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Home My WebLink About01-2765MARK ~. UDREN& ASSOCIATES BY: Mark ~. Udren, Esquire A?TT I.D. NO. 04302 1040 N. HIN~8 HIGHWAY, SUITE 500 CHERRY HILL, N~ 08034 85S-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTORNey FOH PLAINTIFF :COUI~T OF COMMON PLEAS :CIVIL DIVISION : :Cknnberland County : Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s} COMPLAINT IN MORTGAGE FORECLOSURE YOU ~AVE 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 PA~ER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LANYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE OFFZCE gET FORTH BELOW TO FIND OUT WH~RE YOU ~ GET LEGAL HELP. LAWYERs REFERRAL SERVICE Cumberland County Bar Assoclation 2 Liberty Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9108 AWT~O Le han demandado a usted en la corte. Si Usted Cmiere del de estas demandas ex~uesta ~ ~ ..... ~- . . '7 enderse -~,~= ~&u~ ulas Qe plazo al ~ar~- ~- - _ _ ene . . . = ~ u= aa recna de la demanda y la not~f~cac~on. Hace falta ascentar una comparencia escrita persona o con un o en defensas o ,us ob]~'e°cg~eY 'ntregar a la c°rte en f°rma escrita sus . ? s a las demandas en contra de s Sea avlsado gue si usted no se da~{~-~- ~ .... u persona. - · ~,,~=, ~ corse tomara medidas y pue~e, co~tlnuar la demanda en contra suya sin revi · notxflcaclo~ a~ ..... . P o avlso o co=e pue e a esta demanda, qu que Usted cumpla con todas las prov~s~ones de Usted puede perder dinero o sus propiedades u otros derechos importantes para Usted. LL~%'E~BTA D~MANDA A UNABOGADOz~MEDZATAMENTE, SI NOTZENEABOGADO O SI NO TZENE EL DZ~=~O 8UFZCZE~TE DE PAQAR TAL 8ERVZCZO, VAYA EN PF~BONA O LLAI~ POE T~LEFONO A LA OFZCINA CUYA DIP. ECCZON SE · NCUENTRA EBCRZTA ABAJO PARA AVERZGUAH DONDE ~ ~ug CONSEQUZH A~ZST~NCZA LEGAL. Cumberland County Bar Association 2 Liberty Avenue CarHsle~ Pa 17013-3387 717/249-3611 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. Uuiess 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 mall 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 wm 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 marled to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt coHeetor and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments= Assignor= Atlantic Regina1 Mortgage Corporation Assignments of Record to= Wells Fargo Home Mortgage Inc. Recording Date: 1/15/98 Book= 566 Page= 593 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: 167 Old Town road MUNICIPALITY/TOWNSHIP/BOROUGH= South Middleton Township COUNTY: Cumberland DATE EXECUTED= 4/17/97 DATE RECORDED: 4/21/97 BOOK: 1376 PAGE: 241 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows= (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage as of Principal of debt due and unpaid Interest at 8.5% from 9/1/00 to 4/7/01 (the per diem interest accruing on this debt is $17.19 and that sum should be added each day after 4/7/01) Title Report Court Costs (anticipated, excluding Sheriff,s Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $94.75 and that sum should be added on the first of each month after 4/7/01) Late Charges (monthly late charge of $28.00 should be added on the fifteenth of each month after 4/7/01) Non-Sufficient Funds Fees Other Fees Suspense Balance Corporate Advance $72,810.09 3,696.36 250.00 280.00 156.20 325.07 80.00 30.00 (544.66) 155.00 Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $80,878.56 7. The attorney,s fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff,s Sale. If the mortgage is reinstated prior to the sale, reasonable attorney,s fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner,s Emergency Mortgage Ass/stance 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 $80,878.56 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 & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN TRACT OF LAND WITH IMPROVemENTS TH~0M nUCTU" SITUATE IN SOUTH MIDDLRTON TOWNSHIP, CUMBERLAHD COUNTy, PENNSYLVANIA, DOIFdDYm AND DRSCRIRJe~ AB FOLLOWS: SEGZNNZNG AT /%. STONE COB.NER OM THE SOUTHEB.N SZDR OF THE OLD TOWN ROAD, SATD CORNER BEING OM THE NORTHRILN BOUIqDANy LTNE OF LARGER TRACT OF LAND OF WHICH THE WITHIN DESCRIBWD PRNEISRS WAS A PART; THuNCE NORTH 57 DNGREKS 15 MINUTES EAST, 1S8 FEET TO A STAK~ ON THE NORTHERN SIDE OF SAID ROAD; THNECR BY LAND NON OR FORM~RL! OF LLOYD M. BRA~DT AND RECROSSING SAID ROAD, SObw~ 41 D~GRRRS 15 MlmuTES EAST, 150 FEET TO A STANK; THENCE BY THE S~M~, SOuw~ 57 DEGREEs lq MIhuTES W~ST, 150 FEET TO A STAKe; THlZNCB BY THK SAM~, MOUTH 43 DEGREES 45 MIhu'J.'SS WEST, 152 FRET TO THE PLACE OF BNGINEING. CONTAINING .52 ACREs, MORE OR LESS; AND BRING IM~ROV~fl) WITH A TWO-STORY CINDER BLOCK AND WOOD FHAM~ COTTAGE. Z 902 0'47 07':1 Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotze, NC 28201-1225 January 1, 2001 Wend? 5. Arnold 167 Old Town Road Ga£dners PA 17324 RE: Wells Fargo I lome Mortgage, Inc. Loan Number 6296311 Mortgagor(s): Mortgaged Premises: Thomas R. Ford Wendy S. Arnold 167 Old Town Road' Gardners, PA 17324 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mor~_~ on your h~ is in dt~lllt; and the I~n,l~r ;nrona~ to ;u[cclose. Suecific info,,.afitm about the -~-'m~'e of the d~f~,l~, is ~rovided in the aernehetl The HOMEOWNER'S MORTGAGE. ASSISTANCE PROGRAM (HEMAP) may be able to help m save your nome. This Notice erolains how the uroaram worb, To sec if HEMAP can help~ you must MEET WITH A CONSUMER CRFr)IT COUNSELING AGENCY wi I'HII~ 30 DAYS OF THE DATE OF THIS NOTICE. Take this with you when yon meet with the Cnunsellna Aaencv. The namer address and phone onmber of Corlsllmpr Credit Connse!ing A..mme~es serving yonr Couutv are listed at the end of this N_nfi_ee_= If you have any aue*tln,,: you may call the Pennsvlvnn~n Housi~ Fiannce Aeencv toll free at 1-800-342-2397. (Persons with hnmired henrine cnn ,,nil (717) 780-1869). This Notice contains important legal information. If yon have any questions, representatives at the Consumer Cr.edit Counseling Agency may be able to help explain it. You may also want to contact an attorney :n your area. The local bar association may be able to help you find a lawyer. LA NO I]I"ICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOII~]CACION OBTENGA UNA TRADUCCION INMEDFrAMENTE LLAMA_NDO 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 DERECHO A REDIMIR SU HIPOTECA. EXHIBIT 03? 07~ '~ Welts Fargo Home m,p,~?age, Inc. '~ P.O. Box 1225 Charlotte, NC ~ ~ 28201-1: January 1, 2001 Thomas R. Ford 167 Old Town Road Gardners PA 17324 RE: Wells Fargo Ilome Mortgage, Inc. Loan Number 6296311 Mortgagorls}: Mortgaged Premises: Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 ACT 91 NOTICE TAKE ACT/ON TO SAVE YOUR HOME FROM FORECLOSURE ~_ o . eon oar home isin default, and the lender i mrec~ose. 'fie info~~ a_e_ , ....... ntcods m ~; ugtalllc I r vtoeo m the att ched es. The HOMEOW~s!.~TAN.CE PROGRAM (HEMAP m ~~__P_ ma be able to hel to ~~ ,~ ~w_,~H.~ _-A.C__NO _SUMER CREDIT ~~~'~- ;th ,h THE~rATE OF THIS N T1CE. Take this Notice · ... ,,n m wi h n elln~ ~.ber_of Consumer Credit Counselin A encies servin our ~es~ons ou ma call the Penns Ivania ~wi im air be ri Can call This Notice contains important legal information, if you have any questions, representatives at the Consumer Credit Counselin,, A ............. contact an attorn in our ar o n,.,,,-y may ne ante.to help explain it. You may also want to cT y ea. The local bar associanon may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE 5UMA [MPORTANC/A, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. S! NO COMPRENDE EL CONTENDO DE ESTA NOT/FICACION 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 DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICERs Thomas R. Ford Wencly S. Arnolcl 1~7 Old Town Rn~Cl Gardners, PA 17324 6296311 WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL AgglgTANC~. WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS; IF YOU COMPLY g't I'H THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE *ACTa), 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 OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage, for thirD (30) days from the date of this Notice Dur ng that time you m. ust,.arrangc and attcnc] a. fact:, to-f~ce" meeting with one of the consumer credit counsel ng agencies u,s. ted .at the end of th~s ~Totlee. THIS MEE.TI..N? MIJgT OC.C. IJR WITHIN THE NEST ~0~.D.2L~ IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MITgT RRING YOHR MORTGAGE liP TO DATE_ THE PART OF THIS NOTICE. C~I I.ED "HOW TO CIJRE YOUR MORTGAGE DEFALJLT". EXPI.AINS HOW TO RRIN(; YOIIR MORTGAGE UP TO DATE_ cC¢O~S~MER C .RE ,D. rr ,COU. NSEL, IN~G..AGEN. C. iFg -- If You meet with one of the consumer credit ou se mg agenc:es I:sten at t~e enu ut t~ls not~ee, the lender may NOT take action against you for thirty'(30-'} days after the date of this meeting. The names, addresses and teleohone numbers of designated conm~mer creclit cot~nselin~ a~renc~es for the county in which the nrbnertv ig locatedare set forth at the end of this N-otice. lr is on y necessary to schedule 6ne fac~-to-faee meeting. Advise your lender immediately of your intentions. -- APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for snecific irfformation about the nature of your default.) If you have trim and are unable to resolve this proble n with the lender, you have the r,,ight to app~ly for financial assi~s.t,,ance frgm the Homeowner's Emergency Mortgage Assistance ~rolgram. ~o au so, you !nus. t tm out, s~gn and file a comp. leted Homeowner'sE&er~encv ,a. ssts. tanc,e Prol~ra.rn,~.pl~!~catlon with one of the designatM consumer credit counseling a~encies fistea at toe eno ut mis ~otice. Only coosumer cre&t couoseling agencies have al~plicatio::s for the program and they will assist you in submirt ng a complete apphcat on to the P6nnsylvania HousingFinanee Agency. Your application MUST be filed or postmarked within thirty (30) days of your-face-to-face meeting. YOU MllgT F/LE YOUR APPLICATION PROMI'I'LY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEi-I'd.R, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 0011381585 ~A- Available funds for emergency morma~ assistance are very limited. They will gency under the eligibil ty cr teria esta'bhshed by the Act. Tlie Perm.sylvan a Housing Finance Agency has six'v/(60} days to make a dec s nn after t rece yes your apphcatinn. During that time, no foreclosure proceedings will he.pursued a~ainst you if you have met the time r. equireme~n, ts .