HomeMy WebLinkAbout05-2078
ATTORNEY FOR PLAI IFF
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, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PTI
Mortgage Pass-Through
Certificates Series 2003-0PTI
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Joseph D. Miller, Jr.
Dana Mi ller, Mortgagor NO. 0 $' - ;)()'l!?
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
Cw"C
YOU HAVE BEEN SUED IN COURT. If you wish to defend agains
claims set forth in the following pages, you must take a
within twenty (20) days after this Complaint and Notice are se
by entering a written appearance personally or by attorne
filing in writing with the Court your defenses or objections t
claims set forth against you. You are warned that if you fa
do so the case may proceed without you and a judgment m
entered against you by the Court without further notice fo
money claimed in the Complaint or for any other claim or r
requested by the Plaintiff. You may lose money or proper
other rights important to you.
8Zh)
the
tion
ved,
and
the
1 to
be
any
lief
y or
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D 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 AB E TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER EGAL
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
AVISO
Le han demandado a usted en la corte. Si usted quiere defen erse
de estas demandas expuestas en las paginas siguientes, usted iene
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 escrit sus
defensas 0 sus objeciones alas demandas en contra de su per ona.
Sea avisado que si usted no se dafiende, la corte tomara medi as 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 provision s de
esta demanda. Usted puede perder dinero 0 sus propiedades u tros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE AB GADO
o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VA A EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIO SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONS GUIR
ASISTENCIA 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 c editor
to whom the debt is owed is as named in the attached docurnent. Unless you notify us ithin
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 d notify
us in writing of a dispute within the 30 day period, we will obtain verification of the ebt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, i is not
an admission of liability on your part. Also, upon your written request within the 0 day
period, we will provide you with the name and address ofthe original creditor if differe t from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease co ection
of your debt, or any disputed portion of it, until we obtain the information that is r uired
and mail it to you. Once we have mailed to you the required information, we w I then
continue the collection of your debt.
This law firm is deerned to be a debt collector and this Notice and the attached docu ent is
an attempt to collect a debt, and any information obtained will be used for that purp se.
UDREN LAW OFFICES, P.c.
Isl 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 th n it
is such by virtue of the following recorded assignments:
Assignor: Option One Mortgage Corporation
Assignments of Record to: Wells Fargo Bank, N.A., as Truste for
MASTR Asset Backed Securities Trust 2003-0PT1 Mortgage Pass-Th ough
Certificates Series 2003-0PT1
Recording Date: LODGED FOR RECORDING
2. Defendant(s) is the individual designated as such 0 the
caption on a preceding page, whose last known address is a 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 Defendan (s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) I aned
to the Defendant (s) the sum appearing on said Mortgage,
hich
Mortgage was executed and delivered to Plaintiff as securit for
the indebtedness. Said Mortgage is incorporated here'n by
reference in accordance with Pa.R.C.P. 1019 (g)
The information regarding the Mortgage being foreclosed s as
follows:
MORTGAGED PREMISES: 34 West Keller Street
MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg
COUNTY: Cumberland
DATE EXECUTED: 09/18/02
DATE RECORDED: 09/20/02 BOOK: 1773 PAGE: 3933
The legal description of the mortgaged premises is attached h reto
and made part hereof.
4. Said Mortgage is in default because the required pa ents
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 authoriz d by
said Mortgage itemized below,
shall be immediately due.
5. After demand, the Defendant (s) continues to fa' I or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installment of
principal and interest when due in the amounts indi ated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage s of
4/11/05 :
Principal of debt due
Unpaid Interest at 8.25% *
from 8/1/04
to 4/11/05
(the per diem interest accruing on
this debt is $22.67 and that sum
should be added each day after
4/11/05)
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $78.16 and that sum should
be added on the first of each
month after 4/11/05)
Late Charges
(monthly late charge of $50.01
should be added in accordance
with the terms of the note
each month after 4/11/05)
Suspense Balance
Total Fees Due
Attorneys Fees (anticipated and actual
to 5% of principal)
TOTAL
$110,2 6.64
6,2 5.86
3 5.00
2 0.00
4,2 3.52
7 0.15
(1 .84)
32.04
5 5 3.83
$127,9 7.20
* This interest rate is subject to adjustment as more full set
forth in the Note and Mortgage.
7 .
The attorney's fee set forth above are in conformi
Y with
cted
documents and Pennsylvania law, and will be coll
the mortgage
in the event
If the
of a third party purchaser at Sheriff's Sale.
mortgage is reinstated prior to the sale, reasonable attor ey's
fees will be charged in accordance with the reduction provisi ns of
Act 6, if applicable.
8. The combined notice specified by the Pennsyl ania
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 ha not
been notified in a timely manner of Defendant(s) eligibility
WHEREFORE, the Plaintiff demands judgment, in rem, ag inst
the Defendant(s) herein in the sum of $127,907.20 plus inte est,
costs and attorneys fees as more fully set forth in the Compl int,
and for foreclosure and sale of the Mortgaged premises.
I
Mark J. Ud ,en, ESOUIRE
UDREN LAW OFFICES~ P.C.
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL THAT CERTAIN HOUSE AND LOT OF GROUND (KNOWN AS LOT NO. 15) SITUATE AND BING ON
THE NORTH SIDE OF WEST KELLER STREET IN THE BOROUGH OF MECHANICSBURG, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO W T:
BEGINNING AT A POINT AT THE CORNER OF LOT NO. 13, NOW OR FORMERLY OF ELDA M.
BASCOM, BEING ALSO ON THE BUILDING LINE OF SAID WEST KELLER STREET; THENCE B
LOT NO. 13 NORTHWARD, ONE HUNDRED FIFTY-NINE (159) FEET, MORE OR LESS, TO A
(20) FOOT ALLEY; THENCE BY SAID ALLEY, EASTWARD, THIRTY-FIVE (35) FEET, MORE
LESS, TO LOT NO. 17, NOW OR FORMERLY OF BRINDLE; THENCE BY SAID LOT, SOUTHWA
HUNDRED FIFTY-NINE (159) FEET, MORE OR LESS, TO A POINT IN THE BUILDING LINE
WEST KELLER STREET, AFORESAID; THENCE BY SAID BUILDING LINE, WESTWARD, THIRT
(35) FEET, MORE OR LESS, TO A POINT AT THE PLACE OF BEGINNING.
SAID
ENTY
OR
D, ONE
OF
-FIVE
HAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND OTHER BUILDINGS, KNOWN
AND NUMBERED AS 34 WEST KELLER STREET.
647/0006893 I 76/0PO 1 0111910000000000000
February 18, 2005
Joseph D Miller
34 W Keller St
Mechanicsburg, PA 17055-6339
Homeowners Name: Joseph D Miller
Property Address: 34 W Keller St, Mechanicsburg PA ] 7055
Loan Account No.: 0006893176
Original Lender: OPTION ONE MORTGAGE CORPORATION
Current LenderlServicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGffiLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE
FOR
EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
f:XHI IT A
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
OPOl 0 (Page I of 9) 64 7/0006893176/0PO 10/2/910000000000000
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 "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO
CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - 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. The names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in
which the property is located are set forth at the end of this Notice,
or you may contact Pennsylvania Housing Finance Agency at 800-342-2397
(Persons with impaired hearing can call (717) 780-1869 or visit the
Pennsylvania Housing Finance Agency website at www.phfa.org.Itis only
necessary to schedule one face-to-face meeting. Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
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 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.
(Page 2 of 9)
OPOIO 021 R21
647 /0006893176/0PO 11/3/9/0000000000000
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THI
LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIA TEL Y AND
YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY 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.
(Page 3 of 9)
OPOI1016R21
647/0006893176/0POI2/4/9/0000000000000
Re: Loan No. 0006893176
**********************************************************************
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 A TIEMPT TO
COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for
Emergency Mortgage Assistance.)
**********************************************************************
HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on
your property located at:
34 W Keller St, Mechanicsburg P A 17055
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following
months and the following amounts are now past due:
(a) Monthly payments: 6 MONTHS @ $ 911.72
MONTHS @ $.00
$ 5470.32
(b) Previous late charges;
$ 700.14
(c) Other charges; Escrow, Inspection,
NSF checks $ 174.83
(d) Other provisions of the mortgage obllgation,
if any $ 0.00
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED
AS OF THIS DATE $ 6345.29
B. YOU HAVE FAlLED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
OPOl2 (Page 4 of9)
647 /0006893 I 76/0PO 12/5/9/0000000000000
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $6345.29, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD.
Payments must be made either by cash, cashier's check, certified
check or money order made payable and send to:
Overnight Mail Address
Western Union Quick Collect
4600 Touchton Rd E
Bldg 200 Ste 102
Jacksonville, FL 32246
Mailstop: JI CASH
Pay to: Option One Mortgage Corporation
Code City: OptionJax, FI
You can cure any other default by taking the following action within
thirty (30) days of the date of this letter. (Do not use if not
(applicable.)
(Page 5 of 9)
OPOl2 022 R21
64 7/0006893 I 76/0PO 13/6/910000000000000
Re: Loan No. 0006893176
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to
exercise its rights to accelerate the mortgage debt.
