ON ~E L~ 0F ' NOW O~ FO~Y OF WILL~ C. KOST~ ~CE ~ONG ~E C~ LI~ TO,SHIP ~O~, SOuwn 11 DE~ES 11 MI~uwmS '47 SECO~S ~T, A DZST~CE OF 133.28 FEET TO A S~iKE~ ~CE ~ON~ ~E S~, SOuwm 11 DEG~ES 27 MI~ES 17 ~T, A DIST~CE OF 46.82 FE~ TO A SPIKE~ ~CE'~ONG ~ NOW O~ FO~Y OF ~ M. PETERSON, ET ~, SOu=~' 54 DEG~ES 33 ~u~S 45 SECO~S ~ST, A DIST~ OF 185.78 FEET TO A FOIl; ~CE ~0~ 0~ ~S NOW OH FO~Y OF ~ M. pETE~SON, ET ~, NO~ 40 DEG~ES 31 ~mu~ES 39 SECO~S ~ST, A DIST~E OF 147.73 FEET TO A POI~ ~CE ~ON~ ~E ~ NOW O~ FO~Y OF WILL~ C. NO~ 50 DEG~ES 57 MI~ES 45 SECO~S ~T, A DIST~CE OF 273.18 FEET TO C~H L~ OF TO,SHIP ~0~ T-418, ~E P~CE OF CONTAINING 0.8131 AC~tES. BEING KNOWN AWS 288 MILDRED ROAD, NEWVILLE, PA 17241 PROPERTY ID NO.: 15-04-0393-052 TITLE OF SAID PREMISES IS VESTED IN MILDRED L. NEIDIGH, SINGLE ADULT INDIVIDUAL BY DEED FROM WILLIAM J- wEAVER AND ELIZABETH D. WEAVER, HUSBAND AND WIFE- DATED 08/12/1993, RECORDED 08/12/1993, IN DEED BOOK L 36, PAGE 707. MARK J. UDREN& ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~S ~I~HWAY, SUITE 500 CHE~Ry ~ILL, NJ 08034 ~56-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 172S7 Defendant (s) : ATTORNEy FOR PLAINTIFF :COURT OF CO~ON PLEAS : CIVIL DIVISION :Cumberland County ~ MORTGAGE FORECLOSURE :NO. 01-2537 WRI~O~ ~X~CUTI~ TO THE S~ERIFF OF Cumberland COUNTY: To satisfy the Judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 288 Meadows Road Newville, PA 17241 SEE LEC4%L DESCRIPTION ATTACRED Amount due Interest From Au~A~~ to Date of Sale ~er diem ~$16.71 $~. 470. ~9 (Costs to be added) By-- Prothonotary Clerk Date COURT OF co~ON pLEAS NO. 01-2537 EMC Mortgage Corporation VS. Mildred L. Neidigh WRIT OF EXECUTION ~ DEBT $_ 6o~4'70~9 Date of Sale ~ Per diem ~$16.71 cOSTS PAID: pROTHY S- SHERIFF STATUTORY S- COSTS DUE PROTHY. S- ppis TO BE sOLD: 28~ Mea~i:l~'s I~ad · UDREN & ASSOCIAT~ MAR J sUITE 500 cHERRY HILL, NJ 08034 (856) 482-6900 MARK J. UDREN&A~sOCZATES BY= Mark J. Udren, ~8~u~re ATTY i.D. NO.04302 1040 N. EIN~S HIGHWAY, SUITE 500 CHEERy NILL, NJ 08034 8~6-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, SUite 2O0 Irving, TX 75038 Plaintiff ATTORNEy FOR PLAZNTIFP :COURT OF COMMON PLEAS ~ CIVIL DIVISION ~Cumberland County : -MORTGAGE FORECLOSURE Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 NO. 01-2537 Defendant (s) : CERTIFICATE TO T~E S~{ERIFF I HEREBY CERTIFY THAT: I. The Judgment entered in the above matter is based on an Action: _A. In Assumpsit (Contract) _B. In Trespass (Accident) _ x C. In Mortgage Foreclosure _D. On a Note accompanying a purchase money mortgage and the prOperty being eXposed to sale is the mortgaged property. II. The Defendant(s) OWn the property being eXposed to sale as: ~ A. An individual _B. Tenants by Entireties -- _C. Joint Tenants with right of survivorship _D. A partnershil0 -- E. Tenants in Con~on _F. A corporation III. The Defendant(s) is (are): _~X A. Resident in the Commonwealth of Pennsylvania -- 8. Not resident in the Commonwealth of Pennsylvania _C. If more than one Defendant and either A or B above is not applicable, state which Defendant Pennsylvania. ~~the Commonwealth of Resident: ~ :k J. Ud~en, ESQuiRE --~ Ad tess & I.D. # as above MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~S HIQHWAY, SUITE 500 CHERRy HILL, NJ 08034 ~56-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant (s) : ATTOP~NEy FOR PLAINTIFF :COURT OF CO~ON PLEA~ ~ CIVIL DIVISION ~Cumberland County - MORTC, AGE FOREcLosURE : NO. 01-2537 CERTIFICATE Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the · subject to the above~captioned matter and that the premises are not provisions of Act 91 because it is.. Sec. ) ) ) (x) ( ) An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 4904 relating to unsworn falsification to authorities. 