~,t ~'qrth above. You will be notified &rectly by ~e Pennsy vania Housing Finance t~gency or ~ts ueclslon on your app ication. NOTE: IF YOU ARE CURRENTLY PROTECI ~D BY THE FILING OF A PETITION IN B~uNRK~_U__I~_C_Y~__T~__E FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION U I'OSi~-S ONLY AND SHOULD NOT BE CONSIDERED AS AN A ~ ~MPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to ,~t¢) NATURE OF THF DEFAULT - - The MORTGAGE debt held by the above lender on your property located at: '1 ~7 Old Tnwn Road G.,-d.,..-. PA 17374. 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: Octnhvr 9~flCl. J~mmry 7001 Other charges (explain/itemize): Late Char~es ~th~r Fee~ tif ~.npllc~M~l ~S~.flfl TOTAL A MOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION S238.67 $2.509.95 a OW~T.Q CURE _T_H_E .D_E._FAULT - - You may cure the default within THIRTY (30) DAYS of the ~ ~fi~tssno~.ce_.B_ ~ PAllING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH $ ........, PLUS A_NY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY {301 DAY PERIOD. Payments must be made either by cash. cashier's check~ certified check or money order made payable and sent to_' WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2$01-O1H DES MOINES, IOWA 3JII32R You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: IF YOU DO NOT CURE THE DEFAULT - - If you do not. cure the default within THIRTY {301 DAYS of the date of this Notice, the lender intends m exercise its r~hm to aeeel~'ate the morma~e debt.' Thi~ means that the entire outstanding balance of this debt will be considered due immediately and you may lose ...... the chance to pay the mortgalze in monthly installments . If full pay.ment of.the total amount past., due ts not made w~th n THIRTY ~0) DAYS, the lender also intends to instruct tis attorneys to start legal action to foredose u~on your mort~re~ oropert¥. IF THE MORTGAGE IS FORECLC~IeF~ UPON o - The mortgnged proper.p/will be sold by the Sheriff to t~ay oft the mortgage debt. It the lender reters your case to tis attorneys, But you cure the delimluency before the lender begins legal p. rocecdings aga nst you,you will still be required to a the reasonable attorney's fees that were actually incurred, upto $$0 00., However, if leg,il proceeSi~ are started against'you, you will have to pay all reasonable attorney s fees actually recurred by tbe lender even if th~ey exc, ee,d $$.0.00. Any ,at, torney's fees w be added tb the amount you owe the]ender, which may also incmne other reasonanle costs. If you cure the defau t within the'THIRTY {30l DAY ~eriod yon will not be re,mired to laav attorney's tees. ' ' OTHFI~ I.I~NF}I~I~ REMI~I~IF.~.. The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. O0113B/eB5 RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cur~,t within the THIRTY (30) DAY period and foreclosure proceedings have b'egun, ' ......... to cure the d~f~nlr and nrevenr the sale at any time un ro one hour before rl~e glqeri~ EARI.W. gT POgglRI.E glqERIFF'.q gAI.R DATF -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged prolaerty could be held would be ,approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s gale will be sent to y. ou before the sale. Of course, the amount needed to cure the default w II increase the longer.you walt- You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER_' Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 ParKway Plaza Blvff. CharlOtl~, NC 28217 1-800-766-0987 704-423-4016 Tanisha Robinson t~FFECT OF .q, HF. RIFF'fi gA, I.F - Yo,u should realize that a Sheriff's Sale will end your ownership of e mortgaged property and your right to occnpy it. If you continoe to live in the rd err after th Sheriff's SaTe, a lawsuit to remove you and your shi.gs and other belongings ggu{ ,l b started the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt,-~9.ovided that all the outstandin a ments c~a_,rges and attorney's .fe,e.s ,and costs are paid prior to or at the sale and that the other reqgu~ents ' O me mortgage are satlSllt.~l. YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. · TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. · TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD ~O,Cr.C..U~R...R.E.D.~.I..F' .Y..O.~ CURE THE DEFAULT. (HOWEVER2 YOU DO NOT HAVE THIS ~.,.,l-lt ~t) {.,UAE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) $41-1757 FAX# (717) $41-4670 CUMBERLAND COUNTy Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Mctropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-$925 FAX# (717) 234-945~ YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1.