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 foreclose upon your
mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - 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 brings legal proceedings against you, you will still be required
to pay the reasonable attorney'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 amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period, you
will not be required to pay attomey's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not
cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriffs
Sale. You may do so by paying the total amount then past due, plus
any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs
connected with the Sheriffs Sale as specified in writing by the
lender and by performing any other requirements under the mortgage.
OP013 (Page 6 of 9)
647/00068931 76/0POI3171910000000000000
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.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriffs Sale of the mortgaged property
could be held would be approximately (7) SEVEN Months from the date
of this Notice. A notice of the actual date of the Sheriffs 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.
(Page 7 of 9)
OP013 019 R21
647/0006893] 76/0PO] 4/8/910000000000000
Re: Loan No. 0006893176
HOW TO CONTACT THE LENDER:
Name of Lender: Option One Mortgage Corporation
Address: 4600 Touchton Rd East Bldg 200 Ste 102
Attn: Julia Langston Address: Jacksonville, FL 32246
Phone Number: 904-996-1730
Fax Number: 1-866-497-1263
Contact Person: Julia Langston
Office hours: Monday through Thursday 8:00 a.m. to 8:00 p.m.
Friday and Saturday 8:00 a.m. to 5:00 p.m.
EFFECT OF SHERIFF'S SALE - 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.
ASSUMPTION OF MORTGAGE - You
mayor X may not (CHECK ONE) sell
or 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.
YOU MAY ALSO HAVE THE RIGHT TO:
* 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 CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAT 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.
OP014 (Page 8 of 9)
64 7/0006893176/0PO 14/919/0000000000000
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO
SUCH ACTION
BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS
ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS
BEEN
DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES.
(page 9 of 9)
OP014 024 R21
647/0006893176/0P8251119/0000000000000
February 18, 2005
Dana Miller
34 W Keller St
Mechanicsburg PA 17055-
Homeowners Name: Joseph D Miller
Property Address: 34 W Keller St, Mechanicsburg P A 17055
Loan Account No.: 0006893176
Original Lender: OPTION ONE MORTGAGE CORPORATION
Current LenderlServicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE
FOR
EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR
CONTROL,
* IF YOU HA VB A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
OP825 (Page] of 9)
647/00068931 76/0P825/2/9/0000000000000
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 "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR
MORTGAGE UP TO DATE. THE P ART OF THIS NOTICE CALLED "HOW TO
CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - 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. The names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in
which the property is located are set forth at the end of this Notice,
. or you may contact Pennsylvania Housing Finance Agency at 800-342-2397
(Persons with impaired hearing can call (717) 780-1869 or visit the
Pennsylvania Housing Finance Agency web site at www.phfa.org.Itis only
necessary to schedule one face-to-face meeting. Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
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 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.
(Page 2 of 9)
OP825 010 R32
64 7/0006893176/0P826/3/910000000000000
YOU MUST FILE YOUR APPLICA TION 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.
AGENCY 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.
(page 3 of 9)
OP826 008 R32
647/0006893] 76/0P827/4/910000000000000
Re: Loan No. 0006893] 76
**********************************************************************
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 CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on
your property located at:
34 W Keller St, Mechanicsburg P A 17055
IS SERIOUSLY IN DEFAULT because:
I
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following
months and the following amounts are now past due:
(a) Monthly payments: 6 MONTHS @ $ 911.72
MONTHS @ $.00
$ 5470.32
(b) Previous late charges;
$ 700.]4
(c) Other charges; Escrow, Inspection,
NSF checks $ 174.83
(d) Other provisions of the mortgage obligation,
if any $ 0.00
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED
AS OF THIS DATE $ 6345.29
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
OP827 (Page 4 of 9)
647/0006893 I 76/0P827 /5/9/0000000000000
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $6345.29, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD.
. . .
Payments must be made either by cash, cashier's check, certified
check or money order made payable and send to:
Overnight Mail Address
Western Union Quick Collect
4600 Touhcton Rd E
Bldg 200 Ste 102
Jacksonville, FL 32246
Mailstop: J1 CASH
Pay to: Option One Mortgage Corporation
Code City: OptionJax, F1
You can cure any other default by taking the following action within
thirty (30) days of the date of this letter. (Do not use if not
(applicable.)
(Page 5 of9)
OP827 015 R32
647/0006893 I 76/0P828/6/9/0000000000000
Re: Loan No. 0006893176
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to
exercise its rights to accelerate the mortgage debt.
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 foreclose upon your
mortgaged property.
'. 1Il.
IF THE MORTGAGE IS FORECLOSED UPON - 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 brings legal proceedings againsf you, you will still be required
to pay the reasonable attorney'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 amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period, you
will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not
cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriffs
Sale. You may do so by paying the total amount then past due, plus
any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs
connected with the Sheriffs Sale as specified in writing by the
lender and by performing any other requirements under the mortgage.
OP828 (Page 6 of 9)
647 /OOO6893176/0P828/7 /9/0000000000000
.. ...
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.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriffs Sale of the mortgaged property
could be held would be approximately (7) SEVEN Months from the date
of this Notice. A notice of the actual date of the Sheriffs 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.
(Page 7 of 9)
OP828 008 R32
647/0006893176/0P829/8/9/0000000000000
Re: Loan No. 0006893]76
HOW TO CONTACT THE LENDER:
Name of Lender: Option One Mortgage Corporation
Address: 4600 Touchton Road East Bldg 200 Ste ] 02
Altn: Julia Langston
Address: Jacksonville, Fl 32246
Phone Number: 904-996-1730
Fax Number: 1 -866-497-1263
'. &
.
Contact Person: Julia Langston
Office hours: Monday through Thursday 8:00 a.m. to 8:00 p.m.
Friday and Saturday 8:00 a.m. to 5:00 p.m.
EFFECT OF SHERIFF'S SALE - 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.
ASSUMPTION OF MORTGAGE - You
mayor X may not (CHECK ONE) sell
or 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.
YOU MAY ALSO HAVE THE RIGHT TO:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE
MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON
YOUR BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT
HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAT 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.
OP829 (Page 8 of 9)
647/0006893] 76/0P829/9/9/0000000000000
A
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO
SUCH ACTION
BY THE LENDER.
" TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS
ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS
BEEN
DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES.
(page 9 of 9)
OP829 018 R32
.l.
V E R I F I CAT ION
Mark J. Udren, Esquire, hereby states that he is the atto ney
for the Plaintiff, a corporation unless designated otherwise; hat
he is authorized to take this Verification and does so becaus of
the exigencies regarding this matter, and because Plaintiff
verify much of the information through agents, and because h
personal knowledge of some of the facts averred in the foreg
pleading; and that the statements made in the foregoing plea
are true and correct to the best of his knowledge, informatio
belief and the source of his information is public record
reports of Plaintiff's agents. The undersigned understands
this statement herein is made subject to the penalties 18
Pa.C.S. Section 4904 relating to unsworn falsificatio to
authorities.
......
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-02078 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WELLS FARGO BANK NA
VS
MILLER JOSEPH D JR ET AL
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
MILLER JOSEPH D JR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, MILLER JOSEPH D JR
34 WEST KELLER STREET
MECHANICSBURG, PA 17055
PER DANA, DEFENDANT IS LIVING IN DILLSBURG AREA.
SHE DOES NOT KNOW EXACT ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
7.40
5.00
10.00
.00
40.40
So answers: -'J ~?
~' /
.. ,/",;"'/ .......~
.----. 7;;:& ~-_/
( R. Thomas Kli .
Sheriff of Cumberland County
MARK UDREN
05/13/2005
Sworn and subscribed to before me
this
r c;,.
(& -
day of 1M "7
.2iM{ A.D.
C l.u--- Q ~.~
prdtlbnotary j-r.t
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02078 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK NA
VS
MILLER JOSEPH D JR ET AL
CPL. TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MILLER DANA
the
DEFENDANT
, at 1815:00 HOURS, on the 26th day of April
2005
at 34 WEST KELLER STREET
MECHANICSBURG, PA 17055
by handing to
CHRISTINA MILLER, WIFE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
~ /:,r//
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R. Thomas Kline
05/13/2005
MARK UDREN
Sworn and Subscribed to before
By' ,J~/ ~
v Dejuty Sher' f
. ..,
me this If - day of
'flLj ;J U-o '5' A. D .
(/~~-'thoq"o~ J ~
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
p1eadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v.
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
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
upon Defendant(s),
Joseph D. Miller, Jr.,
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 (s)
at
34
West
Keller
Street,
Mechanicsburg, PA 17055, which is the mortgaged premises. A copy
of the Return of Service is attached hereto and marked as
Exhibit "A".
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(s).
4. The last known address of Defendant(s) 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 by regular mail and certified mail upon
said Defendant (s), Joseph D. Miller, Jr. and by posting the
mortgaged premises.
UDREN LAW OFFICES, P.C.
By: 1Jb
Mark J. dr ,Esquire
Attorney 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
p1eadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v.
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
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, local tax
records, and motor vehicle records.