18 Pa. MARK J. UDREN& ASSOCIATES BY= M~rk J. Udren, Esc/uire ATTY I.D. NO. 04302 1040 N. KINQS HIQHWAY, SUITE 500 CHEP.~Y HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff Vo Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant(s) ATTOP/~Y FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FOP~ECLOSURE NO. 01-2537 AFFIDAVIT PURSUANT TO RULE 3129.1 EMC Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 288 Meadows Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mildred L. Neidigh 45 ~ S. Earl Street, Apt. 5, Shippensburg, PA 17257 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. Commercial Credit Corp. 1320 Lincoln Way E., Suite 13 Chambersburg, PA 17201 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real EState Tax Dept. Domestic Relations Section Commonwealth of PA, 1 Courthouse Square, Carlisle, PA 17013 13 N. ~anOver St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 ~n' Name and address of every owledge who has any interest other person of whom the plaintiff has the sale: in the property which may be affected by Name Address Tenants/Occupants 288 Meadows Road, Newville, PA 17241 I verify that the statements made in s this affidavit ~f~? personal knowledge trUe and COrrect a or information and belief. - ~ ~a~se Statements herein DATED: August 27, 2001~ CIATES ~J- Ud~en~m -- Marl ~ en~,~Q .-- -- - Att~ ~ey for Plalntiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINQS HIQHWAY, SUITE 500 CHEP. RY HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 20O Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 : NO. ATTO~N~Y FOR PLAI~TIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTgAgE FORECLOSURE 01-2537 Defendant (s) TO: Mildred L. Neidigh 45 ~ S. Earl Street, Apt. Shippensburg, PA 17257 5 Your house (real estate) at 288 Meadows Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in the Cumberland County Courthouse, 1 Courthouse Sqaure, Carlisle, PA, to enforce the court judgment of $60,470.59, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. MAY R~. ARL~ TO DRF. VENT T~IS -~RIFF'S RAT.R To prevent this Sheriff's Sale, you must take The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. TO find out how much you must pay, you may call: /~- You may be able to stc~0 the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chalice you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) OTHER I~.T C-,HTS 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 m~ney. 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 te~ (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 T~IB PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT ~AV~ A LAWYE~ OR CAmelOT AFFORD C)~, ~0 TO UR T~r-~HO~ 'r~ OFFICE LIb-A-~ B~LOW TO FIND OOT ~--~ YOU CAN LAWYER B.EF~RRAL 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 BY: AT-TY ar~: j. Udren · -T.D. NO. 04302 1040 N. C~E~u~ .._K_I_NGS R~GHWAy, SU~T~ .~.'_'~ ~-~"L, NJ 08034 - 500 a:~o-482-6900 .... ~ EMC Mortgage. COrpor.ation 909 Ridden Ridge Drive, SUite 2O0 Irving, TX 75038 Plaintiff 'COURT OF COMMON PLEAs : CIVIL DIVISION : CUmberland County ATToRN~. i~OR PLAINTI~'F V. Mildred L. Neidigh Box 440 Shippensburg, PA 17257 ~NO. 01-2537 Defendant(s) : A~F~'DAVIT OF SER%~/CE PU'RBUANT TO Pa.R.c. P.RULE 3129 I 1 A co- o- . Esquire, hereby Verifie i~ atta,~~ the Notzce o~ o= .... s .~_ ~-~u nereto =~ ~=.