$14 Derr~ Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717} 234-2227 Adams Coun.ty Housing Authority 139-143 Carhsle St. ' Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. ~ R_I F I~-_A TLOJ 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 &ASSOCIATES -~ J. UDREN & ASSOCIATEs BY: Nark j Udren, Esquire AT~-~ I.D. N~. 04302 1040 N. KIN~s HIGhWAy, SUITE 500 CHERRy HILL, NJ 08034 8._556-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) ATTORNEy FOR PLAINTIFF 'COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County ~ MORTGAGE FORECLOSURE : NO. 01-2765 Civil Term TO THE PROTHONOTARy: Kindly enter judgment i ~fegdant(s) for fai n.favor of the Plai ' . within 2 ~ .... lure to file an _ ~lff and a alns 0 ~=~.zrom servi-~ ~=- - Answer tu ~ai tiff, g t ~he mortgaged premise ~ un=r~o~ and for for ~ s ~omplalnt s, and assess plaintiff,s d=_~osur~ .a~.d sale of the As set forth in Complaint Interest per Complaint $80,878.56 From 4/8/01 to 6/14/01 1,168.92 Late charges per Complaint From 4/15/01 to 6/14/01 56.00 Escr°~r~Y~.~~ per Complaint um =/1/01 to 6/14/01 .... TOTAL I hereby certify that (1) Defendant are as =~..-- ~ the address s - . accordance wi-~ ,_~t'~*_~ove, and (2) t~,, ~.of .th= Plaintiff an~ ' ' ~ ~u~Y which is attached hZ~$~,given in A or ey for ~ ~. UDR~ & ASSOCIATEs E~ ~ark ~ Udren, Esquire &~ I.D. NO. 04302 1040 ~. ~ZNGS NZG~A~, 8UZ~ 500 ~R.~¥ mILL, ~ 0~034 ~ells Fargo Home Ho~gage, Znc F/K/A NO~we,~ Hor~ga~e' Inc. ' 5024 Pa~k~a~ Plaza Charlotte, ~C. 28217 Plaintiff V. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 ATTO~y FOR PY.~.Z~'ZFF .--" COURT OF CO~ON PLEAS ~ Ctu~berland Cotmty : NO. 01-2765 Civil Term De fendant (s) DATED: JUne 1, 2001 TO: Thomas R. Ford 167 Old Town Road Gardners, Pa 17324 YOU ARE IN DEFAULT BECAY;YO~~TZC~ APPEARANCE PERSONALLY U_ HAVE FAILED TO ENTER A WRITTEN OR BY ATTORNEy AND FILE IN WRITING WIT~ THE COURT YOUR DEFENSES OR OBJECTIONs TO THE CLAIMS SET FORTH AGAINST YOU. UNLEss YOU ACT WITHIN TF~N DAYS FROM THE DATE OF THIS NOTICE, A JUD~ MAy BE ENTERED AGAINST YOU WITHOUT A HEARIN~ AND YOU MAy LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTs. YOU SHOULD TAblE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE THE FOLLowING OFFICE TO FIND OUT SERVicE · ~u .qqunc. y Bar Association .~ '.1percy Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9180 _D_EBIDA DENTRO D SU ?___~_TE EN ESTE OR N._O_ HABER TO ":L E UN TERMINo D CASo. AL mo HA,DO --. TRIBUNAL PODRA S E DIEZ (10) DIAS TOMAR LA ACCIoN ks_c?_c" PREu _c sin NOTIFIC cIoN ~-'"-'RDER BIENEs yAL----" ~_C_TAR SENTENCiA m.~-~%',"'~-~--USTED EN CORTE ~ NOTIFICACIoN A r~ O~T~R,.~O~_DERECHOS, iMPO,,~_o_u uONTRA, USTED O --. -~u~J~O I ~-,~x-~. D -'"""~ 8I NO TI ~EDIAT EBE LLEV 0 ENE_D_INERO SUF ~M~TE SI USTED AR ESTA LLAME POR Tm. ICIENTE PARA T NO TIENE ES _ LEFONo A ~.L SERvIcIO. CRITA LA OFICI _ VAYA EN - J'~ ASSISTENCIA Cumberla-~-~.~RRAL SERVICE · [~_qo. uncy Bar Associatio z "1Perry AVenue n Ca. rlisle~ Pa' 17013-3387 717/249-3166 or 800/990-9180 ~" ~ USED FOR THAT ~ ~. I~DIL~N &ABBOCZATE8 EY: Nazk J Ddren, Esqut=e ATTOrNEy FOR ~LAz~I'ZFF ATTy Z.D. NO. 04302 1040 N. EZ~s HIGHWAY, SUITE 500 CHERRy HILL, HJ 08034 ~4 i---6 .u Wells Fargo Home Mortqage, Inc. F/K/A Norwest Mortga ~ I i COURT OF COlOrON PLEAS 5024 Parkway Plaza E~ nc. ~ CIVIL DIVISION Charlotte, NC. 28217 i Cumberland County Plaintiff v. Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) DATED: June 1, 2001 TO: Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 NO. 01-2765 Civil Term YOU AR~ IN DEFAULT BECAUSE YOU APPEARANCE PERSONAL m~ ~ . _H~_VE FAILED TO ENTER A WRITTEN COURT YOUR DEFENsEsLY ~" ~ aTTORNEY AND FILE IN WRITING WITH THE OR OB~TECTIONS TO THE CLAIMS SET FORTH A~AINST YOU. UNLEss YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A Juu(~MENTMAy BE ENTERED A~AINST YOU WITHOUT A HEARIN~AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RiGHTS. YOU SHOULD Ti~J(~ THIS NOTICE TO ALAWYER AT ONCE. IF YOU DO NOT~AVEALAWYER OR CANNOT AFFORD ONE, C~3 TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN ~ET LEGAL HELP. CUmbe__L~WY~R REFERRAL SERVICE r~an~ Coun · . .. ty Bar Association ~ L1Derty Avenue Carlisle, Pa 17013-3387 717/24923166 or 800/990-9180 NOTZF-T~.A~DRT~b-TE DEEIDAD ~%RTE EN ESTE HABER TO~U~DO ENTRo DE UN TE CASO. AL LA EL TRIE RMINo DE DIE NO TOMAR LA UNAL PODIA Z (10) DI ACCION ESCUc ~.._S~INNEcESIDAD ._AS__ DE ESTA NOTIF HAR PREUBA DE COMPARAR ICACIoN, PE ALG~A, DICT ECER USTED RDER BIENEs y ;%R SENTENCiAEN EN CORTE O ES .... -~NO A LA ...... ~v~CIO, VA~ -----' ~RITAABAJo PARA A OFICINA, CDYA DIRE A EN.~RSONA LEC~AL ~;ERIGUAR CCION SE .. · DONDE SE p ~ ~,~,___ ENcuEN~RA S ...... UED_ --*--~UIR ASSISTENCIA ~RVICE ~%U~Derland qgUnty Bar Association 2 L~berty Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9180 NOTICE: PURBUANT TO THE FAIR DHBT COLLECTION PRACTzCEB ACT, THIS LAW FIRM IS DH~r~n TO BE A DEBT COLLECTOR AND THIS IS AN ATT~MPT TO COLLECT A DEBT. AN~ I]TFO~LMATIOH OBTAI~TED WILL BE USED FOR THAT PURPosE. ~]; 0'o UDR~ & &SSOCZ&T~8 B~: Eark 0' Udren, Esquire A;~ I.=. ~o. o*~o2 .