As set forth in the Return of Service marked Exhibit "A", the
Sheriff and/or Process Server has been unable to serve the
Complaint. A good faith effort to discover the whereabouts of the
Defendant (slhas 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 upon Defendant(s) by regular mail and certified
mail and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
By: ;[J4 /
Mark J. U re~ Esquire
Attorney for Plaintiff
'-'..............'-........... ...... ...'-........~._.
-.- - --
~ASE NO: 2005-02078 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WELLS FARGO BANK NA
VS
MILLER JOSEPH D JR ET AL
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
MILLER JOSEPH D JR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, MILLER JOSEPH D JR
34 WEST KELLER STREET
MECHANICSBURG, PA 17055
PER DANA, DEFENDANT IS LIVING IN DILLSBURG AREA.
SHE DOES NOT KNOW EXACT ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
7.40
5.00
10.00
.00
40.40
SO~~~
R. Thomas Kli -
Sheriff of Cumberland County
MARK UDREN
05/13/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
EXHIBIT A
o SOl/O! li(
Players National Locator, Inc.
~AEElDAVIT QF_ GQQD FAITH INVESTIGATION
Loan Number: 05040124
Attorney Firm: MARK J UDREN & ASSOCIATES
Case Number:
Subject: Joseph 0 Miller Jr
AKA.: Joseph 0 Miller
Last Known Address: 34 W Keller Street
Mechanicsburg, PA 17055
Last Known Number: (717) 766-4004
Melissa Kozma. being duly sworn according to law, deposes and says:
1. I am employed in the capacity 01 Location Specialist for Players National Locator. Inc.
2. On 05/19/2005, I conducted an investigation into the whereabouts of the above named
delendant(s). The results of my investigation are as follows:
CREDIT INFORMATION -
A. SOCIAL SECURITY NUMBER(S):211-56-B548
B. EMPLOYMENT SEARCH:
We were unable to verify current employment for Joseph 0 Miller Jr.
C. INQUIRY OF CREDITORS:
Creditors indicated the last reported address for Joseph 0 Miller Jr is 34 W Keller Street,
~henillSburg, PA~17Jl55,wIth the home number of (717) 766-4004,
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
The home number for Joseph D Miller Jr is (717) 7664004, registered to 34 W Keller Street,
Mechanicsburg, PA 17055. We called the home number and spoke with a relative who stated
Joseph D Miller Jr Is living at 34 W Keller Street. Mechanicsburg, PA 17055.
INQUIRY OF NEIGHBORS-
N/A
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of May 19, Z005 the National Change of Address (NCOA) has no change for Joseph 0 MlllerJr
from 34 W Keller Street, Mechanicsburg, PA 17055.
MOTOR VEHICLE REGISTRATION -
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Motor Vehicles has Joseph D Miller Jr listed at 34 W Keller
Street, Mechanicsburg, PA 17055,
OTHER INQUIRIES -
A. DEATH RECORDS:
As of May 19, 2005 the Social Security Administration has no death record on file for Joseph D
Miller Jr and/or A.K.A's under the social security number provided.
EXHIBIT B
9,H ,ao/zoa.d ELZ~l
ma aE< 9,9
UO!~I?IJOSSV S , J8,{1?Id-IDOJ:/ Uld6Z: 10
\O~6H"W
B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. ):
None Found.
C. COUNTY VOTER REGISTRATION:
The Cumberland County VDters Registration OffIce has Joseph 0 Miller Jr listed at 34 W Keller
St",-"t,~~chanicsburg, PA 17055.
ADDITIONAL INFORMATION ON SUBJECT -
A. DATE OF BIRTH:
January 1971
~~;{ A JAAJ\ /011 fA
f'J. FIANT Melissa Kozma jI
"NOTARY SEAL"
Krisline M. Sr.oIt. NoIary Public .
51. Louis County, Slale of Mlssoun
My Commission Expires 9/212006
Players National Locator, Inc. 174 Clarkson Road, Suite 225 St.Louis, MO 63011
Phone: (636)230-9922 Fax: (636)230-0558
BE&-J EDD!EDD'd ElZ-1
Bm DEZ 919
UOIlE1JOSSV s,Ja~eld-woJJ wdOE:ID
,D-61-'~
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 knowledge, 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.
Date: 5/2'110)
1JA/
Mark J. Udren, Esquire
Attorney for Plaintiff
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, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v.
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
Defendant(sl
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:
x
Regular First Class Mail
Certified Mail
Other
Date Served: S/ZII/t'5
TO: Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
UDREN LAW OFFICES, P.C.
By: ~
Mark J. Udren, Esquire
Attorney for Plaintiff
)
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r
C1
WELLS FARGO BANK,
NA., as Trustee for
MASTR Asset Backed
Securities Trust 2003-
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PT1,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
JOSEPH D. MILLER, JR., :
DANA MILLER,
Mortgagor,
Defendant(s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31't day of May, 2004, upon consideration of Plaintiffs Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (1)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
Defendant's last known address at 34 West Keller Street, Mechanicsburg, PA 17055, (2)
publication once in the Cumberland Law Journal and in a newspaper of general
circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, PA 17055.
BY THE COURT,
"--'"
J. 'fi sley Oler, Jr.
I
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-
Mark J. Udren, Esq.
WOODCREST CORPORATE CENTER
III Woodcrest Boulevard
Suite 200
Cherry Hill, P A 08003-3620
Attorney for Plaintiff
~ ~ [".01.0<
~
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v.
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint on the above-captioned matter.
DATE: June 10, 2005
UDREN LAW./r;' ICES, P.C.
{A" .'
'1/
Mark J dren, ESQUIRE
ATTO Y FOR PLAINTIFF
-----
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02078 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK NA
VS
MILLER JOSEPH D JR ET AL
CPL. TREVOR KENT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MILLER JOSEPH D JR
the
DEFENDANT
, at 1625:00 HOURS, on the 14th day of June
, 2005
at 34 WEST KELLER STREET
MECHANICSBURG, PA 17055
by handing to
POSTED PROPERTY AT 34 WEST
KELLER STREET MECHANICSBURG
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
So Answers:
18.00
8.14
6.00
10.00
.00
42.14
.r-~~'<:~
R. Thomas Kline
06/15/2005
UDREN LAW OFFICES
Sworn and Subscribed to before
By:=1~ I{,d.
( Deputy Sheri
me this ;(c g, day of
(--14''<- d2 &os A.D.
I Cft;~/2o~1:;;~Jr,
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
p1eadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PTl
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v.
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
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 Complaint to
Defendant(s), by certified mail and regular first class mail, to
the last known address of Defendant(s) as follows:
DATE MAILED:
Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
I verify that the statements made herein are true and correct and
I understand that false statements made herein are subject to the
penalties relating to unsworn falsification to authorities.
Dated:
JUflf, f)l lbo <"
UDREN ~ES' P.C.
Mark-J. Uaren, Esquire -------
Attorney for Plaintiff
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COMPl.ETE THIS SECTION ON DELIVERY
.
. Complete Items 1, 2, and 3~ Also complete
"em 4 if Restricted Delivery Is desired,
. Print your name and address on the reverse
so that we can return the card. to you.
. Attech this card to the back of tha mall piece,
or on the front If space permits.
1. Article Addressed to:
:bse.ph D. Nil' e.,(J J(-,
34 we.s+ te.,\ \u- sf-reef
HeGho.nlc?:,6ufj I O{1 It-oS
2. Artlr.IR N. rm"'-
7004 2890 0004 1256 3623
PS Form 3811, February 2004
A Signature
x
B. Received by (PrlntedName)
o Agent
Cl Addressee,
C. Date of DOllvery
D. ISdellvery address different ~ Item 1?
if VES. enter delivery address below:
DVes
DNa.
3. Service Type
I!!( Certified Mall 0 Express MaO
o RegIstered lii;'Aetum Recelpt'for Merchandise
o Insured MaR 0 C.O.D.
4. Restr1cled Delivery? (ExtnJ Fee) 0 Ves
DomestIc Return Receipt
102595-02-M-1540
WELLS FARGO BANK,
- N.A., as Trustee for
MASTR Asset Backed
Securities Trust 2003-
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
CIVIL ACTION - LAW
JOSEPH D. MILLER, JR" :
DANA MILLER,
Mortgagor,
Defendant( s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31st day of May, 2004, upon consideration of Plaintiff's Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (1)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
Defendant's last known address at 34 West Keller Street, Mec,llanicsburg, PA 17055, (2)
publication once in the Cumberland Law Journal and in a- newspaper of general
,circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, P A 17055.
BY TIIE COURT,
TRUE COP"( FROM RECORO
tll TIIitlmoJIy wtItJreot. I here unto S8l my haoo
and the ... II saJd ~ at Cartislft P&.
fills I AA;- II~ ~ dtJO.<f'
.. l h11/1.2J 0 '"'Yu.Jj}/J~.. A ;",,(("
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EXHIBIT A
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UbREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOOD CREST COPRORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
v.
Joseph D, Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
PRAECIPE TO FILE PROOF OF PUBLICATION
TO THE PROTHONOTARY:
Kindly file the attached Proof of Publication with regard to
the captioned matter.
DATE: September 20, 2005
UDREN LAW OFFIC
, P.C.