~t ~-~rl~f,s ~v=ry other i-~- -~ r'~'qlmlt "A" .... mraem4~- ~ ~esced ~=,~ ~ , -~ sent to -,-~-- ~=cu COD~, --~ .... ==rcl=lCate~ ~ .~ii ~ ~Xecution .~a~ one date ~ ~- ~%=~Older ~n~ == ~"~ on the attached 2...~.Notice of Sher' , , certlzled ~1 .... 1fl s Sale w Was Si~n,~m~%- ~ une date ~_~_ Re--' ~ .... or my Def~-~ -mm==r~n~ on the -~7 ..... ~s; by re-ul-~ · _ ~=lpu. CoD~,~ ~ ~ =~u~t(s) o- ~- ~ . ~uzached D~ .... ~ =r mall and ~ibit "B', '---' ~ =ne said No~_ -- --= au=ached hereto a~ 3. .If a Retu~ Receipt is not se~ce on the date · attached hereto, then se~ice was bv personal hereto a ~u:=.- specified on the attached Return of Se~ice/attached 4. If se~tce was Order is attach ~ ~ Order of Co rt then proof e_ -=~euo as ~hibitu,,B~. of compliance With said All Notices Were Se~ed within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is ~ relatin= to ..... de S~ject ~o ~ ~rn falsificati~ ~he penalties o~ 18 Pa.c.s. Section 4904 Dated: NOVe~er 26, 2001 ~ ~K J. ~R~ & ~SOCIATEs MARK J. UDi~EN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. EIN~S HIGHWAY, SUITE 500 CHEI~RY HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 2O0 Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 Defendant (s) ATTORNEy FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland.County NO. 01-2537 DATE: September 7, 2001 TO= ALL PARTIES IN iNTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OWNER(S): MILDRED L. NEIDI~M PROPERTY: 288 Meadows Road Newvtlle, PA 17241 Improvements: RESIDENTIAL DWELLIN~ The above captioned property is scheduled to be sold at the ~ua~.rlan~ County Sheriff,s Sale on D~, at 10:00 AM, at the CUMBERLAND COUNTY COURTHOUSE, I COURTHOUSE SQUARE, 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. STATE OF PENNSYLVANIA, } COUNTY OF CUMBERLAND ss. Robert p Ziegler .................................................................. Recorder of Deeds Ju and for said County and State do'hen:by ,--fi;fy that thc Shcrlff's Deed in which ................ F~IC Nt~ Corp .................................................................................... is fl~e ~im~e the 5 th the nme having been sold to said f~rantce ou ............................................... day of Dec Ol ........................................ A.D.,i ..... ,und~nd byviflue ~ a w~t .............. Execution 5th ................................................ iuuedouthc ..................................... dayof. Sept . ~ 01 ......................... a.u., ..... ~ out of thc Court of Canmmn Pkas of said County'~ of Civil 01 N~er 2537 . ~lC ~tg Corp muner .............. ,mt thesmtof ............................................................... ............ imf ~ildred L Neidigh 250 ..... i755 ................. h d~YreeordedhShefiWsDcedBoukNo ............. , Page ............. IN TESTIMONY WHEREOF, I hvc hereunto set my hand and seal of said office th;, ._==/=.=~.._. day of ....... ........... D., .... EMC Mortgage Corporation VS Mildred L. Neidigh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2537 Civil Tem~ Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 24, 2001 at 2:51 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mildred L. Neidigh, by making known unto Mildred L. Neidigh, at 45 V2 S. Earl Street, Apt. 5, Shippensburg, Pennsylvania, its contents and at the same time handing to her personally the said true attested copy of the same Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 03, 2001 at 9:11 o'clock P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mildred L. Neidigh, located at 45 V: S. Earl Street, Apt. 5, Shippensburg, 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 