=_~' H;~.,., N; o;o3, su~;,~ soo ~"~-~82-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff ATTO~.NEy FOR PLAINTIFF COURT OF COMMON PLEAs ~CIVIL DIVISION Cumberland County MORTC~%GE FORECLOSURE Ve Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 De fendant (s } NO. 0~-2765 Civil Term Defendant: Age: Residence: Employment: A~FIDAVIT OF NON-MILITARy SERVICE STATE OF COUNTY OF TH~ ~ERsi~.D · ~ ss averments herein being 'duly sworn, de~ose~ and seys that the maintained by us ea;t%ebra~dP ~e~a~t~%°~ic~%d=e and records P~aintiff here' ~=ay or Naval Service ~e~,abov~ Defendant(s) ~ agent of the are not in the u~ nne 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: Age: Residence: Employment: Thomas R. Ford Over 18 As captioned above Unknown Over 18 AS captioned abOve Unknown ~ame: Sworn to and. subscribed before me this i~t~day ~ ,~'~ , ~0o~, /~'tary Pu.~'~ ~.c ~ J. UDR~N& ASSOCIATES BY= Mark J U~ren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~s HIGHWAY, SUITE 500 CHERRy HILL, NJ 08034 8~56-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Elvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) ATTORNEy FOR PLA~'I~IFF : COURT OF CO~ON PLEAS : CIVIL DIVISION :Cumberland County [ MORTGAGE FORECLOsURE NO. 01-2765 Civil Term TO: THOMAS R. FORD 167 Old Town Road ~ardners, PA 17324 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 CONCERNING THIS NOTICE PLEASE CALL: ATTORNE~ At this telephone number:~ ~6-9~6-~1___ __ MARK j. UDREN& ASSOCIATES BY= ~ark j Udren, Esquire ATTY I.D. NO. 04302 1040 N. KiNGS HIGHWAY, SUITE CHERRy HILL, NJ 08034 8~56-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 De fendant (s) ATTOP, NEy FOR PLAINTIFF ' COURT OF COMMON PLEAS : CIVIL DIVIsIoN :Cumberland County ~ MORTGAGE FORECLOsURE 01-2765 Civil Term PRAEcIPE FOR Jum~HENT FOR FAILURE TO TO THE PROTHONOTARy: Kindly enter judp~nent · Defendant(s . an favor of t · . within 20 d~vJ°;ro~a~}~ 3%~file an Ans~h;r Plaintiff ~nd. against the mortgaged Dr~is~'" ~zvlc= =hereof and for ~_?lalnt~ff.s Complaint ..... =nu assess Plaintiff,s di~°~r~ ?~d sale of the As set forth in Complaint Interest per Complaint $60,878.$6 From 4/8/01 to 6/14/01 1,168.92 Late charges per Complaint From 4/lS/01 to 6/14/01 56.00 ESCrow payment per Complaint From 5/1/01 to 6/14/01 ~ 189~ TOTAL I hereby certif Defendant are as sho~Y~h-at (1)_th.e addresses of t · . accordance with---~ --- ore, an~ (2) that ..... he Plalnt~ff and . . ~u&e Z~7.1, a cony ~....~._= . ,,uu~ce ~as been iv · ~K . S ~rk F Ud%e~, ESQUIRE - ~A~Uor~ey for ~la[n~'~f D~ES ~E HE~E~y ~SESSED I~I~TED . DATE: ~ ~ ~. UDR~N & ASSOCZATEs BY: )~.rk J Udren, Esqut=e ATTY Z.D. NO. 04302 1040 N. [ZNGS HZGI-~A¥, SUZTE 500 CHERRy HZ~, NJ 08034 8~56-482-6900 Wells Far9o Home Mortgage' Inc. F/K/A Noz~west Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) WENDy S. ARNOLD 167 Old Town Road Gardners, PA 17324 ATTO~Ey FOR pLAINTTFF COURT OF COMMON PLEAS CIVIL DIVISION :Cumberland County MORTC4%GE FOREc~)sURE NO. 01-2765 Civil Term 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. ~ 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 ~2~VE ~ QUESTIONS CONCEP, NIN~ THIS NOTICE PLF~E CALL: ATTORNEY___~ At this telephone number: ~6_~4u~-2~ ~ MARE j. UDI~EN& ASSOCIATEs BY= Mark j Udren, Esquire ATTY I.D. MO. 04302 1040 M. KINGS HIGHWAY, SUITE 500 CHERRy HILL, NJ 08034 8_56-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) ATToRNEy FOR PLAINTIFF 'COURT OF COMMON PLEAS : CIVIL DIVISION :Cumberland County ~ MORTGAGE FORECLOSURE NO. 01-2765 Civil Term PEAEcIPE FOR JUDGemENT FOR FAI---- -- TO T~E PROTHONOTARy: Kindly enter iud en · D~fendant(s) . gm t in favor of · · wit ~- -- ~ f~r fallure to ~ .... the Plalntlff a ~ ..... h.., ~u uays ~rom --~.~ =.f-~ ~ answer ~ ~_. _.n~ ~lnst the mortgaged Premix,- i~'~ce unereof and ~- ~_i- .=~lnzlff,s ComDlain~ ..... o, ~u assess Pla4~~aurecl°S~re and sm]~ X=-iU- As set forth in Complaint .... ~ s uamages as follows~*~ ~ une Interest per Complaint $80,878.56 From 4/8/01 to 6/14/01 1,168.92 Late charges per Complaint From 4/15/01 to 6/14/01 ESCrow payment per Complaint From 5/1/01 to 6/14/01 56.00 TOTAL hereby certify that (1) the addresses ,hown ov,. of the . ~"== wl~n Rule 237.1, a 'cop'~-~'/.,~_na~t. notice has A tor e Plai i' f NARE j. UDREN & ASSOCIATEs EY= Mark j Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINOS HIGhWAy, SUITE 500 CHERRy HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 ATTORNEy FOR PLAZNTZFF :COURT OF CO~ON PLEAs : CIVIL DIVISION :Cumberland County ~ MORTGAGE FORECLosuP~E 01-2765 Civil Term Defendant (s) : TO THE SHEHZFF: ISsue Writ of Execution in the above matter: 167 Old Town Road Gardners, Pa 17324' Amount due FOR WRiT OF EF~ECUTzoN Interest From ~une~-lS~_2Q01 to Date of Sale Per diem ~$17.19 Dec.emher_5~_2OD1 Z,-~l~06 (Costs to be added) Ma: ATT~ ~)REN &ASSOCIATES 7J Udl ~NEy F ~n, ESQUIRE ~R PLAINTIFF c..'