BY
Mark
ATTO
ESQUIRE
LAINTIFF
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Tanunv Shoemaker, Classified Advertising Manager, of The Sentinel, of the County
and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a
newspaper of general circulation in the Borough of Carlisle, County and State
aforesaid, was established December 13th, 1881, since which date THE SENTINEL has
been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions
and issues of THE SENTINEL on the following day(s)
Tune 18, 2005
COPY OF NOTICE OF PUBLICATION
NOTICE
IN Ttte'COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION.LA W
NO. 05-2078 CIVIL TERM
NOTICE OF ACTION IN MORTGAGE FORECLOSURE
WELLS FARGO BANK, N.A., AS TRUSTEE FOR MASTR ASSET BACKED
SECURITIES TRUST 2Q03.0PT1 MORTGAGE PASS-THROUGH
CERTIFICATES SERIES 2D03-0PT1, PLAINTIFF V&. JOSEPH D. MILLER, JR.
and DANA MILLER, MORTGAGOR, DEFENDANTS
I: JOSEPH D. MILLER. JR., Defendant, whose las1 known address is
34 West Keller Street, Mechanicsburg, PA 17055.
COMPLAINT IN MORTGAGE FORECLOSURE
u are hereby notified that Plaintiff, WELLS FARGO BANK, NA, AS TRUSTEE
=OR MASTR ASSET BACKED SECURITIES TRUST 2003~OPT1 MORTGAGE
:lASS-THROUGH CERTIFICATES SERIES 2003-0PT1, has filed a Mortgage
=oreclosure Complaint endorsed with a Notice to Defend, against you in the Court
)f Common Pleas of Cumberland County, Pennsylvania, docketed to NO. 0&-2078
:;IVIL TERM, wherein Plaintiff seeks to foreclose on the mortgage secured on your
lroperty focated, 34West KeflerStreet, Mechanicsburg, PA 17055, whereupon
lour property would be sold by the Sheriff of Cumberland County.
NOTICE
lU HAVE BEEN SUED IN COURT. If you wish to defend againstthe claims set
orth inthe notice above, you musttake actfon withIn twenty (20) days after this
~omplaint and Notice are served, by entering a written appearance personally or
lY attorney and filing in writing with the Court your defenses or'objectlons to the
:Ialtns seUorth,against you. You are'wamed that if you fail to, do so the case may
)(:oce:sd without you and a judgment may be entered ag.ainst.you by the Court
yithout fUrther,notice for any money claimed In the Complaint or for any other
:laimbnellef requested by the Plaintiff. "Y.9'~Jn.,~dR@i.!3,iJJWr1'-Y&'ij(oPJt~~
,ghtslmpor(anttoyoo>, .>' ..',~,"T,,,. .. .. ... ....,
~1't~:jl:ll2;.p." ~'~ih\(jllb~.,~~15Uh\j~I1;'
1A'__YI!R'4O'<1'O;O'R' . . O'RE'1'RE'Ol'FICE SET FO'RTH BELOW,
rHIS'O'FFlCECANPROVIDEYO'U.WlfH THEINFO'RMATIO'NABOUT HIRING A
.AW,YERl:IFYGUCANNO'T AFFO'RD TO' HIRE.A LAWYER; THISO'FFICE MAY
'EABLETO' PRO'VIIlEYOUWITIlINFO'RMATIO'N ABO'UT AGENCIES THAT
it1AY. OFF.ER LEGAL SE~VICES TO ELIGIBLE PERSONS AT A ReDUCED FEE
JANO' FEEl
LAWYERS REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 Uberty Avenue
CarliSle, PA 17013
717.249-3166
800-990~91 08
.RK J. UDREN
TORNEY FOR PLAINTIFF
'REN lAW OFFICES, P.C.
lodcrest Corporate Center
I Woodcrest Road
'It9200
erry Hill, NJ 08003-3620
3.482.6900
Affiant further deposes that hel she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement
as to time, place and character of
~:;:;-i(~~~
Sworn to and subscribed before me this
14th day of September, 2005.
CYrJUlJtUlW ;;q. ~~ fl._
Notary Pu c
My commission expires: q Ir lor
COMMONWEALTH OF PENNSYLVANIA
NoIanal Seal
Chnstina L ware, NoIary Public
Gar1isle Boro, Cumberland County
My Commission Expires Sept 1, 2008
Member. Pennsylvania Association Of Notaries
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No, 587, approved May 16, 1929), p, L.1784
COMONWEALTH OF PENNSYL VANIA
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 I, 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,
~c
SWORN TO AND SUBSCRIBED before me this
1 day of July, 2005
N SEAL
LOIS E, SNYDER, Notary Public
C 3'~SIe Bora, Cumberlano County
My Commission Expires March 5, 2009
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland. County,
Pennsylvania
Civil Action-Law
No. 05-2078 CMI Term
WELLS FARGO BANK, N.A" AS
TRUSTEE FOR MASTR ASSET
BACKED SECURITIES TRUST
2003-0PTI MORTGAGE PASS-
THROUGH CERTIFICATES
SERIES 2003-0PT1,
PLAINTIFF
vs,
JOSEPH D. MILLER. JR. and
DANA MILLER. MORTGAGOR.
DEFENDANTS
TO: JOSEPH D, MILLER, JR., De-
fendant, whose last MOwn ad-
dress is 34 West Keller Street
Mechanicsburg. PA 17055 '
COMPLAINT IN MORTGAGE
FORECLOSURE
You are hereby notified that Plain-
tiff, WElLS FARGO BANI\'. NA., AS
TRUSTEE FOR MASTR ASSET
BACKED SECURITIES TRUST
2003-0PTI MORTGAGE PASS-
THROUGH CERTIFICATES SERIES
2003-0PTI, has filed a Mortgage
Foreclosure Complaint endorsed
wtth a Notice to Defend, against you
in the Court of Cornman Pleas of
Cumberland County, Pennsylvania,
docketed to NO, 05-2078 CIVIL
TERM, wherein Plaintiff seeks to
foreclose on the mortgage secured
on your property located. 34 West
Keller Street, Mechanicsburg. PA
17055. whereupon your property
wo"uld be sold by the Sheriff of
CUinberland County.
NOTICE
YOU HAVE BEEN SUED IN
COURT. If you wish to defend
against the claims set forth in the
noticeaoove, you must take action
within twenty (20) days after this
Complaint and Notice are served
by entenng a written appearanc~
personally or by attorney and filing
in writing with the Court your de-
fenses 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 allier claim or
relief requested by the Platntlff. You
may lose money or property or other
lights important to you.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER
GO TO OR TELEPHONE THE OF-
FICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH
THE INFORMATION ABOUT HIR-
ING A LAWYER. IF YOU CANNOT
AFFORD TO HIRE A LAWYER, TIllS
OFFICE MAY BE ABLE TO PRO-
VIDE YOU WITH INFORMATION
ABOUT AGENCIES TIiAT MAY OF-
FER LEGAL SERVICES TO ELI-
GIBLE PERSONS AT A REDUCED
FEE OR NO FEE,
LAWYERS REFERRAL SERVICE
CUMBERLAND COUNTY
BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(7171 249-3166
(8001 990-9108
MARK J, UDREN, ESQUIRE
UDREN LAW OFFICES, P.C,
Attorneys for Plaintiff
Woodcrest Corporate Center
III Wood crest Road
"quite 200
Cherry H1ll, NJ 08003-3620
(856) 482-6900
July I
WELLS FARGO BANK,
N,A., as Trustee for
MASTR Asset Backed
Securities Trust 2003-
OPT1 Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v,
CIVIL ACTION - LAW
JOSEPH D, MILLER, JR., :
DANA MILLER,
Mortgagor,
Defendant( s)
.~..
NO, 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 st day of May, 2004, upon consideration of Plaintiff's Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (1)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
Defendant's last known address at 34 West Keller Street, Mec)lanicsburg, PA 17055, (2)
publication once in the Cumberland Law Journal and in a newspaper of general
, circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, PA 17055,
BY THE COURT,
i
it
~
TRUE COP'( FROM RECORlJ
In TMtlmony wtIIlreot. 1ll8re unto set IT'fi haM
MId th.... .hald~CariIsIe Pi.
Tn. I Ak ~ .tar dro,':/
. I ()
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Pm!:tlonOllr;r
EXHIBIT A
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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, N.A" as
Trustee for MASTR Asset Backed
securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO, 05-2078 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) Joseph D. Miller, Jr. And Dana Miller, Mortgagor 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 4/12/05 to 10/7/05
Late charges per Complaint
From 4/12/05 to 10/7/05
Escrow payment per Complaint
From 4112/05 to 10/7/05
$127,907.20
4,057,93
300,06
468,96
TOTAL S132,734,15
I
I hereby certify that (1) the addresses bf the Plaintiff and
Defendant are as shown above, and (2) that noti e has been given in
accordance with Rule 237,1, a copy of which is at ached hereto.