Sheriffmailed a notice ofthe pendency of the action to one of the within named defendants to wit: Mildred L. Neidigh, by regular mail to her last known address of 451/2 S. Earl St., Apt. 5, Shippensburg, PA 17257. This letter was mailed under the date of October 8, 2001 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 Court House, Carlisle, Cumberland County, Pennsylvania, on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum of $15,000.00 to Attorney Mark J. Udren & Associates for EMC Mortgage Corporation. It being the highest bid and best price received for the same, EMC Mortgage Corporation of Two MacArthur Ridge, 909 Hidden Ridge Drive, Suite 200, Irving, TX 75038, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $1,214.05, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 300.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 23.40 SCHEDULE OF DISTRIBUTION SALE #21 Writ No. 2001-2537 Civil Term EMC Mortgage Co~poration VS Mildred L. Neidigh 288 Meadows Road Newville, PA 17241 Sale Date: Buyer: Bid Price: December 5, 2001 EMC Mortgage Corporation $15,000.00 Real Debt: $60,470.59 Interest: 1,671.00 Writ Costs: 112.40 Total $62,253.99 DISTRIBUTION Amount Collected: $ 1,214.05 Sheriff's Costs: 1,014.05 Legal Search: 200.00 So ~swers: o ~_ R. Thomas Kline, Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITFINO THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 21 Held Wednesday, December 5, 2001 Date: December 5, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive. Taxes for the current year 2001. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , and recorded , , in Cumberland County Deed Book , Page RECITAL: Being the same premises which William J. Weaver and Elizabeth D. Weaver, husband and wife, by deed dated August 12, 1993 and recorded August 12, 1993 in Deed Book "L", Volume 36, Page 707, granted and conveyed to Mildred L. Neidigh. OTHEREXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Mortgage in the amount of $54,400.00, given by Mildred L. N. eidigh to Un~ted. C,o,,., ~ Lending Corporation, dated April 19, 1996 and recorded April 25, 1996 m Mortgage NOOK t.~, Page 1101. Assigned to Bankers Trust Co. by instrument recorded in Miscellaneous Record Book 560, Page 27. Complaint in Mortgage Foreclosure filed on April 30, 2001 by EMC Mortgage oration as Plaintiff against Mildred L. Neidigh, as Defendant in the office of the Prothonotary tCo°fi~leC no. 01-2537. Default judgment in the amount of $60.470.59 entered September 5, 2001. 6. Mortgage in the amount of $10,464.90 given by Mildred L. Neidigh to Commercial Credit Corporation dated October 15, 1997 and recorded October 23, 1997 in Mortgage Book 1411, Page 984. 7. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 8. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to the improvements on the subject property. 9. Satisfactory evidence to be produced that EMC Mortgage Corporation had standing to bring the above-mentioned foreclosure action when last assignment of record was to Bankers Trust Co. 10. Real estate taxes accruing on and after January 1, 2000 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. BEAL E~TATE ~ NO. 21 Writ No. 2001-2537 Civil EMC Mor~?