> MARK j. UDREN & ASSOCIATEs BY: Mark j Udren, Esquire ATTY I.D. NO. 04302 ~ N. ~IN~S HIgHWAy, SUITE 500 ~ERRy HILL, NJ 08034 ~$6-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc 5024 Parkway Plaza Blvd ' Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) ATTORITEy FOR PLAINTIFF COURT OF CO~4ON FLEAS CIVIL DIVISION :Cumberland County MORTGAGE FOR]~CLOsURE ." NO. 01-2765 Civil Term : CERTIFICATE Mark j. Udren, Esquire, hereby States that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage NOn-owner occupied Vacant ( ) ( ) (x) ( ) Act 91 procedures have been fulfilled. Over 24 months delinquent. This Certification is made subject to the penalties of 18 Pa. Sec. 4904 relating to unsworn falsification to authorities. ZF_~ ~ -j,~. -5' 'MARK J. UDREN & ASSOCIATES EYz Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KIN~s HIGHWAY, SUZTE 500 CHE~Ry HZLL, NJ 08034 ~56-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A NOrWest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 ATTOP~NEy FOR PLAINTIFF : COURT OF COMMON PLEAS ~ CIVIL DIVISION :Cumberland County ~ MORTC4~GE FORECLOSURE NO. 01-2765 Civil Term Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home. Mortgage, Inc F/K/A Norwest Mortgage, Inc ' . in the above action, by its attorney. Mark j Udren, Eso , s~ PlaIntiff of the date the ~raecipe for ' ' s ~ollowing information ...... the Writ of Execut~A--' ~orth as ·own Road G ~ .... ~u-uernlng the real ~u~ was filed the · a.~,=~, PA 17324 property located at: 167 Old PA 17324 PA 17324 1. Name and address of Owner(s) or reputed Owner(s). Name Address ' THOMAS R. FORD 167 OLD TOWN ROILD, C4%RDNERS, WENDy S. ARNOLD 167 OLD TOWN ROAD, GARDITERS, 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 lien on the real property to be sold: a Name record Address NONE 4. Name and address of record: Name Plaintiff herein. the last recorded holder of every mortgage of Address 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 RFJtL ESTATE TAX DEPT. Domestic Relations Section Commonwealth of PA, Address I COURTHOUSE SQUARE, CARLISLE, PA 17013 13 N. HANOVER STREET, CARLISLE, PA 17013 Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 7. Name and address of every knowledge 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 167 Old Town Road, Gardners, PA 17324 ~ verify that the statements made in thls affidavit are =o the best of my personal knowle . true an understand that fa dge or ~ . d correc of 18 Pa ~ ~ -- lse statements her · .... ~format~on and b ~ ~ ..... ~ec. 4904 rel~-- ~ e~,,~z~ maae sub~ec~ ~- ~ e__~. ~ im EN &ASsOCIATEs DATED: Jul~e 14, 2001 ~~ M~rk j. Udren, E~Q. A~tOrney for Plaxntiff MARX 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. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 Defendant(s) ATTORNEy FOR PLAINTIFF COURT OF CO~ON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-2765 Civil Term TO: THOMAS R. FORD 167 OLD TOWN ROAD GARDNERS, PA 17324 Your house (real estate) at 167 Old Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff,s Sale on December 5, 2001, at 10:00 AM in the CO~ISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $82,292.98, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ][O~3 ~Y RE AR?.m TO PREVENT T~T~ -~WmDTFF,S RAT,F To prevent this Sheriff,s Sale, you must take /~mm~u~m~e_m~ 1. The sale will be cancelled if you pay to the mortgagee the hack payment, late charges, costs and reasonable attorney,s fees. To find out how much you must pay, you may call: ~85f~L_A~2~fLg00. 2. You may be able to stop the sale by filin~ 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 stoppin~ the sale. (See notice on page two on how to obtain an attorney. ) 1. If the Sheriff.s Sale is not stOpped, your property will be sold to the highest bidder. You may find out the pr/ce bid by calling 856-482-6900. 2. You may be able to pet/t/on the Court to set aside the sale if the bid price was grossly inadec/uate 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 ~rom the BUyer is not paid to the owner of the property as if the sale never happened, the Sheriff, You will remain S. You have the right to remain in the~p~ert, y until the full amoun . paid to the Sheriff and the Sheriff gives a deed may bring legal proceedings to evict you. =vune ~Uyer. At that ti t due me, the buyer 6. You may be entitled to a Share of the A schedule of distribution of the mOne,- ~'= - money which w within 30 days after the sale. This schedule . your house wzll be f~-~ = Your house. --=u my the Sheriff (10} days -ft,~ _P~Oposed distributio ..... aun this s recelvxng tha .... ' ' ten 7. You may also have other rights and back, if you act immediately after the sale. defenses, or ways of getting your home YOU S~OULD TAF~ T~IS pAlmER TO YOUR LAWyER AT ONCe. I~ YOU DO NOT HAV~ A LAWFEit OR CAI~OTAFIeO~DoNE, GO TO OR T~LEpNO~T~L~OFFiC~LZST~B~LO~TO F~OOT~tEYOUcAN CUmberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717/249-3166 or 800/990-9180 ASSOCIATION DE LICENCIDADos DE FI/-~DELFIA Servicio de Reference Legal CUmberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717/249-3166 or 800/990-9180 SHERIFF'S RETURN - REGULAR CASE NO: 2001-02765 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE VS FORD THOMAS R ET AL BARRY J HORN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FORD THOMAS Rthe