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Home My WebLink About05-0584 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@Udren.com Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass- Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Carter Harrison 313 Lamp Post Lane NO. 0[; - SPL( Camp Hill, PA 17011 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE C t:;< L ~ 'tfL~ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AV1SO 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 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1CIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 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 tbis Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address ofthe original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 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: Option One Mortgage Corporation Assignments of Record to: Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Recording Date: 12/11/00 Book: 662 Page: 165 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: 313 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township COUNTY: Cumberland DATE EXECUTED: OS/21/99 DATE RECORDED: OS/26/99 BOOK: 1544 OF Hampden PAGE: 886 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 Mortgage 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 12/27/04: Principal of debt due Unpaid Interest at 10.99% * from 12/1/03 to 12/27/04 (the per diem interest accruing on this debt is $26.23 and that sum should be added each day after 12/27/04) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $99.50 and that sum should be added on the first of each month after 12/27/04) Late Charges (monthly late charge of $51.01 should be added in accordance with the terms of the note each month after 12/27/04) Total Fees $87,126.42 10,283.46 325.00 280.00 8,434.96 NSF Fee Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 662.97 608.20 20,00 4.356.32 $112,097.33 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8, The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the plaintiff demands judgment, in rem, against the Defendant(sl herein in the sum of $112,097.33 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ^ , , Mark J. Udre , ES UIRE UDREN LAW OF ICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL' THAT CERTAIN PIECE OR PARCEL OF LAND, WITH IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE AT THE DIVIDING LINE BETWEEN LOT NOS, 9 AND 10, BLOCK "H" OF THE HEREINAFTER MENTIONED PLAN, WHICH POINT IS 627.23 FEET IN A NORTHWESTERLY DIRECTION FROM THE SOUTHWESTERLY CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE OF THE PLAN, THENCE BY SAID DIVIDING LINE SOUTH 35 DEGREES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BLOCK "H" OF THE PLAN, THENCE ALONG LOTS NOS. 13 AND 12, NORTH 59 DEGREES, 30 MINUTES WEST 100,33 FEET TO THE DIVIDING LINE BETWEEN LOTS NO.S 10 AND 11, BLOCK "H" OF THE PLAN, THENCE BY SAID DIVIDING LINE NORTH 35 DEGREES, 10 MINUTES EAST 121.43 FEET TO A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE, THENCE BY SAME SOUTH 54 DEGREES, 50 MINUTES EAST 100 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NO. 9 AND 10, BLOCK "H" OF THE PLAN, THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK "H", PLAN 4 OF PINE BROOK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 15 PAGE 41. ';'t" \~ . December 30, 2004 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thh. i~ an official notice thnt the mnrtrJIep on your homp i~ in rlpfanttr snit thE" Ipnnp.r intends to forpdo~p. Spprific information ahout thp. nD1nrp. of thE" ()pfanlt i~ provirlpn in the attftC'hprl P3f~~ Th.. HOMF,OWNF,RO~ MORTr;Ar.R A~~ISTANr.R PROr.RAM CHF.MAP) roilY h.. ahle to help to savp yonr home This Noticp pyplains how thp program works. 1'0 spp if Hlf,M A P ('$In helpr yon mllst MRRT WITH A C::ONSTTMF,R CRF,fiT"f r.mlNSRLTNr. Ar.RNr.V WITHIN "0 DA VS OF THR DATF, OF THIS NOTJr.F Tak.. this Notif'p. with Y011 when yon mppt with the rOJJnsp.lin~ AfPnry The nsmp, arlrlrPS.s Sind phone nnmhPT llY CnnsnmeT CrP.rlit C'nnnsplinft Ae:r.neies sprvil'l~ yonT ronnty arP lidPll sit the Phil of this Notir.e. If yon have Rny qJl~tinns.r yon may "'$111 the Pennsylv9niJl Hnnsin~ FinDncp A~pn('y ton frpp. at 1..HOO..:\42..2::\97 f}>ersons with irnpairp.tI h..l1Ml1g Cl1n call (717) 7RO-1 Rfi9). 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 DERECHO 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 ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNERDs EMERGENCY MORTGAGE ASSISTANCE PROGRAMD EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU IllPOTECA. EXHIBIT A Page 10f6 HOMEOWNER'S NAME(S): Eric Taylor __Sb:!r!!U'..l'llyIQL__.._,_"_,__,,,,_,_,,_,__.. 202 Park Avenue _Wi!~!c'!i_~llrr~,J,>AJ.s2!!~:49_22_______________,_ QQlmJ42<1_'_'________'_______ ,_Q1!ljQ!!,.Q.!!~MQrt,gllg~(;QrpQr.l!tiQ!!____-.,"_"'_"__ Wells Fargo Bank Minnesota National Association as Trustee for Option One Woodbridge Loan Trust _2QQ4:1Asset,Bll!;k~d,C_~rl:il'i~IlWiiS~ri!c'!i2004:1 PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: HOMEOWNERDS EMERGENCY MORTGAGE ASSISTANCE PROGRAM VOl] MAY RR RUc;mT,R FOR FINANCIAl. ASSISTANCR WHICH rA N SA VR VOTJR HOMF, FROM FORRCI .OSTJRF, A NO HRl.P YOn MA KR FJ1TJ1RR MORTc;Ac;R PA VMRNTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE []ACTO), YOU MAV BE ELJGmLE 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 ELJGmILITY REQUIREMENTS ESTABLJSHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TRMPORARV STAY OF FORRrl.OSJ1RR.- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Dface-to-faceD rneeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MRRTTNc; MJ]ST OrrJ1R WITHIN THR NRXT (~O) OA VS, TF YOl j DO NOT APPT Y FOR FMERGENry MORTGAGE ASSTSTANrE YOlT MTTSTRRTNG VOlJR MORTGAGF TTPTO OATF TIfF PART OFTHTS NOTTrF rAT T EO DHOW TO rTTRE YOlTR MORTGAGE OEFATTT.TD FXPT ATNS HOW TO RRTNG VOlTR MORTGAGF TTP TO DATE rONSTTMRR rRROIT ronNSRI,INc; AC;RNrms .- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. Th" nBm'" Bllel,,,,,,,, Bnc1 tel"phnne nnmhPTS of nP:"iV1~tP:ri c;nnl;.;.nmf>:T r.Tp.rlit {,()lln~p:line t"Jep:nr.i~s for thp, rnnnty in whir.h thp. prnpf":rty is Inc;;1tf"ll Bee ,,,t forth 2t th" "nc1 of this Nntir". It is only necessary to schedule one face-to-face meeting. Advise your lender immec1i2t"ly of your intentions. APPl.WATTON FOR MORTc;Ac;R ASSTSTANrR .. Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the Page 2 of6 program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. YOU MTJi'\T FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGRNCV ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO f:lJRR YOUR MORTGAGE DEFAITT,T (Rrin~ it lip to date). NA'fTTRF OF THF ORFATJT.T -- The MORTGAGE debt held by the above lender on your property located at: 202 Park Avenue Wilkes Barre, P A 18702.4929 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: ..,.MQ,nth!y,P!ll'ID~11~,of$187d.sJQr.Jun~J>J@4J!!ruJI~~~mb~r...l,J!!!!'L"'$z!Uz,lS_",,__ _,.MQ,n,thlY_L,!!~"(;.!!JJm,s_oI.$J_7,2Ho.r_J!!n~t,,Z!!!M.fur!!,P!l~~m_!!!'r,J,..2!!!!~L",$lz!!,7S__,__, Other charges (explain/itemize): Escrow Advance=$2584.16 NSF Fee=$20.00 ,A~cU!Du!ate!!L!!~,(;JI!!rg~s",$17,2S"_,.,,,_,____,__,__ ",TQTAL AMQPNT_PAST DUE: ."""..,.,."__......".._$4~11.7~ .. B. YOU HAVE FAfLED TO TAKE THE FOLLOWING ACTION (Do not l1S~ if not "W1ir"hlp): JSLA HOW TO CTJRF TIfF OFF A TIT ,T -. You may cure the default within THIRTY (30) DAYS of the date of this notice BV PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS !I;4<:;11.7;; PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WmCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P~ymf>nt" mll"t hf': mac1f': ~1thf>r hy r.::Jf\n r.;l",hlpr'<;; ~h~~k rp.Tiifip.n rhp.ck nr mnn~y nrnp.r m::anp ray::ahle: :mcl ~~ntt()' TJrlrpn T.QW Offic.p~r P r. Wnnrlcrpd C..cu:pnratp. CpnteT 111 Woor!rrpst Roar! i'\lIitp 200 Cherry Hill, Nl 01100'1-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not I1SP ifnot "pplir."hlp )', JSLA Page 3 of6 TF yon 00 NOT cnRF THF. OFF ATJT ,T -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, thp ]pnrlpr intpnrl, to pxprd,p it, ,.;,;.to to accplpratp thp mort;gaw r1pht This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in 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 foree.lo~p. upon yonr rnortg'a~rI property. TF THF MORTC.AC.F TS FORFCT ,OSRO TJPON .- The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the arnount you owe the lender, which may also include other reasonable costs. If YOII I'IITP the rlefsnllt within thp TmRTV (~O) nA V pPriorl yon will not hE' required to p~y attornpy'~ fp.p.~ OTHRR T .FNTlRR RFMFOTFS -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RTC.HT TO nJRF THR ORF A TJT.T PRTOR TO SHRRTFF'S SA T .R -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ynn <till have the rieht tn CnTf' thf': clf':fanlt :mcl prf>vf>nt thf> !':alp. at :my timp. np to nnp: honr hf'foTf': thf' Shf':rifr~ Salf': Vrm may no ~() hy paYlne thp. total amount thp:n pas:t nllf': pIll" :my latp: or othf':T charef>!': thpn elm' Tf'H!':on::lhlf': ::lttnmpy'" ff':f':!': :mcl (':o!':t" r.nnnpctp;o with thp. fnTf'C':lo"l1Tf': !':alp :lnrl any othf'T r.o!':t" r.onnf':ctpIl with thf> Shf':riff"" Salp. :l!': "pp:C':lfif':cI in writlne hy {hI'" Ip:nnf':T :mrl hy pp.rfnnnln~ any othf>T n~qJ1irf':mf':nt" nnnf':T thf> moTte-fiEf':, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. RART.TRST POSSTRT.F. SHRRTFF'S SAT.F OATF -- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately Ii months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THF, T.FNllRR. Name of LenderlServicer: Address: Phone Number: Fax Number: Contact Person: ....QpP())'-Q!!eMortg1!ge,C!!!l!!!f1!ti!lIl.........,......__ """""..", 4600 Touchton Road E Building 200 Suite 102 ..J!!c~()!!yjIJ.!'~fL~2Z4!!,....m.... """""......",.... "",'lQ4,99!!,:.l73Jt extjjI 730"""..",..".."""",..""""" J!!!!!:''I.'l7:12!!3 "",.., ",C!!~t!!lI!.ef,.se,rnc,e",........,.... RFFF.CT OF SHF.RTFF'S SAT ,R -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time, ASSnMPTTON OF MORTC.AC.R -- You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of6 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of6 YOlJ MA Y AI,SO HAVE THR RIGHT. . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF 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 OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE 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. rONSTJMRR rRRnTT rOlTNSRUNG AGRNrTF.S SFRVTNG YOTJR rOTJNTV T .T1ZFRNF, COUNTY CCCS of Northeastern Pennsylvania 31 W. Market Street/P.O. Box 1 ]27 Wilkes-Barre, PA 18702 (570) 821-0837 OR ]-800-922-9537 FAX (570) 821-1785 CCCS of Northeastern Pennsylvania 1400 Abington Executive Park, Suite 1 Clarks Summitt, PAl 841 1 (570) 587 -8163 or 800-922-9537 FAX (570) 587-9134/9135 Comm. on Econ Opportunity of Luzeroe County ] 63 Amber Lane Wilkes-Barre, Pennsylvania 18702 (570) 826-0510 OR 1-800-822-0359 FAX (570) 829-] 665--CALL BEFORE FAXING/(570) 455-4994 HAZELTON/FAX (570) 455-5631-CALL BEFORE FAXING/(570) 836-4090 TUNKHANNOCK EOC of Scbuylkill County 225 North Centre Street Pottsville, PA 17901 (570) 622-1995 FAX (570) 622-0429 Page6of6 \jJ r;:: -- ~ v\J -==::'\ 1- ,- ;;t' -0 n ~ ~~ 5 1;, )~ ~ ~ -cJ -v -""'" ')> 0 - Vl \ - --'\' ) c ~ - ./ 1\ )\ (:, <::) 0 tJ "; .., ~ i,.'" j-' -f:- () ;-. -J G ,-----' '0 :J \,...., - ~ vi 0- ~ ~ '" 0 Oc o:=go :L:..-/o.:D:D m"",mm :D""cnZ :D0.....s;; -<00< :1:00< r=O::oc r-::IJ -0 '""t. . mo ~~f .~ o :c -- :n 0) 0 r-" <:>)> '0 80";0 "z' ..... rn ..JJ ..D U1 U1 "" "" CJ CJ ..JJ ..D "" "" m m cO cO "" "" CJ CJ CJ c::J CJ c::J 0 c::J U1 U1 m m .-'l .-'l "" ::r 0 r:J CJ c::J l"- I"- U.S. Postal Service", CERTIFIED MAIL" RECEIPT (DomestIc Mail Only; No Insurance Coverage ProvIded) SI= Certified Fee \15 PQ$tmark He", Return Reciept, Fee (Endorsement ReqUIred) Restrtcted De\\ve1y, Fee (Endorsement ReqUIred) Total Postage & Fees $ ;~~;!:C;0-~~c..~Q,CL~o.~,.......,... ci&-:'s;aiB:ZI..........n..~.n..