\
J, U en, ESQUIRE
\Attorney for Plaintiff
A INDIC:Z:fh~
PRO THY~
DAMAGES ARE HEREBY ASSESSED
DATE:
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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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
NO. 05-2078 Civil Term
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$132,734,15
./
Interest From 10/8/05 3.445,84
to Date of Sale March 8, 2006
On Going Per Diem of 522.67
to actual date of sale if sale is
held at a later date
(Costs to be added) $
UDREN LAW OFFICES, P.C,
, RE
PLAINTIFF
p
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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, N,A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
v.
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
NO, 05-2078 Civil Term
WRIT OF EXECUTION
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the judgment, interest and costs in the above
matter, you are directed to levy upon and sell the following
described property:
34 West Keller Street
Mechanicsburg, PA 17055
SEE LEGAL DESCRIPTION ATTACHED
Amount due $132,734,15
Interest From 10/8/05 3,445,84
to Date of Sale March 8, 2006
On Going Per Diem of $22.67
to actual date of sale if sale is
held at a later date
(Costs to be added) $
Prothonotary
By
Clerk
-
Date
COURT OF COMMON PLEAS
NO, 05-2078 civil Term
-------------------------------------
-------------------------------------
Wells Fargo Bank, N,A" as Trustee f~r MASTR Asset Backed
Securities Trust 2003-0PT1 Mortgage Pass-Through Certificates
series 2003-0PT1
vs,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
-------------------------------------
-------------------------------------
WRIT OF EXECUTION
-------------------------------------
-------------------------------------
.'
REAL DEBT
$
132,684,14
INTEREST $ 3,734,15
from 10/8/05
to Date of Sale March 8, 2006
On Going Per Diem of $22,67
to actual date of sale if sale is
held at a later date
COSTS PAID:
PROTHY $
SHERIFF $
STATUTORY $
COSTS DUE PROTHY, $
PREMISES TO BE SOLD:
34 est Keller Street
Me h icsburg, PA 17 55
\ rk J, Udren, ESQUIRE
1UDREN LAW OFFICES, P.C,
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 669-5400
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,~L THAT CERTAIN HOUSE AND LOT OF GROUND (KNOWN AS LOT NO. l5) SITUATE AND BEING ON
THE NORTH SIDE OF WEST KELLER STREET IN THE BOROUGH OF MECHANICSBURG, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT,
BEGINNING AT A POINT AT THE CORNER OF LOT NO, l3, NOW OR FORMERLY OF ELDA M,
BASCOM, BEING ALSO ON THE BUILDING LINE OF SAID WEST KELLER STREET, THENCE BY SAID
LOT NO. l3 NORTHWARD, ONE HUNDRED FIFTY-NINE (l59) FEET, MORE OR LESS, TO A TWENTY
(20) FOOT ALLEY, THENCE BY SAID ALLEY, EASTWARD, THIRTY-FIVE (35) FEET, MORE OR
LESS, TO LOT NO, l7, NOW OR FORMERLY OF BRINDLE, THENCE BY SAID LOT, SOUTHWARD, ONE
HUNDRED FIFTY-NINE (l59) FEET, MORE OR LESS, TO A POINT IN THE BUILDING LINE OF
WEST KELLER STREET, AFORESAID, THENCE BY SAID BUILDING LINE, WESTWARD, THIRTY - FIVE
(35) FEET, MORE OR LESS, TO A POINT AT THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND OTHER BUILDINGS, KNOWN
AND NUMBERED AS 34 WEST KELLER STREET.
BEING KNOWN AS:
34 WEST KELLER STREET, MECHANICSBURG, PA 17055
PROPERTY ID NO,
16-23-565-124
TITLE TO SAID PREMISES IS VESTED IN JOSEPH D. MILLER, JR" MARRIED
PERSON BY DEED FROM MARY E, PAUL AND ELWOOD C, PAUL, HUSBAND AND
WIFE DATED 12/15/99 RECORDED 12/23/99 IN DEED BOOK 213 PAGE 836,
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 05-2078 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N,A" AS TRUSTEE FOR
,MASTR ASSET BAKCED SECURITIES TRUST 2003-0PTl MORTGAGE PASS-THROUGH
CERTIFICATES SERIES 2003-0PTl Plaintiff(s)
From JOSEPH D MILLER, JR., AND DANA MILLER, MORTGAGOR, 34 W. KELLER ST"
MECHANICSBURG PA 17055.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 34 W. KELLER ST., MECHANICSBURG PA 17055 (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
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $132,734,15
L.L. $.50
Interest FROM 10/8/05 TO 3/8/06 @ 222.67 PER DIEM ~ $3,445.84
Atty's Comm %
Ally Paid $180.54
Plaintiff Paid
Date: OCTOBER 10, 2005
Due Prothy
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name MARK J, UDREN, ESQ.
Address: 111 WOODCREST RD., STE, 200
WOODCREST CORPORATE CENTER
CHERRY ffiLL 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, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO. 05-2078 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.
Mark J. Udren, ESQUIRE
ATTORNEY FOR PLAINTIFF
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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, N,A" as
Trustee for MASTR Asset Backed
securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
Joseph D, Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 Civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129,1
Wells Fargo Bank, N.A" as Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1 Mortgage Pass-Through Certificates
Series 2003-0PT1, 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: 34 West Keller Street
Mechanicsburg, PA 17055
1, Name and address of Owner(s) or reputed Owner(s) :
Name Address
Joseph D. Miller, Jr,
34 West Keller Street
Mechanicsburg, PA 17055
2, Name and address of Defendant(s) in the judgment:
Name Address
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
3, Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Hampden Township
230 South Sporting Hill Road,
Mechanicsburg, PA 17050
Keystone Oil Products
PO Box 157, Camp Hill, PA 17011
4, Name and address of the last recorded holder of every mortgage
of record:
Name Address
Plaintiff herein, See Caption above,
5, Name and address of every other person who has any record lien
on the property:
Name Address
None
6. Name and
interest in
the sale:
Name
address of every other person who has any record
the property and whose interest may be affected by
Address
Real Estate Tax Dept.
1 Courthouse Square, Carlisle, PA
17013
Domestic Relations Section
13 N, Hanover Street, Carlisle, PA
17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept, 280946
Harrisburg, PA 17128-0946
7, Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
TenantslOccupants
34 West Keller Street
Mechanicsburg, PA 17055
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief, I understand that false statements herein are made
subject to the penalties of 18 Pa,C,S, sec, 4904 relating to
unsworn falsification to authorities,
DATED: October 7, 2005
,c.
ark J, Udren, ESQ.
Attorney for Plaintiff
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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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P.O. Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO. 05-2078 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Joseph D, Miller, Jr,
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West Keller Street, Mechanicsburg,
PA 17055 is scheduled to be sold at the Sheriff's Sale on March
8, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $132,734,15, obtained by Plaintiff above (the mortgagee)
against you, If the sale is postponed, the property will be
relisted for the Next Available Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1, The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400,
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1, If the Sheriff's Sale is not stopped, your property will be sold
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
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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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West Keller Street, Mechanicsburg,
PA 17055 is scheduled to be sold at the Sheriff's Sale on March
8, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $132,734.15, obtained by Plaintiff above (the mortgagee)
against you, If the sale is postponed, the property will be
relisted for the Next Available Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1, If the Sheriff's Sale is not stopped, your property will be sold
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
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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, N.A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P.O, Box 57038
Irvine, CA 92619-7038
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO, 05-2078 Civil Term
v,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
DATE: October 7, 2005
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Joseph D. Miller, JR. And Dana Miller
PROPERTY: 34 West Keller Street, Mechanicsburg, PA 17055
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on March 8, 2006, at 10:00 am, at
the Commissioners Hearing Room, 2nd Floor, Coruthouse, 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,
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CO PRORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O. Box 57038
Irvine, CA 92619-7038
Plaintiff
v,
Joseph D. Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
PRAECIPE TO FILE PROOF OF PUBLICATION
TO THE PROTHONOTARY:
Kindly file the attached Proof of Publication with regard to
the captioned matter.
DATE: February 27, 2006
UDREN LAW OFFICES, P.C.
BY
Mar
ATT
Udren, Esquire
FOR PLAINTIFF
\VELLS FARGO BANK,
N.A" as Trustee for
M.A..STR Asset Backed
Securities Trust 2003-
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE COlJRT OF C0Mlv10N PLEAS OF
CUMBERLAND COUNTY, PENNSYL Vi\"NIA
v.
CIVIL ACTION - LAW
JOSEPH D. MILLER, JR., :
DANA MILLER,
Mortgagor ,
Defendant( s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 st day of May, 2004, upon consideration of Plaintiffs Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (1)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
~,
Defendaut's last known address at 34 West Keller Street, Mechanicsburg, PA 17055, (2)
publication once in the Cumberland Law Journal and in a newspaper of general
circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, P A 17055.
BY THE COURT,
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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
February 3, 2006
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.
SWORN TO AND SUBSCRIBED before me this
3 day of Februar--Y,,1006
~~ 2 ~~Arj'A/
Notary
"
CUMBERLAND LAW JOURNAL
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action-Law
No. 05~2078 Civil Term
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PTl
Mortgage Pass-Through
Certificates Series 2003-0PTl.
P,O, Box 57038,
Irvine. CA 92619-7038.