~e Corporation vs. Mildred L. Neldigh Atty.: Mark J. Udren ALL THAT CERTAIN piece of land s{tuate in Lower Mifflin Township. County of Cumberland and State of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point in the cen- ter line of Township Road T-418, on the line of land now or formerly of william C. Kostonbaude~. thence along the center line of said Town- ship Road, South 11 degrees 11 minutos 47 seconds East, a distance of 133.28 feet to a spike: thence along the same, South 11 degrees 27 minutes 17 seconds. Fast. a dis- tance of 46.82 feet to a spike: thence along land now or formerly of Raymond M. petorson, et ux, · South 54 degrees 33 minutes 45 seconds West, a distance of 185.78 feet to a point; thence along other lands now or formerly of Raymond M. petorson, et ux, North 40 de- grees 31 minutes 39 seconds West. a distance of 147.73 feet to a point; thence along the land now or for- merly of William C. Koalenbeuder, North 50 degrees 57 minutes 48 seconds East. a distance of 273.18 'feet to the center line of Township Road T-418, the place of beginning. cONTAININO 0.8131 acres. BEING KNOWN AS 288 Mead- owe Road, Newville. PA 17241. PROPERTY ID NO.: 15-04-0393- 052. TITLE OF SAID PREMISES 15 VESTED IN Mildred L. Neidigh, single adult individual by Deed from William J. Weaver and Elizabeth D.' Weaver. husband and wife. Dated 08/12/1993. recorded 08/12/ 1993. in Deed Book L 36. Page 707. MARK J. UDI~EN & ASSOCIATES BY: Mark J. Udren, Esquire AT~"f i.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEI~Y HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg, PA 17257 De f endant ( s ) ATTOI~NEY FOR PLAINTIFF cOURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-2537 AFFIDAVIT pURSUANT TO RULE 3129.1 EMC Mortgage Corporation, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the writ of Execution was filed the following information concerning the real property located at: 288 Meadows Road, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mildred L. Neidigh 45 ~ S. Earl Street, Apt. 5, Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: Name Address SAME A~ #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 record: Name Plaintiff herein. Commercial Credit Corp. of the last recorded holder Address See Caption above. 1320 Lincoln Way E., Suite Chambersburg, PA 17201 of every mortgage of 13 5. Name and address of every other person who has any record lien on the property: Address Name NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue i Courthouse Square, Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 288 Meadows Road, Newville, PA 17241 to the best of my personal knowledge or mnzorma~on an~.De~ez2. of 18 Pa.C.S. sec. 4904 relating =o ~/lswrrn =~u~=~=~ .... K J. ~ & ASSOCIATES Atto~y for Plaintiff MA~K J. UDP. EN & ASSOCIATES BY: Mark J. Uclren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP~Y HILL, NJ 08034 856-482-6900 EMC Mortgage Corporation 909 Hidden Ridge Drive, Suite 2OO Irving, TX 75038 Plaintiff Mildred L. Neidigh P.O. Box 440 Shippensburg,' PA 17257 Defendant (s) ATTOI~NEY FOR pLAINTIFF : NO. : : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE' 01-2537 TO: Mildred L. Neidigh 45 ~ S. Earl Street, Apt. 5 Shippensburg, PA 17257 Your house (real estate) at 288 Meadows Road, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in the Cumberland County Courthouse, 1 Courthouse Sqaure, Carlisle, PA, to enforce the court judgment of $60,470.59, obtained by Plaintiff above (the. mortgagee) against you. If .the sale is postponed, the property wzll be relisted for the Next Avazlable Sale. NOTT~Z OF OW~g'S I~IQHTS To prevent this Sheriff's Sale, y~ must take ' ' 1. ~e sale will be c~celled if ~u pay to =he ~r=gagee the back pa~ent, la~e c~es, cos~s ~ reaso~le at=o~ey's fees. To fi~ out ~ ~ch ~u ~st pay, ~u ~y call: ~ 2. You ~y be ~le to st~ the sale by filing a petition asking ~he Court ~o strike or ~en the jud~ent, if the jud~en= was impr~erly entered. You ~y also ask the C~rt to postpone the sale for go~ cause. 