~1fA.?;\'l.5hm 'tJ (J) ." o '3 '" (Xl ~ ~ . ." . m ~ 2" @ w or -< !l '" o o .... 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(~j .S9P!^OJd I!ew P9!1!1.I9:J ~ r I I I I I I I II I ~._--."",.;,._'",",- V E R I FIe A T ION 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. Udr n, QUIRE UDREN LAW OFFICES, P.C. . ~ ~ {0 1- ~ 0 h ~"1'\ - ~ C> ~, r 1'"'\1 0 C,.'O - -0 \ 7S ..() fV r- ~~: $: , " ,t- "---'-- UDREN LAW OFFICES, P.C. BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@Udren.com Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term v. Carter Harrison Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure upon Defendant, Carter Harrison by regular mail and certified mail and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant at 313 Lamp Post: Lane, Camp Hill, PA 17011, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit "AU. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "B". 3. Said investigation was unable to determine an alternate address for said Defendant. 4. The last known address of Defendant is as set forth in the attached Exhibits, WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R,C,P, 430 directing service of the Complaint in Mortgage Foreclosure upon said Defendant, Carter Harrison by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. By: Mark J. U r D, Esquire Attorney for P aintiff UDREN LAW OFFICES, P,C. BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term v. Carter Harrison Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made, NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976), Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address, Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, records, and motor vehicle records. local tax As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage Foreclosure. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. By: Mark J, Udren, Esq ire Attorney for Plaintiff ;::itl.bK.l..t'.t'. b ,K..I:.J.U.tU\J - J.'\IV.L. J."VUJ.U.J CASE NO: 2005-00584 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HARRISON CARTER but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT f HARRISON CAR,TER 313 LAMP POST LANE CAMP HILL, PA 17011 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE TO SERVE DEFENDANT, HE WAS NOT FOUND AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge So ans~~2~? ~~ R. Thomas Kline Sheriff of Cumberland County 18.00 38.48 5.00 10.00 ,00 71.48 UDREN LAW OFFICE 03/07/2005 Sworn and subscribed to before me this day of A.D, Prothonotary EXHIBIT A - - -- ....... - - ....... .:...0. -- - - - -..... - ......... ............ ....... .- ...... - -- - - ...... - ...... ....... - - .- - - - .- - -- ...... ..... - - - - - - ........ .....,.. - --" - - - - -... ....... Players National Locator, Inc. . AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 04120554 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number: . Subject: Carter Harrison A.K.A.: Carter H Harrison Last Known Address: 313 Lamp Post Lane Camp Hili, PA 17011 Last Known Number: (717) 761-6843 Melissa Kozma, being duly sworn according to law, deposes and says: 1, I am employed in the capacity of Location Specialist for Players National Locator, Inc, 2 On 02/28/2005, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION- A. SOCIAL SECURITY NUMBER(S):129-38-6129 B. EMPLOYMENT SEARCH: We were unable to verify current employment for Carter Harrison. C INQUIRY OF CREDITORS: Creditors Indicated the last reported address for Carter Harrison is 313 Lamp Post Lane, Camp Hill, PA 17011, with the home number of (717) 761-6843. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH The home number for Carter Harrison is (717) 761-6843. registered to 313 Lamp Post Lane, Camp Hill, PA 17011. We called the home number and spoke with Carter who stated he is living at 313 Lamp Post Lane, Camp Hill, PA 17011. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of February 25, 2005 the National Change of Address (NCOA) has no change for Carter Harrison from 313 Lamp Post Lane, Camp Hill, PA 17011. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Motor Vehicles has Carter Harrison listed at 313 Lamp Post Lane, Camp Hill, PA 17011. OTHER INQUIRIES. A. DEATH RECORDS: As of February 25, 2005 the Social Security Administration has no death record on file for Carter Harrison and/or A.K.A's under the social security number provided. eXHIBIT 18 1Er-, 8LO/1I0d 191-1 8>50 OEI 9E9 uoq'!JOSSV s,Ja~"ld-wOJ, W"6E:OL ,0-81-qa, -B PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC, ): None Found. C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Carter Harrison listed at 313 Lamp Post Lane, Camp Hili, PA 17011. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BiRTH: June 1958 A "NOTARY SEAL" Kristine M. Sco\I, NotarY P~b"c . 51. \.ouis Cou~ty, Sta,te Of ~l:,~1 My CommisSIon Explles 9/..~uv Players National Locator, Inc. 174 Clarkson Road, Suite 225 St.Louis, MO 63011 Phone: (636)230-9922 Fax: (636)230-0558 lEv-~ BIO/BIO'd 19l-1 8150 OEl 9t9 UOI1"I'OSSV s,Ja~eld-WoJ~ weOV:OI gO-Bl-qa~ VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his kno",ledge, information and belief, The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark J. Udr Attorney for Date: sf;jO!5 UDREN LAW OFFICES, P.C. BY: Mark J. Udren ESQUIRE ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO, 05-584 civil term v. Carter Harrison Defendant(s) CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: ~ Regular First Class Mail Certified Mail Other Date Served: ..J/lt/o5 TO: Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 UDREN LAW f"'') .: ' J,-:-" :J' c.) I.,: "I ~'I C,) ,;,Iv:J 5 2.005 MAR 1 IN THE COURT OF COMMON PLEAS OF Cumberland COUNT. CIVIL DIVISION Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff NO. 05-584 civil term v. Carter Harrison Defendant(s) o R D E R (Yl~ } ~ f'.A this day of AND NOW, , 2005, upon consideration of Plaintiff's Motion and the Affidavit of G od Faith investigation attached hereto, it is hereby ORDERED that s rvice of the Complaint in Mortgage