DEFENDANT , at 0918:00 HOURS, on the 8th day of May at SHERIFF'S OFFICE COURT HOUSE 1 COURT HOUSE SQUARE , 2001 CARLISLE, PA 17013 THOMAS FORD by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff.s Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this ~ day of _ ~ 2~o! A.D. ; P~othonotary - So Answers: R. Thomas Kline 05/09/2001 MARK J UDREN~ ~ De~ ~heriff SHERIFF'S RETURN - CASE NO: 2001-02765 P COMMONWEALTH OF PENNSYLVA/qIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE VS FORD THOMAS R ET AL REGULAR PATRICIA SHATTO , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ARNOLD WEN-DY S the DEFENDANT , at 0845:00 HOURS, on the 9th day of May at SHERIFF'S OFFICE COURT HOUSE 1 COURT HOUSE SQUARE , 2001 CARLISLE~ PA 17013 by handing to WENDY S. ARNOLD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: So Answers: Docketing 6.00 Service .00 .. -. "' ' ~ ' Affidavit .00 "' '~" .... ~ .~' ' :~:' Surcharge 10.00 R. Thomas Kline .00 16.00 Sworn and Subscribed to before me this .~.3.~(, day of / ~ ~rothonotary 05/09/2001 MARK J D-DREN By: . 7 Deputy Sheriff MARK J. UDP. EN & A~SOCIATES BY~ Mark J U~ren ATTY T.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff %COURT OF Co~ON PLEAS i CIVIL DIVISION .Cumberland County ATTORNEY FOR PLAINTIFF Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) NO. 01-2765 civil Term AFFIDAVIT OF SERVICE pUR~UA~T TO pa.R.C.P.HULE 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 Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. relating to unsworn falsification to authorities. Dated: said C.P. Section 4904 MARK J. UDREN & ~SOCIATES November 26, 2001 ~ BY: M~rk ~k~ren, Esquire Attorney for Plaintiff MARK J. UDREN &ASSOCIATES BY: Mark J udren, Esquire ATTY Z.D. NO. 04302 1040 N. KIN~S HZ~HWAY, SUITE 500 CHERRY HILL, MJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-2765 Civil Term DATE: August 6, 2001 TO: ALL PARTIES IN INTEI~EST A~D CLAIMANTS NOTZCE OF SHERIFF'S SALE OWNER(S): Thomas R. Ford Wendy S. Arnold PROPERTY: 167 Old Town road ~ardners, Pa 17324 Improvements= R~SIDENTIAL DW~LLIN~ The above captioned p~operty is scheduled to be sold at the ~rl.~d_ County Sheriff's Sale on llec~r_~- ~1, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CA~LISLE, 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. EXH D' T A MA~K J. UDP. EN & ASSOCIATES BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHER~Y HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, Pa 17324 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-2765 Civil Term To the Prothonotary: Kindly note on the record that the above Defendant, Thomas R. Ford and Wendy S. Arnold has filed Chapter 13 Bankruptcy in Middle the District of Pennsylvania on December 4, 2001, Bankruptcy Case No. 01-06436. Mark J , Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Wells Fargo Home Mortgage, Inc. f/PYa Norwest Mortgage, Inc. VS Thomas R. Ford and Wendy S. Arnold In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2765 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. ShefiWs Costs: Docketing 30.00 Sumharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.66 Mileage 3.25 Levy 15.00 Advertising 15.00 Certified Mail 1.12 Poundage 12.21 Postpone Sale 20.00 Law Journal 246.80 Patriot News 206.94 $ 622.48 paid by attorney 3-07-02 Sworn and subscribed to before me This /q~ day of 2002, Prothonotary /~' So Answei's: R. Thomas Kline, Sli~riff Real Estate Deputy .N2tRK J. UDREN & A~SOCIATES' BY: Mark J Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP. RY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 01d Town Road Gardners, PA 17324 Defendant(s) ATTOP. NEY FOR PLAINTIFF :COURT OF COMMON PLEAS ~ CIVIL DIVISION :Cumberland County -.' NO. : : MORTGAGE FORECLOSURE 01-2765 Civil Term A/~FIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. F/K/A Norwest 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: 167 Old Town Road, Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s): Name Address THOMAS R. FORD 167 OLD TOWN ROAD, GARDNERS, WENDY S. ARNOLD 167 OLD TOWN ROAD, GARDNERS, 2. Name and address of Defendant(s) in the judgment: Name Address PA 17324 PA 17324 S~ AS ~1 ~%BO%rE 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 record: Name and address of the last recorded holder of Address every mortgage of 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 REAL ESTATE TAX DEPT. Domestic Relations Section Commonwealth of PA, Department of Revenue Address I cOURTHOUSE SQUARe, CARLISLE, 13 N. HANOVER STREET, CARLISLE, Bureau of Compliance, Dept. Harrisburg, PA 17128-0946 PA 17013 PA 17013 280946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Address Name Tenants/Occupants 167 Old Town Road, Gardners, PA 17324 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 uns~falsification to authorities. DATED: June 14, 2001 ~~OCIATES M~Lrk J. Udren, ESQ. A~:torney for Plaintiff ~ ~. UDI~Elq &ASSOCIATES. BY: Mark ~ ud~en, Esquire ATTY ~.D. NO. 04302 1040 N. ~I~S H~GHWAY, SUITE 500 CHEI~Y HILL, N~ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff Thomas R. Ford Wendy S. Arnold 167 Old Town Road Gardners, PA 17324 Defendant (s) ATTORNEY FOR pLAINTIFF cOURT OF CO~4ON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-2765 Civil Term TO: WENDY S. ARNOLD 167 OLD TOWN ROAD GA~DNERS, PA 17324 Your house (real estate) at 167 Old Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 AM in the CO~4ISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $82,292.98, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTJ~_ ' Yo~ MAY R~ ABL~ TO pR~VF~NT THIS ~W.