3. You ~y also be ~le to stop the sale thr~gh other legal proceedings. You ~y ~ed ~ a==o~ey ~o assert ~r rights. The sooner you contact one, the more c~nce ~u will ~ve o~ s~o~ing ~he sale. (See notice on page =~ on how to obtain ~ a=~o~ey. ) 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 =he bid price was grossly inadequate compared to =he 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. yon have the right to remain in the property until =he full amount due is paid to the Sheriff and =he Sheriff gives a deed to the buyer. At that time, the buyer may brin~ 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 clays 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 iu~nediately after the sale. YOU SHOULD TAKE THiS pAPEK TO YOUR LAWYEK AT ONCE. IF YOU DO NOT ~AVE A LAWYER 0K CA~OT A~FOP. D ONE, GO TO OK TELEPEOHB ~,um OFFZC~ LISTED BELOW TO FI. ND OUT ~ YOU CAN GET LEGAL NELP. 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 KO. 279] P. 2 SU. 12.20C' 9~ ~ ~' ~ST~ON, ET ~. NO~ 40 DEG~ZS 31 ~i~ 3~ S~CO~S ~ST, A DiST~ OF 167.73 F~ET TO A ~o~; ~E ~o~ ~E ~ ~w OR ~o~Y o~ w~z~ C. KOST~A~EH, NOR~ 50 DE~S 57 MZ~X~ 45 SECO~S ~T, A ~ST~CE OF 273.18 P~T ~O ~ C~ER LZ~ 0F T~S~P ~0~ T-418, ~K p~CE OF B~Gi~ING. COI~AZ~'/NG 0.8131 ACRZS. BEING KNOWN AS 286 MEADOWS ROAD, NEWVILLE, PA 17241 PROPERTY ID NO.: 15=04-0393-052 TITLE OF SAID PP, EMISES IS VESTED IN MILDRED L. NEIDIGH, SINGLE ADULT INDIVIDUAL BY DEED FROM WILLIA~ J. WEAVER AND ELIZABETH D. WEAVER. HUSBAND Ai~D WIFE. DATED 08/12/1993, I~CO~DED 08/12/1993, IN DEED BOOK L 36, ~AGE 707. '4. PAGE.02 WRIT OF EXECUTION .~nd/or AI'rACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01- 2537 COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBV'RLAND COUNTY: To satisfy the debt, interest and costs due W. MC Mortgage Corporation CIVIL 19 __ CIVIL ACTION - LAW , PLAINTIFF(S) from Mildrend L. Neidigh, P O Box 440, Shippensburg PA 17257. DEFENDANT(S) (1) You are directed to levy upon the propedy o! the defendant(s) end to sell Real estaLe located at 288 Meadows Road, Newville PA 17241. (See attached 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/am enjoined from paying any debt to or lot the account of the defendant(s) and from delivering any properly of the defendant(s) or ofhent;ise disposing thereof; (3) ilpropertyofthedefendant(s)notlevieduponansubjecttoattachmentisfound nthepossassionofanyoneofher than a named garnishee, you are directed to notify him/her that he/she has been added as a gamishee and is enjoined as above stated. 5.50 Amount Due $60,470.59 t.t. Interest o 1em $1,6 71.0 §ue Prothy $1.0 0 Atty's Corem % Other Costs Arty Paid $112.4 0 Plaintiff Paid Date: September 5, 2001 CURTIS R. LONG REQUESTING PARTY: by: Name Mark J. Udren, Esquire Address: 1040 N Kings Highway, Cherry Hill NJ 08034 Altorney for: Plaintiff Telephone:(856) 482 6900 Supreme Court iD No. 04302 Ste 500 Deputy REAL ESTATE SALE No. ~-~ On ~t3~-. I"}-, ~Oc~ thestmriffleviedul~ontbeamn~lam~ interest in the real property situated In/..~./~._A -'/]4;/~J~?, x' ~ f3- Oumbedand County, Pa., known qnd numbered a8:~~' ~J. ~,/'~ ~ .~[-~---and more fully Oescribed on Exllibit "A" filed with this writ and by this reference incorporated herein. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND: Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly 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: October 12, 19, 26, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. B~ mTAT~ ~ NO. 21 Writ No. 2001-2537 Civil EMC Mortga~ Coax)ration vs. Mildred L. Neidlgh Atty.: Mark J. Udren ALL THAT CERTAIN piece of land situate in Lower Mifflin Township, County of cumberland and State of Pennsylvania. bounded and de- scribed as follows, to wit: BEGINNING at a point in the cen- ter line of Township Road T-418. on the line of land now or formerly of William C. Kcotenbauder; thence along the center line of said Town- ship Road, South 11 degrees I l minutes 47 seconds East. a distance of 133.28 feet to a spike; thence along the same, South 11 degrees 27 minutes 17 seconds. East. a dis- tance of 46.82 feet to a spike; thence along land now or formerly of Ravmnnd M. Peterson. et ux. R/~ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of~ THE PAT.RIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1629 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patrlot-Naw~ and The Sunday Patriot-News newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published In their regular daily and/or Sunday/ Metre editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested In the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in fv~iscellaneous Book "M", Volume 14, Page 317. ~.~ ..~... PUBLICATION ................................ , ............................................................. COPY Swo, m to and subscr~&~efore m.~s,' 19th d~z~mber2001 A.D. ~" S_A_ L E .. #21 CldTmm . ;,;.,~,~r, Fenn~,vamfaAMo~Umt 0t Nefa~scornmlssion expires June 6, 2002 . ~,~.~~..~.]<~--. -,/~----~J~a~l. j~ . CUMBERLAND CUMBERLAND COUNTY SHERIFFS OFFlCE COUNTY 17013 COURTHOUSE ~_,~..~.~.;..~,.."r~'~"~"""~'='~"'*'~ Statement of Advertising Costs L°~-~'~_. ~p Itmd ?41& ~ ee i~ ..,_. =' To THE PATRIOT-NEWS CO., Dr. ~"~*~1~ ": ~ ~ For publishing the notice or publication attached hereto on the above stated detes $ ~05.44 ~ u ~,,,.~._~ ~. Probating same Notaqt Fee{s) $ t .$0 ~..~.~ u ~,.~1~1 Total $ 208.04 Publlaher'e Receipt for Advertlalng Coat The Patriot News Co., publisher of ~and ~, newspapers of general circulation, hereby acknowledge receipt of the aforesaid nctlea and publication costs and certifies that the same have been duly paid. BF-,AL E~TA~ ~ NO. 21 Writ No. 2001-2537 Civil EMC Mortgage Corporation vs. Mildred L. Neldigh Atty.: Mark J. Udren ALL THAT CERTAIN piece of land situate in Lower Mifflin Township, County of Cumberland and State of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point in the cen- ter line of Township Road T-418, on the line of land now or formerly of William C. Kostenbauder: thence along the center line of sald Town- ship Road, South ll degrees 11 minutes 47 seconds East, a distance of 133.28 feet to a spike; thence along the same, South 11 degrees 27 minutes 17 seconds, East. a dis- tance of 46.82 feet to a spike; thence along land now or formerly of Raymond M. Peterson, et ux. South 54 degrees 33 minutes 45 seconds West, a distance of 185.78 feet to a point; thence along other lands now or formerly of Raymond M. Peterson, et ux, North 40 de- grees 31 minutes 39 seconds West, a distance of 147.73 feet to a point; thence along the land now or for- merly of WflIlam C. Kostenbauder, North 50 degrees 57 minutes 45 seconds East, a distance of 273.18 feet to the center line of Township Road T-418, the place of beginning. CONTAINING 0.8131 acres. BEING KNOWN AS 288 Mead- ows Road, Newvllle, PA 17241. PROPERTY ID NO.: 15-04-0393- 052. TITLE OF SAID PREMISES IS VESTED IN Mildred L. Neldlgh, single adult individual by Deed from Wdilam J. Weaver and Elizabeth D. Weaver, husband and wife. Dated 08/12/1993. recorded 08/12/ 1993, in Deed Book L 36, Page 707.