Foreclosure and all subsequent p eadings on Defendant, Carter Harrison, shall be complete when Pla'ntiff or its counselor agent has mailed true and correct copie of the Complaint in Mortgage Foreclosure and all subsequent plea ings by certified mail and regular mail to the last known ad ress of Defendant, Carter Harrison at 313 Lamp Post Lane, Camp ill, PA 17011 and by posting the mortgaged premises located at 13 Lamp Post Lane, (Hampden Township) Camp ~~ Lfl\~ A ( . }'b-O' o'~ J. }J1"il'Y '1 Z :0\ W~ 8 Z ~'~lA SfiUl ^Bc;hO>~C:\-'I,i.Odd 3'rll dO 3'JdcO-CBl\:l UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff v. Carter Harrison Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PEAS CIVIL DIVISION Cumberland County NO. 05-584 civil erm PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-ca tioned matter. DATE: March 31, 2005 FICES, .C. Mark J. iUdren, ESQU RE ATTORN Y FOR PLAINT FF ,-.~ ..., '-'. -~" ') SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-00584 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS - - HARRISON CARTER - R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent se rch and inquiry for the within named DEFENDANT - HARRISON CARTER but was - unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , HARRISON CARTER - 313 LAMP POST LANE - - CAMP HILL, PA 17011 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE TO SERVE DEFENDANT, HE WAS NOT FOUND AT GIVEN ADDRESS. - Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 38.48 5.00 10.00 .00 71.48 So answers: ._,""" /~,;;> .,./ ~.> - A::;"~~.;;=::::;'- ~-"-:r'__/{'~'" R. Thomas Kline Sheriff of Cumberland County UDREN LAW OFFICE 03/07/2005 Sworn and subscribed to before me this '1 day of 7IJ~ c1{)9IfA.D. ~mt!J::/"''''r ~ SHERIFF'S RETURN - REGULAR CASE NO: 2005-00584 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HARRISON CARTER ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HARRISON CARTER t e DEFENDANT , at 1450:00 HOURS, on the 7th day of A ril 2005 at 313 LAMP POST LANE CAMP HILL, PA 17011 by handing to POSTED PROPERTY AT 313 LAMP POST LANE CAMP HILL a true and attested copy of COMPLAINT -- MORT FORE together with and at the same time directing His attention to the contents th reof. Sheriff's Costs: Docketing Service Posting Surcharge 18.00 9.62 6.00 10.00 .00 43.62 So Answers: .~~~ R. Thomas Kline 04/08/2005 UDREN LAW OFFICES Sworn and Subscribed to before me this 1/ day of ~ \ Deputy Sheriff t~. . :< €? D j---- ?1\-d." .~ Prothonotary A.D. -~ ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term v. Carter Harrison Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. UD DATED: May 13, 2005 BY Mark J. Udren, Esquire Attorney for Plaintiff " V E R I F I CAT ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 0~~~ Na~' Title: Company: Carter Harrison Loan #0001693340 MJU #04120554 --- ----- ~"' .." ...--:. "{..;~ (f' - ~REN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ OB003-3620 856-669-5400 Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 05-584 civil term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Carter Harrison for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 12/28/04 to 05/13/05 Late charges per Complaint From 12/28/04 to 05/13/05 Escrow payment per Complaint From 12/28/04 to 05/13/05 TOTAL I hereby certify that (1) Defendant are as shown above, and accordance with Rule 237.1, a c DAMAGES ARE HEREBY ASSESSED AS DATE: (Yl';:}i /'1 260S I $112,097.33 3,593.51 204.04 497.50 $116,392.38 in ~. UDREN LAW OFFICES, P.C. BY, Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff ATTORNEY FOR PLAINTIFF v. j COURT OF COMMON PLEAS j CIVIL DIVISION County 1 NO. 05-584 civil term Carter Harrison Defendant(s) Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 DATE of Notice: May 2, 2005 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION /J'RACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS ~S AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED/FOR THAT PURPOSE. s . ren, Woodcrest Corpora ill Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Cert~f~cates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 05-584 civil term v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF COUNTY OF SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon invest~gations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Carter Harrison Age: Over 18 Residence: As captioned above Employment: Unknown Nam:i1~ Title: Company: Sworn to and subscribed before-we~his ,~ dqy of t-c.- , 200::5. . ~p.~-:\ r ~ Cd" 011512007 , 'I ;.-.!:'1'~_ ~ffI& 1. ()O)432-42S4: i -~~:'-E ft"'nced U\N (8 1"I.,lnc i . :: ~~ V'"' . . ~rJA55 ....._ . ~~h l~ fl,'iI1;'3 hat, ...u.... i ~,,',',,~:,":;,"~ ......~.......... ~............. ~ -4 ~~ -D \) Q r'" c) c.:1 - - G-J -J ..;;.;3 -,1 I' '0 ' \"' V\ -.. r ..c:, - r -,".. - ~ ~ V) --' --..() J Q.J ~ .. - - f'..) 0.~ ,," ,.~~u ~~... ~::'~;':~"~~.~/"-~. ---------. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 05-584 civil term TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 05/14/05 to Date of Sale 09/07/05 Per diem @$26.23 $116.392.38 3.068.91 (Costs to be added) $ f':,J ~ \ If \' ~ w ..r::: VI S ~ Y-' ? . /rl :r ~ l 70P ~~ -- 1: ...::t -{Q. ~ '-.l.....()~ -- ""'" "'-' -- V( :"'- ...:t ~ . . 0J \) "l Q \r1 r ..J:. \) - ~ c; \) () \) C- O \i 0- j ~~ I , \ "(-i) "- T - 1- " - ~J- '" . - - - ::. - - -- , 1")- C'-: - WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-584 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA F/K1A NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION SASCO MORTGAGE LOAN TRUST 1999-BC4 MORTGAGE P ASS-THROUGH CERTIFICATES, SERIES 1999-BC4, Plaintiff (s) From CARTER HARRISON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $116,392.38 L.L. $.50 Interest FROM 5/14/05 TO DATE OF SALE 917105 - PER DIEM @$26.23 - $3,068.91 Atty's Comm % Due Prothy $1.00 Atty Paid $197.10 Plaintiff Paid Date: MAY 17, 2005 Other Costs CURTIS R. LONG (Seal) ProthonotarY ~ ~y Arv,..,p ,P 'l?