Plaintiff
v.
Joseph D. Miller. Jr.
Dana Mtller. Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055.
Defendant(s)
NOTICE OF SALE OF
REAL PROPERlY
To: Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West
Keller Street, Mechanicsburg. PA
17055 is scheduled to be sold at the
Cumberland County Sheriff's Sale on
March 8. 2006 at 10:00 a.m. in the
Commissioners Hearing Room. 2nd
Floor. Courthouse, Carlisle, PA 17013-
3387, to enforce the court judgment
of $132,684.14, obtained by Plain-
tiff above (the mortgagee) against
you. If the sale Is postponed. the
property will be relisted for the Next
Available Sale.
ALL THAT CERTAIN house and
lot of ground (known as Lot No. 15)
situate and being on the North side
of West Keller Street in the Borough
of Mechanicsburg, County of Cum-
berland and State of Pennsylvania,
bounded and described as follows.
to wit:
BEGINNING at a point at the COT-
ner of Lot No. 13. now or formerly
of Elda M. Bascom, being also on
the building line of said West Keller
Street: thence by said Lot No. 13
northward, one hundred fifty-nine
(159) feet. more or less. to .a twenty
(20) foot alley; thence by said alley.
eastv.lard. thfrty-five (35) feet, more
or less, to Lot No. 17, now or form-
erly of Brindle; thence by said lot,
southward. one hundred fifty-nine
(159) feet, more or less, to. a point
in the building line of West Keller
Street, aforesaid; thence by said
building line, westward, thirty-five
(35) feet, more or less, to a point at
the place of beginning.
Having thereon erected a two-
story frame dwelling house and oth-
er buildings. known and numbered
as 34 West Keller Street.
BEING KNOWN AS: 34 West Kel-
ler Street. Mechanicsburg, PA 17055.
PROPERlY ID NO., 16,23-565-
124.
TITLE TO SAID PREMISES IS
VESTED IN Joseph D. Miller, Jr.,
married person by deed from Mary
E. Paul and Elwood C. Paul. hus-
band and wife dated 12/1.5/99 re-
corded 12/23/99 in Deed Book 213,
Page 836,
MARK J. UDREN
MARK J, UDREN
& ASSOCIATES
Attorneys for Plaintiff
Vv'oodcrest Corpm'ate Center
III Wood crest Road
Suite 200
Cbeny Hill. NJ 08003-3620
(856) 669-5400
Feb. 3
3
~ .4 , " .
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County
and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a
newspaper of general circulation in the Borough of Carlisle, County and State
aforesaid, was established December 13th, 1881, since which date THE SENTINEL has
been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions
and issues of THE SENTINEL on the following day(s)
Tanuary 30,2006
COPY OF NOTICE OF PUBLICATION
NOTICE OF AcnON IN MORTGAGE FORECLOSURE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 05-2078 CIVIL TERM
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003.QPT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P.O. Box 57038
Irvine, CA 92619M7038,
Plaintiff
v,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanlcsburg, PA 17055
Defendant(s)
NOTICE OF SALE OF REAL PROPERTY
To: Joseph D. Miller, Jr.
34 West Keller Street
Mechanlcsburg, PA 17055
Your house (reat estate) at 34 West Kellar Street, Mechanicsburg, PA 17055 is
scheduled to be sold at the Cumberland County Sheriff's Sale on March 8, 2006
at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse,
CarlIsle, PA 17013-3387, to enforce the court judgement of$132,684.14,
obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be rellsted for the Next Available Sale.
ALL THA1' CERTAIN HOUSE AND LOT OF GROUND (KNOWN AS LOT NO. 15)
SITUATE AND BEING ON THE NORTH SIDE OF WEST KELLER STREET IN THE
BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND AND STATE
OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ATTHE CORNER OF LOT NO. 13, NOW OR FORMERLY
OF ELDA M. BASCOM, BEING ALSO ON THE BUILDING LINE OF SAID WEST
KELLER STREET; THENCE BY SAID LOT NO. 13 NORTHWARD, ONE
HUNDRED FIFTY-NINE (159) FEET, MORE OR LESS, TO A TWENTY (20) FOOT
ALLEY; THENCE BY SAID ALLEY, EASTWARD, THIRTYMFIVE(35) FEET, MORE
OR LESS, TO LOT NO. 17, NOW OR FORMERLY OF BRINDLE; THENCE BY
SAID LOT, SOUTHWARD, ONE HUNDRED FIFTY-NINE (159) FEET, MORE OR
LESS, TO A POINT IN THE BUILDING LINE OF WEST KELLER STREET,
AFORESAID; THENCE BY SAID BUILDING LINE, WESTWARD, THIRTYMFIVE
(35) FEET, MORE OR LESS, TO A POINT AT THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND
OTHER BUILDINGS, KNOWN AND NUMBERED AS 34 WEST KELLER STREET.
BEING KNOWN AS: 34 WEST KELLER STREET, MECHANICSBURG, PA 17055
PROPERTY 10 NO.: 16-32M565M124
TITLE TO SAID PREMISES IS VESTED IN JOSEPH D. MILLER, JR., MARRIED
PERSON BY DEED FROM MARY E. PAUL AND ELWOOD C. PAUL, HUSBAND
AND WIFE DATED 12/15/99 RECORDED 12/23/99 IN DEED BOOK 213 PAGE
836,
MARK J. UDREN
ATTORNEY FOR PLAINTIFF
MARK J. UDREN & ASSOCIATES
WOODCRE$T CORPORATE CENTER
111 WOODCREST BOULEY ARD, SUITE 200
CHERRY HILL, NJ 08003M3620
85&-66&-5400
Affiant further deposes that he! she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement
as to time, place and character of
publication are true,
c
Sworn to and subscribed before me this
31st day of January, 2006,
LVi )J))tU((t, c1f) l{)~f-
Notary Pub c
My commission expires: q /, fOg
COMMONWEALTH OF PENNSYLVANIA
\---- I\IotalialSeal . I
,,;hnstina L WcMe" Notary PubliC I
i 03"'5Ie Bora, Cumbef1and County II
I Vly Q'roffilS."'''' EXJllres Sepl1. 2008
M€.:, "?" ' ';;,';s'l'.mni:o k'~ociation Of Notnr'c!'
-,
: I~\
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-,
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, N,A" as
Trustee for MASTR Asset Backed
securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO, 05-2078 Civil Term
v.
Joseph D. Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE TO FILE
TO THE PROTHONOTARY:
PROOF OF SERVICE
Kindly file the attached Proofs of Service with regard to
the captioned matter,
UDREN LAW OFFICES, P,C,
Date: March 2, 2006
J Udren, Esquire
rney for Plaintiff
,
~
Service ~f Proc.e$s b}'
.,.fft, APSl~:~e;_~~~~;la;iLtd.
: APS \N'I'{l'.1\N~~~ AJ>>S lnta-nationaJ Piau
~~7~Offi~roVRd
~ MinJ\~p.Sis: MN" 554~9-3l22
-=--
.'\PS Pile #: 01S9JcJ..4)OOl
AFFIDAVIT OF SERVICE -- llldividual
Wells: r"rgu Bn.nk, NA n.~ lru~lee, ct. 81"'1 .rlnlnttff(s)
\'11;.
In'Jcl'h 0, .M;II~(', Jr.. tt. al..IJd't:nd"..t(!lI)
Serviee "f PTOtess on:
UDREN LA IV OF~'I CES. !',C.
-Dana Miller
Courl Ca.. No, 05-2078 Civil Term
!\J.c;. IleUl'll Ct'nmmlllt)'
111 Wnodc.rcsi Rd, ~llilC .200
Cllerr)" H.U1, N.' 080 ~3..3620
Stote of: P/FA/ 1t',4. ) ...,
County or,_, ht9 K' }
N."", of Sen'cr: /fli.'4h''',r: F"i. Ic;/('/N ..iClZ ,\l!l(\ersigned, bemg duly sworn, deposes and says
tl at at the time of servlce, sfhe was of legal age and was not a party to this action;
O.'e!Timc of Service: II at on the ;/7t:iday of ;:"S-I3t(f//4VY ,200' ,at ,: 11o'eloek ~"l
rl~c:C' of S~nlee:
DocuJJwmts Scr,'ed;
Service ofP.-occss on:
Person Sen"ed, and
Method of Sen'ice:
Dc~CriptiQD of PerSUR
Receiving J)ocmncnts:
al 11 S, Bnltimore Street. #3
.\ in Fra.nklintolfl'n. PA 173.2.1
tl'.e undersigned served the documents described os:
l' otic:e or SberitT's Salt; flf Re:al Prop4!rty
A Inte and cortee! copy (lflhe aforesaid doeumont(s) was served on:
[.aua Miller
L.rEy pe11l0~:liy delivering them into the hands of the person to be served.