~TFF'S S~T.'~--- To prevent this Sheriff's Sale, you must take 1. The sale will be cancelled if you pay to the mortgagee the hack payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) NARK J. UDP~EN& ASSOCIATES BY= Mark J udren, Esquire AT~"f I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP~tY HILL, NJ 08034 856-482-6900 wells Fargo Home Mortgage, Inc. F/K/A Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC. 28217 Plaintiff V. Thomas R. Ford wend¥ S. Arnold 167 Old Town Road Garclners, PA 17324 Defendant(s) ATTOP/~EY FOR pLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland county MORTGAGE FOP~ECLOSURE NO. 01-2765 Civil Term ~CrYICE OF .~Tm~TFF"S ~aT,~ O17 pRaT, PROP~R~'Y TO: THOMAS R. FOP/) 167 OLD TOWN ROAD GA~DNERS, PA 17324 Your house (real estate) at 167 01~ Town Road, Gardners, PA 17324 is scheduled to be sold at the Sheriff~s Sale on December 5, 2001, at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CAttLISLE, PA to. enforce the court judgment, of $82,292.98, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTI~ OF O~'S TO prevent this Sheriff's Sale, ~ou must 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 ouch ~ you must pay, you may call: 1~6} 48~-~900. 2. You may be able to stop the sale by filin~ 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 ~he 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.) WRIT OF EXE'CUTJ0N and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy the debt. inlerest and costs due NO. 01-2765 CIVIL 1~:X TER'~I CIVIL ACTION - LAW COUNTY: I~11~ Fargo Hcme Mortgage, Inc. PLAINTIFF(S) from Thomas R. Foz~ and Wendy S. Arnold, 167 Old Town Road, Gardners, PA 17324 DEFENDANT(S) (1) You are directed to levy upon the property gl the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the delendant(s) not levied upon in the possession o! __ GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account gl the defendant(s) and from delivering any property of the delendant(s) or othenvise disposing thereof; (3) If properlyof the delendant(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 $82,292.98 f~u,% 6/15/01 to 12/5/01 Interest oe_~ A-~m ~ $17.19 - S2,991.06 Atty's Comm % Atty Paid $116.00 Plaintiff Paid Date: Auqust 6, 2001 REQUESTING PARTY: Name Address: Attorney for: Telephone: Supreme Court ID No. ~ .~. Y]d~. Esq. 1040 N. Kinqs Hi.qhway, Suite 500 Ch,~r~ H4ll~ NJ 08034 p1 a~ntif f 856-482-6~00 04302 $.50 L.L. Due Prothy $1.00 Other Costs Prothonotary. Civil Division REAL ESTATE SALE No. Io Gardners and more :-',, this writ and by this refer..,, 3ate: Sept. 10, 2001 [,ill Sept. ~0, 200~ the sheriff levied ul~on the deien~m. interest in the real property situated in ~o,,~. ~,~.~,~ ~umbedand County, Pa., known and numbered -,~cribed on Exhibit "A" filed with '~nroorated herein. Re/aZ ~-state Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L, Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News 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 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 MisceJJaneous Book 'M', Volume 14, Page 317. PUBLICATION ............................................................................................... COPY sm,,;,, L~, a,,,; v~'_£~~_ ~'~ -~-L-~:,r~ me h~his 19th da~y'of N~ovember 2001 A.D. S k L E #10 NO~A~RY PUBLIC ILEAL EBTAI~ ~l%.E Ne. 10 · ~lt I~, ~14/~ IJ..,,{,.,. ~':...._,_._,_ ,____... CMITm. '~"'""'~"aam"a"~t~lS~cornrnlsslon expires June 6, 2002 WIre F.~. It.me Kine,, 11mmK Fssl dcled' ~ Old lb~ Ilmd..id c~ Iminl m ~ 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 Nota~/ Fee(s) Total $ 205.44 $ 1.50 $ 206.94 Publlaher'a Receipt for Advertialng Coat The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of thc 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. PEAL ESTATE K~LE NO. 10 Wrlt No. 20OI-2765 Civil Wells Fargo Home Mortgage. Inc. f/k/a Nor, vest Mortgage. Inc. Thomas R. Ford and Wendy S. Arnold Atty.: Mark J. Udren ALL THAT CERTAIN tract of land wl~ Improvements thereon erected situate in South Mlddleton Town- ship. Cumberland County. Pennsyl- vania, bounded and described as follows: BEGINNING at a stone corner on the southern side of the Old Town Road, said Corner being on the Northern Boundary line of a larger tract of land of which the wlthln de- scribed premises was a part: thence North 57 degrees 15 minutes East, 158 feet to a stake on the northern side of said road; thence by land now or formerly of Lloyd M. Brandt and recro~sing said road. South 41 SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 LO~S E. S~'/O~R, No~,,~I ~ 'lo