/?,/T. / Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No, 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO. 05-584 civil term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant x Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. P.C. rk J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ~ () C::;;':'l ---rj cr' -< '" <..n UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO. 05-58.4 civil term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4, 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: 313 Lamp Post Lane, Camp Hill, (Hampden Township) PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Carter Harrison 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Township of Hampden 230 S. Sporting Hill Rd. Mechanicsburg, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address TenantslOccupants 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 13, 2005 lark J. Udren, ESQ. Attorney for Plaintiff JDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO. 05-584 civil term Defendant(s) NOTICE OF SHERIFF S SALE OF REAL PROPERTY TO: Carter Harrison 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 Your house (real estate) at 313 Lamp Post Lane, Camp Hill, (Hampden Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,392.38, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1, The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call: (856) 669-5400, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff1s Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling 856-669-5400, 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~1~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: August 2nd & August 3rd, 2005 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 11, 2005 Mar UDREN --. f:J MAR 1 5 2.005 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL DIVISION Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset NO. 05-584 civil term Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 Plaintiff v. Carter Harrison Defendant(s) .~ o R D E R (Yl~ 2005, upon consideration of day of " , . Pla~nt~ff's Mot~on I~ fV. AND NOW, this and the Affidavit of Good FaiLh investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant, Carter Harrison, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last kno"in address of Defendant, Carter Harrison at 313 Lamp Post Lane, Camp Hill, PA 17011 and by posting the mortgaged premises located at 313 Lamp Post Lane, (Hampden Township) Camp ~L J. /~' q~/J1;j :E o OC ()~CC ~():D ~~:D m<mm :D<cnZ :DO....... -<o())> ~c ::E -()o . :DO r:D'"tJ-n -zmo." 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NO. 04302 WOODCREST CORPORATE CENTER ~~l WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 plaintiff, by itslhislher 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 al:tached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 16, 2005 UDREN LAW OFFICES, P.C. BY: ^^ Mar J L.l~ren, EsquJ.re Atto n y for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) DATE: August 2, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): CARTER HARRISON PROPERTY: 313 L~p Post Lane, C~p Hill, (Hampden Township) PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 7, 2005, at 10: 00 AM, in the COMMISSIONERS HEARING ROOM, 2~ FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A " " ~~ ,," OE ,~ ~ :q enU. ~ =' ,~~ \ll 116:5 '~<J)u. ~ -= ,!a ~ IJ)O;S; ~ . .~ g''O c cr; $ ~= ~ a:u.. eo; ~ a 1! E'~ Cl "68 l1!; l~]o 1! 18 0.>1_ 11 en <..l ~~, ~ 8= h .2 1l~B .::t itG- ~ ~i!l'J " l'!- m" !ii:!=i-!~J!! > c: ~ca ~ ~::;8 ,<f;::. 0.'& 0. '!! fts~~ Cl ~t~~ U '5 U) :: 0 't %'a Un Moc ~ !l 0. '8 " i\;~ " ~"o~ n88 o DODD ~ ~ ,11 5 ~ " g 0:: ~ ~ '" Cl l) >- .", '" q..., f1) ...400:: c6'0::<'" ",00'" <J"'O::~ ii:~""'" "'0 <J Ill": ....0::... ~f1)l)-::! <"'0: ....5g>- ffio~~ o::g...'" 0"._.: :);.....u . -g(/1Q; .. '" '0 ~.,c -'" :gCIJ ~<o l--- I--'ir- '}.. '_~" !'-,-k~ ~ _~i"~,y- ~' ., e \ ". " u. ~ ~"3;\iiS-()d .~,..1'1 "~J:;,'~;~j "r'!>:)". ': -- 0 ,. I - !~~j\~ ,.. ... :: S '" -: SG,HnV ? ... ~/< I'~,' ~ 'i&llIl'" ~ '.' 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"hh~ ~l~~a-6 III 5 e..&; OJ ~~nS~' .1i.~. &. ~W CD$\!~ al"~i'gii ,~:oH ~]ei~~: ..hd~ SP":i~ >l.h~~ _D",,-E a"~.!\.-l1 "\8 ~~- .. ill ~'9 0 Jl ,,~., ~'(Sg.5~ '6a';jsm g19U~ hl~d ~d8j!,!i !3o.~'i 1-_ :t c ., ... c '0 ... 'Ii en k o " .s .: ! k ~ ,.. .... E ." I Q. e o <J ., ~ ';j ::l :E e k o u.. ~~ 0.0 "68 LD ~~ ..,. E~ ,,'" 8l z~ t! - ~ ::l .0 :g ,f ~ ~l\ ,..: "6 lZi ~ ... c>j E a" is -a~ u.. '" '" ..,. '" ~~ (/l - - ~ - a. EXHIBIT A 1 s ~ l i Q ~ ! ~~ J!l ~ E "8 0. Wells Fargo Bank Minnesota, f/kla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust I 999-BC4 Mortgage Pass Through Certificates, Series 1999-BC4 VS Carter Harrison The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-584 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2005 at 6:56 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above <~ntitled action, upon the within named defendant, to wit: Carter Harrison, by posting the premises located at 313 Lamp Post Lane, Camp HIlI, Cumberland County, Pennsylvania, pursuant to order of court, according to law. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on July 14,2005 at 4:15 o'clock P.M.;he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Carter Harrison, located at 313 Lamp Post Lane, Camp Hill, Pennsylvania, according to law. R, Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Carter Harrison, by regular mail to his last known address of 313 Lamp Post Lane, Camp Hill, P A 17011. This letter was mailed under the date of July 05, 2005 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of ;;.~~ R. Thomas Kline, Sheriff By~1!sJf~~ Real Estate ergeant 2005, A.D, Prothonotary EXHIBIT B ~. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~1~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 926l9-7038 Plaintiff J~TTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County (') c:: ~. ,..., = = <J' .",. c:: G") Q. -' ::L..... rn r:: :;?,8 ;.:::;, i co ':3Q _'--n :s ~2o -> ;G; m 4? ~ ?p o '-< N ri)t_ -z t/;: eo: v. ~;. '--, Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 , -'-" NO. 05-584 civil term :--~ -< Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: August 2nd & August 3"d, 2005 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August ll, 2005 ~ '0f EXHIBIT B UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~~1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-584 civil term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO Cmm.T ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: August 2nd & August 3rd, 2005 Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 11, 2005 P.C. Mar Esqu~re EXHIBIT B --- MAR 1 ,;,Iv:] 5 2DD5 IN THE COURT OF COMMON PLEAS OF CUlnberland COUNTY CIVIL DIVISION Wells Fargo Bank Minnesota f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securi~ies Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, series 1999-BC4 Plaim:iff NO. 05-584 civil term v. Carter Harrison Defendant(s) 0 R D E R }WD NOW, this ") Co fV. day of (Yi ~R. 2005, upon . consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant, Carter Harrison, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail T:O the last knowT, address of Defendant, Carter Harrison at 313 Lamp Post Lane, Camp Hill, PA 17011 and by posting the mortgaged premises located at 313 Lamp POSL: Lane! (Hampden Township) Camp Hill, P.h 17011, /~ ~a~T: ,q / \ I J. EXHIBIT B I~' (jJ!d/7l /J :!E o Oc:: ()_CC -()~ :t.......:c..., m.c::mm :D<cnz :oO-lr- -<O()~ :r00< j=():c0 .-:c"'C~ . mO" zoo :!! <---l::tl() o~~m g:Om!J' C>~()-o LlOmh 2" -l n :1 .., 0 () OJ () ~ I-' OJ OJ " rt I:-' (j) ~ PJ " ",. S f-''O ~ f-' OJ '0 " Z o " t ~ tIl "'. 0 PJ rt tIl .., n S 0 H r '0 I:-' ;'j n n P,PJ t>;I " (j) ;'j ~ :::J (j) 0 p " "l " >-3 r 0 tIl - 3 III u t>;I - rn ~ ::r H "', "J '0 "l ill '0 tIl :.< ll" I-' t:" -.J 17;1 ~ ~ U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mall Only: No Insurance Coverage ProVIded) mm mm mm ~ ~ C'"'O""F"'F"'j'"c"TA'T'""""'U'''S'''E ~ ~ . ru ru Postage $ I ).7 ru ru Certffied Fee "7 C; 0 0 0 0 Retum Receipt Fee - 0' 0 (ErWtnernent. RequIred) \.7 r- Ho.. 0 0 Reslrlcted Delivery Fee 0- ,0- (E:ndClrsement RequIred) m m 0 0 Total postage & Fees $ '-(, Ll1 o o r'- d~TO o Carter Harrison f"'"- 33..3 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 EXHIBIT B I~' (k4? /) Cll ~. ,.. . . . ." ~~. 1: O>0-a~C') 0 3 -.,:= O::LCD 0 ~ .. ~ g g:;: ~ 3 3 . Co> ~% 0"'0 6: -~::ra~ ~:o OJ p . "' . CD :r:e c: =;;--1 ~ .@ '" " c. .... ~ ~ " i! ~iirCD"':Oifl : t<. OO~sm;:;' ;:' "'. 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EXH!B\TB A C1 C' ....' .,:::::;, ,:::::J <:_,.1 ~ C'~. (I"') t'-,.) U::' :;':J'" :l~ C,:} o -n --l :I:"T' rnp -.,-.,(r] ~-~.>~r./ ') 1,') -:,C_ ~. --: .' I 1 _ :1 <~~fl?\ ~ ,~ :-<. o COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Central Penn Propertv Services Inc is the grantee the same having been sold to said grantee on the 7th day ofDec A,D" 2005, under and by virtue of a writ Execution issued on the 17th day of Mav, A.D., 2005, out ofthe Court of Common Pleas of said County as of Civil Term, 2005 Number 584, at the suit ofWeJls Fargo bank Minnesota against Carter Harrison is duly recorded in Deed Book No, 272, Page 4072, IN TESTIMONY WHEREOF, I have hereunto set my hand -zil and seal of said office this / 'i day of 1. ., , A.D, .;zcJut lv' ecorder of Deeds Recorder of oeds, Cumbel1an<l County Carlisle PA My Commiss Expires the First Mo....y of Jan.' ,},O/() Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass Through Certificates, Series 1999-BC4 VS Carter Harrison The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2005-584 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2005 at 6:56 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Carter Harrison, by posting the premises located at 313 Lamp Post Lane, Camp HIll, Cumberland County, Pennsylvania, pursuant to order of court, according to law. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on July 14,2005 at 4:15 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Carter Harrison, located at 313 Lamp Post Lane, Camp Hill, Pennsylvania, according to law, R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Carter Harrison, by regular mail to his last known address of 313 Lamp Post Lane, Camp Hill, PA 17011. This letter was mailed under the date of July 05, 2005 and never returned to the Sheriffs Office, R, Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 7, 2005 at 10:00 o'clock A.M. He sold the same for the sum of$129,373.00 to Central Penn Property Services, Inc. It being the highest bid and best price received for the same, Central Penn Property Services Inc, of 100 S. 7th Street, Akron, PA 17501, being the buyer in this execution, paid to SheriffR, Thomas Kline the sum of $135,788.26. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library $30,00 2,587.46 15.00 15,00 30,00 10.00 .50 Prothonotary Mileage Certified Mail Levy Surcharge Posting Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 1.00 20.80 4.11 15,00 20.00 6.00 383.00 327.23 18.20 25.00 39.50 $3,547.80 Sworn and subscribed to before me 2000, A.D. . p~~ R. Thomas Kline, Sheriff BY vcd.. C( ),IVt:d C1 Real Estate Sergeant p" wJ- UV 30, /0 \7 r t.k s J. r.O 6 . () 1j:J-O'i jC(u,/ '. I . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF , Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v, Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO. 05-584 civil term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4, 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: 313 Lamp Post Lane, Camp Hill, (Hampden Township) PA 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Carter Harrison 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None . '4, Name and address of the last recorded holder of every mortgage of record: Name Address . Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Township of Hampden 230 S. Sporting Hill Rd. Mechanicsburg, PA 17055 6. Name and address of the property and whose Name every other person who has any record interest interest may be affected by the sale: Address in Real Estate Tax Dept. 1 Courthouse Sq, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address TenantslOccupants 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 13, 2005 .ark J. Udren, ESQ, Attorney for Plaintiff L_ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota flkla Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates, Series 1999-BC4 P.O. Box 57038 Irvine, CA 92619-7038 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Camp Hill, PA 17011 NO, 05-584 civil term Defendant(s) NOTICE OF SHERIFF S SALE OF REAL PROPERTY TO: Carter Harrison 313 Lamp Post Lane Camp Hill, (Hampden Township) PA 17011 Your house (real estate) at 313 Lamp Post Lane, Camp Hill, (Hampden Township) PA 17011 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 AM in the commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,392.38, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call, (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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.) WRIT OF EXECUTION and70r ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA F/K1 A NO 05-584 Civil CIVIL ACTION - LAW NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION SASCO MORTGAGE LOAN TRUST I 999-BC4 MORTGAGE P ASS-THROUGH CERTIFICATES, SERIES 1999-BC4, Plaintiff (s) From CARTER HARRISON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from payiug any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $116,392.38 L.L. $.50 Interest FROM 5/14/05 TO DATE OF SALE 9/7/05 - PER DIEM @$26.23 - $3,068.91 Atty's Comm % Due Prothy $1.00 Atty Paid $197.10 Plaintiff Paid Date: MAY 17, 2005 Other Costs CURTIS R. LONG (Seal) Prothono~ '-- By ~O"'- C' - p 7?!~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court 1D No. 04302 Real Estate Sale #58 On June 13,2005 the Sherifflevied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 313 Lamp Post Lane, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 13,2005 By:,j odJJ) S vvutLl Real EstateJDeputy ~\ ~ ~ hi:;': '" ,! "I j.J!dj,' j SCHEDULE OF DISTRIBUTION SALE NO. 58 Date Filed: January 06, 2006 Writ No, 2005-584 Civil Term Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association, as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999- BC4 Mortgage Pass Through Certificates, Series 1999-BC4 VS Carter Harrison 3 13 Lamp Post Lane Camp Hill, PA 17011 Sale Date: Buyer: Bid Price: December 7, 2005 Central Penn Property Services, Inc, $129,373.00 Real Debt: Interest: Attorney Costs: $116,392.38 3,068.91 197,10 Total: $119,658.39 DISTRIBUTION: Receipts: Cash on account (06/13/2005): Cash on account (12/07/2005): Cash on account (12/21/2005): $ 1,500.00 12,937,00 122,851.26 Total Receipts: $137,288.26 Disbursements: Sheriffs Costs Legal Search State Transfer Tax Local Transfer Tax Cumberland County Tax Claim Bureau Marie Huber, Tax Collector Attorney Mark Udren Wells Fargo Bank Minnesota Writ No. 2005-584 Carter Harrison Total Disbursements: Balance for distribution: So Answers: //~~~-., R. Thomas Kline Sheriff $ 3,547.80 200.00 1,813.90 1,813.90 2,393.40 454,53 1,500,00 \19,658.39 5,906.34 ($137,288.26) 0.00 " . TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITIING THEIR REMOVAL IS PRODUCED, SHERIFF SALE NO. 58 Held Wednesday, December 7, 2005 Date: December 7, 2005 T AXES: Receipts for all taxes for the years 2002 to 2004 inclusive. Taxes for the current year 2005. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. 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 , 2006, and recorded , 2006, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Carter Harrison and Guo Harrison, husband and wife, by deed dated April 19, 1999 and recorded May 26, 1999, in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania, in Deed Book 200, Page 211, granted and conveyed to Carter Harrison, single man. OTHER EXCEPTIONS: 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, Public and private rights in the roadbed of Lamp Post Lane, . 6. Building conditions, easements and restrictions as shown on or set forth with the Plan Four of Pine Brook as recorded in Plan Book 15, Page 41, 7, Mortgage in the amount of $90,000.00, given by Carter Harrison to Option One Mortgage Corporation, dated May 21,1999 and recorded May 26, 1999, in Mortgage Book 1544, Page 886. Said mortgage was assigned to Northwest Bank Minnesota, N,A., as Trustee, by instrument recorded December 11,2000 in Miscellaneous Record Book 662, Page 165, Complaint in mortgage foreclosure filed by Wells Fargo Bank Minnesota, formerly known as Northwest Bank Minnesota, N .A., as Trustee, as Plaintiff, against Carter Harrison as Defendant on February 2, 2005, in the Office of the Prothonotary of Cumberland County to File No. 2005-584. Judgment in the amount of $116,392.38 entered May 17,2005. 8, Judgment in the amount of $106,546, 19 entered by Wells Fargo Bank Minnesota, N,A., formerly known as Northwest Bank Minnesota, N,A" as Trustee, as Plaintiff, against Carter Harrison as Defendant, on January 2, 2002 to File No. 2001-6506, 9. Judgment in the amount of $102,788.01 entered by Wells Fargo Bank Minnesota, N.A., formerly known as Northwest Bank Minnesota, N,A., as Trustee, as Plaintiff, against Carter Harrison, as Defendant, to File No, 2003-2805. 10, Building and use restrictions imposed by Pine Tree Point, Inc., recorded in Miscellaneous Record Book 165, Page 677, II. Rights granted to PP&L by instrument recorded in Miscellaneous Record Book 168, Page 527, 12. Rights granted to Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 178, Page 132, 13. 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. 