L J;ly del.i vcring tllem into the hands of , a ,>erson
of suitable age, who verified. or who upon queslioning stated, thal he/she resides with
Dana :\>li11er
at the place of service, and whose relati01'lship to the person is:
T ne person reeelv;,,!; doeulUent. is described as follows: tV
S,:x ~ : SkinColor N ; Haireolor J'J1(t>UJ ; FacialH.ir tVe
'~ '-'.". "r '"
Approx, Age ~3.. : Appro,,", Height'" "" ; Approx Weisht //6
L.'To the best of my ~1Jowledge and belief, said perooTl wa., not engaged in the US Mihtary at
the time of service.
~{~_.- ~ ~'1~
Signature of Sen;er
A 1>5 International, Ltd,
Subscribed and sworn to before me this
.:l'Adayof .f:-fI1R'J..'20 6 c:;
Ct..z e.e.. . ........!'. /
~mary p NOTAJU " Til'e~)
WIlHam E Dolo:, Notary P1.JQlkJ
NOIIh Yorl< 1lcft, YO'k Cau'l,lY
1ll1.....,SJlon ""'llocom~ U;:r:." ~'
Sign:;ltun~ nt. Stn"er, Undersigned declares under pe.nalty Of pcrjury
tl' at tile foregoing is true and correc\.
-,
;'1"
.--1
:...,
-------
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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PTl
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Joseph D. Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 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: January 25, 2006
Joseph D, Miller, Jr,
34 West Keller Street
Mechanicsburg, PA 17055
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: March 3, 2006
UDREN LAW OFFICES, P,C,
Esqulre
Vv'ELLS FARGO BANK.
N,A.. as Trustee for
MASTR Asset Backed
Securities Trust 2003.
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE COT.JRT OF COMMON PLEAS OF
CUMBERLA},'D COUNTY, PENNSYLVA..,NIA
v.
CIVIL ACTION - LAW
JOSEPH D. MILLER, JR" :
DANA MILLER.
Mortgagor,
Defendant(s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 st day of May, 2004, upon consideration of Plaintiff's Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (1)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
"
,
Defendant's last known address at 34 West Keller Street, Mechanicsburg, PA 17055. (2)
publication once in the Cumberland Law Journal and in a newspaper of general
circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, PA 17055.
BY THE COURT,
r / /' /-_ j/
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J. Wesley Oler. Jr.: i - 1. v
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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, N.A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
NO. 05-2078 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 attached Return of Service,
attached hereto as Exhibit "B",
4, If service was by Order of Court, then proof of compliance with said
Order is attached hereto as Exhibit "B",
All Notices were served within the time ~imits set forth by Pa Rule C,P,
3129,
ection 4904
This Affidavit is made subject to the pe
relating to unsworn falsification to auth
Dated: March 30, 2006
BY:
Mark J, Udren, Esquire
Attorney 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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 05-2078 Civil Term
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
DATE: January 18, 2006
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): JOSEPH D. MILLER, JR. & DANA MILLER, MORTGAGOR
PROPERTY: 34 West Keller Street, Mechanic sburg , PA 17055
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on March 8, 2006, at 10:00 am, in
the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA,
Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later 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.
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a.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST COPRORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N,A., as
Trustee for MASTR Asset Backed
securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
plaintiff
v,
Joseph D, Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO, 05-2078 Civil Term
TO THE PROTHONOTARY:
PRAECIPE TO FILE PROOF OF PUBLICATION
C)
Cl
~n
----i
I
0'
G..'J
r<.1
Kindly file the attached Proof of Publication with regard to
the captioned matter.
DATE: February 27, 2006
UDREN LAW OFFICES, P.C.
Udren, Esquire
FOR PLAINTIFF
EXHIBIT .8
.
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST COPRORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PTl
Mortgage Pass-Through
Certificates Series 2003-0PTl
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO, 05-2078 civil Term
TO THE PROTHONOTARY:
PRAECIPE TO FILE PROOF OF PUBLICATION
Kindly file the attached Proof of Publication with regard to
the captioned matter,
DATE: February 27, 2006
UDREN LAW OFFICES, P,C,
Udren, Esquire
FOR PLAINTIFF
v
'XHIBIT B
,
\VELLS LARGO BANK,
N.A.. as Trustee for
MASTR Asset Backed
Securities Trust 2003-
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE COURT OF COM1vION PLEAS OF
CUMBERLA"J\i'D COUNTY, PENNSYL Vi,_,NIA
v.
CIVIL ACTION - LAW
JOSEPH D. MILLER, JR., :
DANA MILLER,
Mortgagor ,
Defendant( s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 s[ day of May, 2004, upon consideration of Plaintiff s Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, Jr. by (I)
mailing a true and correct copy of the complaint by certified mail and regular mail, to
~,
Defendall.t's last known address at 34 West Keller Street, Mechanicsburg, PA ] 7055, (2)
publication once in the Cumberland Law Journal and in a newspaper of general
circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street, Mechanicsburg, P A 17055.
BY THE COURT,
. / /-11
I /i;' ;-'."", !
I" , I ",. ,. I
i_I If-,
I 1/1.//0')/( /.
J 'oo/ , I _,"
J. ~.esley Oler, Jr.ij 1 '"
U
u
r::-,u- 00-',-. -RO
""'- o,..,'v..." Hl ~"""''''''.h...
<Ii _ t;.. "~ "'lC~Ur'i-I
'n T a;timvlli' ~. 1 here un", r;ej, mv ~no
~ tb6 .. fit ~ r:n""t ill Coifilslt i-e..
"'tws - _ -;-j 1 /'
I. /",f - ~ /!I,( fu..v . dG"'C':'
I j, 0 I )w JJ(
, i J,~.t .....t 1,/.. J1;""'~.
/ I _ I ,
~rrttlC'.;:fm';rv
EXHIBIT B
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No, 587, approved May 16, 1929), p, L.1784
COMMONWEALTH OF PENNSYL VANIA
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
February 3, 2006
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,
SWORN TO AND SUBSCRIBED before me this
3 day of Februarv. 2006
~2'~7Ar~
Notary .. '.
'-:XHIBIT !3
,
CUMBERLAND LAW JOURNAL
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action-Law
No. 05-2078 Civil Term
Wells Fargo Bank, N.A.. as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PTl
Mortgage Pass-Through
Certificates Series 2003-0PTl,
P,O, Box 57038,
Irvine, CA 92619-7038,
Plaintiff
v,
Joseph D. Miller, Jr.
Dana Miller. Mortgagor
34 West Keller Street
Mechanicsburg. PA 17055.
Defendant(s)
NOTICE OF SALE OF
REAL PROPERTY
To: Joseph D. Miller. Jr.
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West
Keller Street. Mechanicsburg. PA
17055 is scheduled to be sold at the
Cumberland County Sheriffs Sale on
March 8. 2006 at 10:00 a.m. in the
Commissioners Hearing Room. 2nd
Floor, Courthouse. Carhsle. PA 17013-
3387, to enforce the court judgment
of $132,684.14, obtained by Plain-
tiff above (the mortgagee) against
you. If the sale is postponed. the
property will be relisted for the Next
Available Sale.
ALL THAT CERTAlN house and
lot of ground (known as Lot No. 15)
situate and being on the North side
of West Keller Street in the Borough
of Mechanicsburg, County of Cum-
berland and State of Pennsylvania,
bounded and described as follows,
to wit:
BEGINNING at a point at the cor-
ner of Lot No. 13. now or formerly
of Elda M. Bascom, being also on
the building line of said West Keller
Street; thence by said Lot No. 13
northward. one hundred fifty-nine
(159) feet, more or less, to a twenty
(20) foot alley; thence by said alley,
eastward, Ll-tirty-five (35) feet. more
or less. to Lot No. 17, now or form-
erly of Brindle; thence by said lot,
southward, one hundred fifty-nine
(159) feet, more or less. to a point
in the building line of West Keller
Street. aforesaid; thence by said
building line, westward. thirty-five
(35) feet, more or less. to a point at
the place of beginning.
Having thereon erected a two-
story frame dwelling house and oth-
er buildings. known and numbered
as 34 West Keller Street.
BEING KNOWN AS: 34 West Kel-
ler Street. Mechanicsburg. PA 17055.
PROPERTY ID NO.: 16-23-565-
124.
TITLE TO SAID PREMISES IS
VESTED IN Joseph D. Miller. Jr..
married person by deed from Mary
E. Paul and Elwood C. Paul, hus-
band and wife dated 12/15/99 re-
corded 12/23/99ln Deed Book 213,
Page 836,
MARK J. UDREN
MARK J. UDREN
& ASSOCIATES
Attorneys for Plaintiff
Woodcrest Corpo;,-ate Center
III Woodcrest Road
Suite 200
Cheny Hill, NJ 08003-3620
(856) 669-5400
Feb. 3
3
EXHIBIT B
J
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Tanuny Shoemaker, Classified Advertising Manager, of The Sentinel, of the County
and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a
newspaper of general circulation in the Borough of Carlisle, County and State
aforesaid, was established December 13th, 1881, since which date THE SENTINEL has
been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions
and issues of THE SENTINEL on the following day(s)
January 30,2006
COPY OF NOTICE OF PUBLICATION
NOTICE OF ACTION IN MORTGAGE FORECLOSURE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -lAW
NO. 05-2078 CIVIL TERM
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
\1ortgage Pass-Through
:ertificates Series 2003-0PT1
".0. Box 57038
'rvine, CA 92619-7038,
Plaintiff
v,
Joseph D. Miller, Jr.