14, Real estate taxes accruing on and after January 1, 2006 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. I~:jj, - Robert G. Frey, Agent Note: This Title Report shall not be binding REAL ESTATE SALE NO. 58 Writ No, 2005-584 Civil Wells Fargo Bank Minnesota, fjkja Norwest Bank Minnesota. National Association as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999- BC4 Mortgage Pass-Through Certificates Series 1999-BC4 VS. Carter Hanison Atty.: Mark J, Udren ALL THAT CERTAIN piece or par- cel of land. with improvements there- on erected. situate in the Township of Hampden, County of Cumberland. State of Pennsylvania, more particu- larly described as follows, to wit: BEGINNING at a point on the southwesterly side of Lamp Post Lane at the dividing line between Lot Nos. 9 and 10, Block "H" of the hereinafter mentioned plan, which point is 627.23 feet in a northwest- erly direction from the southwest- erly comer of Carnage House Drive and Lamp Post Lane of the plan; thence by said dividing line South 35 degrees. 10 minutes West 113- .27 feet to a point at the line of Lot 13. Block ~H'" of the plan; thence along Lots Nos. 13 and 12. North 59 degrees. 30 miIlutes West 100- .33 feet to the dividing line between Lots Nos. 10 and 11. Block "H" of the plan; thence by said dividing line North 35 degrees. 10 minutes East 121.4-3 feet to a point on the south- westerly side of Lamp Post Lane; thence by same South 54 degrees. 50 minutes East 100 feet to a point at the dividing line between Lots No. g and 10. Block ~H" of the plan. the place of begirming, BEING all of Lot No. 10, Block "H". Plan 4 of Pine Brook as recorded in the Cumberland County Record- er's Office in Plan Book 15. Page 41. BEING KNOWN AS: 313 LamTi Post Lane. Camp Hill, (Hampde~ Township), PA 17011. "- PROPERTI ID NO,: 10.20-1848- 108, TITLE TO SAlD PREMISES IS VESTED IN Carter Hanison. single man by Deed from Carter Harrison and Guo Harrison. husband and wife dated 04/19/99 recorded 05/ 26(99 in Deed Book 200, Page 21!' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July IS, 22, 29, 2005 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. , , SWO~ 29 o AND SUBSCRIBED before me this day of Julv.2005 L SEAL LOIS E. SNYDER, Notary Public Carhsle Boro, Cumberland County My Commission E.pires March 5. 2009 REAL ESTATE SALE NO. 58 Writ No. 2005-584 Civil Wells Fargo Bank Minnesota, f/k/a Norwest Bank Minnesota, National Association as Trustee for Structured Asset Securities Corporation SASCO Mortgage Loan Trust 1999-BC4 Mortgage Pass-Through Certificates Series 1999~BC4 VB. Carter Harrison Atty.: Mark J, Udren ALL THAT CERTAIN piece or par- cel of land, with improvements there- on erected. situate in the Township of Hampden, County of Cumberland, State of Pennsylvania, more particu- larly described as follows, to wit: BEGINNING at a point on the southwesterly side of Lamp Post Lane at the dividing line between Lot Nos. 9 and 10, Block wH" of the hereinafter mentioned plan, which point is 627.23 feet in a northwest- erly direction fTOm the southwest- erly corner of Caniage House Drive and Lamp Post Lane of the plan; thence by said dJviding line South 35 degrees, 10 minutes West 113- .27 feet to a paint at the line of Lot 13, Block "H" of the plan; thence along Lots Nos. 13 and 12, North 59 degrees. 30 minutes West 100- .33 feet to the dividing line between Lots Nos. 10 and 11. Block "H" of the plan; thence by said dividing line North 35 degrees, 10 minutes East 121.43 feet to a point on the south- westerly side of Lamp Post Lane; thence by same South 54 degrees, 50 minutes East 100 feet to a point at the dividing line between Lots No. g and 10. Block "H" of the plan, the place of beginning. BEING an of Lot No. la, Block "H", Plan 4 afPine Brook as recorded in !.he Cumberland County Record- er's Office in Plan Book 15, Page 41. BEING KNOWN AS: 313 Lamp Post Lane, Camp Hill. (Hampden Township), PA 1701 L PROPERTY lD NO.: 10-20-1848- lOB, TITLE TO SAID PREMISES ]S VESTED IN Carter Harrtson, single man by Deed f,om Carter Harrjson and Guo Harrison, husband and wife dated 04/19/99 recorded 05/ 26/99 in Deed Book 200, Page 211. ..... "" . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State ofPeunsylvania, 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 19th and 26th day(s) of July and the 2nd day(s) of August 2005. 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 PUBLICATION COpy S ALE #58 Sworn to and subs NOT AR PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA, 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attached hereto on the above stated dates 327.23 REAL ESTATE SALE No. 58 WrIt No. 2005-584 Civil Term Wella Fargo Bank Minnesota, tlkle Norwesl Bank Minnesota, Natlonel AasocIatlon .8 Trustee lor SlrucIured Asset Securftlas Corporation SASCO Mortgage Loan Trost 1999-BC4 Mortgage PasS- Through CarlIltcates SerIes 1999-BOI, Va carter .Harrison AtIy: MlIrk Udren DESCRIPTION ALL 1llXf CERTAIN piece or parcel of land, with im-provements therooD erected, situate in the township 0{ Hampden, COIllIty 0{ C\nnOObnd, State of Pennsylvania, more particularly described as follows, to wit BEGINNING at a point on the southwesterly side of Lamp Post Lane at the dividing line between lot Nos. 9 and l(}, block "Wof the hereinafter mentioned pian, which point is 62713 feet in a oorthwesterly direction from the southwesterly comer of Carriage House Drive and Lamp Post Lane of the plan; thence by said di'lidin; Jjne soulh 3S &gre,s. 10 minutes w.,,, 1Il17.....,apoill...lioeatJ...13._ "If'oflhe__.....LoII_131Od12. -".......,30_....>>...'" lhedMiliol'.._u.Noo.....(1I b!ock"\f'O{1heplan;1bencebysaiddivi4UIglioo POrth 35 degrees, 10 minutes east 121.43feettGa point on the soUlhwesterly side of Lamp Post Lane; thence by saine south 54 degrees, 50 minutes east 100 feet to a point at the dividing line betweenLotsNo,9~ lO,block"H:' o{theplJm, the place olbeginning, BEING,]I oILotNo.lO;block "\f'.Pbn4 01 Pine Brook as recorded .. the Comberland County recooJer's office in Plan Book 15 Page 41. BErnO known as 313 Lamp Post Lane, Camp Hill. (IIlunpdeo lbwnship) PA 17011 l'ropo1yIDNo.1ll-2ll-1t!48-108 'ITILE TO SAID PREMISES is vested in Carter Harrisoo, single man by Deed from Carter _ and Quo HamBoo. bUsband and wife daolIW19199 rerorded llSlWJ9 .. Deed Book 2OOPlF211.