Jana Miller, Mortgagor
34 West Keller Street
V1echanicsburg, PA 17055
Detendant(s)
NOTICE OF SALE OF REAL PROPERTY
To: Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
Your house (reat estate) at 34 West KeH2r Street, Mechanicsburg, PA 17055 is
scheduled to be sold at the Cumberland County Sheriff's Sale on March 8, 2006
at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse,
Carlisle, PA 17013.3387, to enforce the court judgement of $132,684. 14,
obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
~LL THAT CERTAIN HOUSE AND LOT OF GROUND (KNOWN AS LOT NO. 15)
SITUATE AND BEING ON THE NORTH SIDE OF WEST KELLER STREET IN THE
BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND AND STATE
OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
3EGINNING AT A POINT ATTHE CORNER OF LOT NO. 13, NOW OR FORMERLY
OF ELDA M. BASCOM, BEING ALSO ON THE BUILDING LINE OF SAID WEST
KELLER STREET; THENCE BY SAID LOT NO. 13 NORTHWARD, ONE
HUNDRED FIFTY-NINE (159) FEET, MORE OR LESS, TO A TWENTY (20) FOOT
ALLEY; THENCE BY SAID ALLEY, EASTWARD, THIRTY-FIVE (35) FEET, MORE
OR LESS, TO LOT NO. 17, NOW OR FORMERLY OF BRINDLE; THENCE BY
SAID LOT, SOUTHWARD, ONE HUNDRED FIFTY-NINE (159) FEET, MORE OR
LESS, TO A POINT IN THE BUilDING LINE OF WEST KELLER STREET,
AFORESAID; THENCE BY SAID BUILDING LINE, WESTWARD, THIRTY-FIVE
(35) FEET, MORE OR LESS, TO A POINT AT THE PLACE OF BEGINNING.
-lAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND
OTHER BUILDINGS, KNOWN AND NUMBERED AS 34 WEST KELLER STREET
3EING KNOWN AS: 34 WEST KELLER STREET, MECHANICSBURG, PA 170551
:JROPEATY 10 NO.. 16-32-565-124
rlTLE TO SAID PREMISES IS VESTED IN JOSEPH D. MILLER, JR., MARRIED
PERSON BY DEED FROM MARY E. PAUL AND ELWOOD C. PAUL HUSBAND
AND WIFE DATED 12/15/99 RECORDED 12/23/99 IN DEED BOOK 213 PAGE
836.
I.tARK J. UDREN
HTORNEY FOR PLAINTIFF
I/IARK J. UOREN & ASSOCIATES
NOODCREST CORPORATE CENTER
111 WOODCREST BOULEVARD, SUITE 200
::HERRV HILL, NJ 08003-3620
156-669-5400
Affiant further deposes that he/ she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement
as to time, place and character of
I:I:~
Sworn to and subscribed before me this
31st day of January, 2006.
.. ..
CI ~
41 tL)tU(,)~ ' / {( )(Clf....
Notary Public
My commission expires: 1.1/1 1:8
COMMONWEALTH OF PENNSYLVANli\ ,
;----..- Notanal Seal . I
\ __ ;hpslma L Wolfe, Notary PublIC I
I ';30'5'€ 8ora. Cumberland County 'I
! V!y {):)f'lrnis:::ion Expires Sept 1. 2008 i
"11.10','. ,,,,,' ':';',('~Bni..c ,r:,.c~ociation Of NOtllfiC"
",XHIB1T 8
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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE TO FILE
TO THE PROTHONOTARY:
ATTORNEY FOR PLAINTIFF
l COURT OF COMMON PLEAS
: CIVIL DIVISION
Cumberland County
NO, 05-2078 civil Term
PROOF OF SERVICE
Kindly file the attached Proofs of Service with regard to
the captioned matter.
Date: March 2, 2006
UDREN LAW OFFICES, P.C.
,
\
I
BY:
Mar J Udren, Esquire
At orney for Plaintiff
EXHIBIT 8
::;:J
'-:-1
::'-:--~
c
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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
v,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE TO FILE
TO THE PROTHONOTARY:
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO, 05-2078 Civil Term
PROOF OF SERVICE
Kindly file the attached Proofs of Service with regard to
the captioned matter.
Date: March 2, 2006
unREN LAW OFFICES, P,C,
J Udren, Esquire
rney for Plaintiff
\
EXHIBITS
Service of Process by
APS International, Ltd.
1-800-328-7171
Wells Fargo Bank, NA as trustee, et. al., Plaintiff(s)
vs,
Joseph D. Miller, Jr., et. al., Defendant(s)
APS International Plaza
7800 Glenroy Rd,
Minoeapolis, MN 55439-3122
APS File #: 075916-0001
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES, P,C,
-Dana Miller
Court Case No, 05-2078 Civil Term
Ms. Henni Crommarty
III Wooderest Rd, Suite 200
Cherry Hill, NJ 08003-3620
State of: P IF 1/11I,4 ) 55.
County of: Je, ~ I(' )
Name of Server: It/!I.J.h. III r rL. 1<</1'1 ~Jf' /2 , undersigned, being duly sworn, deposes and says
that at the time of service, s/he was oflegal age and was not a party to this action;
DatelTimeofServiee: that on the :l7~dayof flFl3/(<lIHYY ,200' ,at ':110'clock ~M
Place of Service:
Documents Served:
Service of Process on:
Person Served, and
Method of Service:
Description uf Person
Receiving Documents:
at .17 S. Baltimore Street, #3
, In Franklintown, P A 17323
the undersigned served the documents described as:
Notice of Sherifrs Sale of Real Property
A true and correct copy of the aforesaid document(s) was served on:
Dana Miller
,/By personally delivering them into the hands of the person to be served.
By delivering them into the hands of , a person
of suitable age, who verified, or who upon questioning stated, that he/she resides with
Dana Miller
at the place of service, and whose relationship to the person is:
The person receiving documents is describeu as follows: N
Sex P . Skin Color It' . Hair Color IJ /(t; I.tJ . Facial Hair 1Yt:!
Approx, ~ge 3:1. ; APprox.'Height .j~" 3 I~ ; Ap~rox, Weight /1 t
/To the best of my knowledge and belief, said person was not engaged in the US Military at
the time of service,
Signature of Server: Undersigned declares under penalty of perjury
that the foregoing is true and correct.
~i!(. -.... ,J. ~.~.~/
Signature of Server
Subscribed and sworn to before me this
~~;;_~IE~Ri2~20 e ,
Notary P NOTARIA ires)
William E. Duke, Not",} Public
NOl'Ih York Bml., York Couut)'
MycommissionexpllaDccember 12, '('''c'
APS International, Ltd.
EXHIBIT B
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, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
,--,
;:"::.J
c)
v,
Joseph D. Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 Civil Term
r,,\......
OJ
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: January 25, 2006
Joseph D, Miller, Jr,
34 West Keller Street
Mechanicsburg, PA 17055
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,
UDREN LAW OFFICES, P.C.
Dated: March 3, 2006
Mar
\
f"XH/B
:: IT 18
,
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PTl
P,O, Box 57038
Irvine, CA 92619-7038
Plaintiff
~ COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO. 05-2078 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: January 25, 2006
Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
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: March 3, 2006
UDREN LAW OFFICES, P,C,
Mar
f:')(HIBIT B
)
VlELLS FARGO BANK.
N.A" as Trustee for
l'vlASTR Asset Backed
Securities Trust 2003-
OPTl Mortgage Pass-
Through Certificates
Series 2003-0PTl,
Plaintiff
IN THE C01JRT OF COMMON PLEAS OF
CUMBERLM'D COUNTY, PENNSYL V.6,,_NIA
v.
CIVIL ACTION - LA W
JOSEPH D MILLER, JR." :
DANA MILLER,
Mortgagor,
Defendant(s)
NO. 05-2078 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 SI day of May, 2004, upon consideration of Plaintif:fs Motion
for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff
may serve the Complaint in Civil Action upon Defendant Joseph D. Miller, II. by (1)
mailing a true and correct copy of the complaint by certified mail and regular maiL to
~,
Defendant's last known address at 34 West Keller Street, Mechanicsburg, PA 17055, (2)
publication once in the Cumberland Law .TournaI and in a newspaper of general
circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 34 West
Keller Street Mechanicsburg, P A 17055.
BY THE COURT,
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which MASTR Asset Backed Securities Trust 2003 Tr is the grantee the same
having been sold to said grantee on the 5th day of Avril A,D" 2006, under and by virtue of a writ
Execution issued on the 10th day of Oct, A,D., 2005, out of the Court of Common Pleas of said County
as of Civil Term, 2005 Number 2078, at the suit ofMASTR Asset Backed Securities Trust 2003 Tr
against Joseph D Miller Jr & Dana is duly recorded in Deed Book No, 274, Page 1902,
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
4-~
day of
In,') Y
, A.D, ;:2 ~c:
~/? Jj/
Recorder of Deeds
Wells Fargo Bank, N,A., as Trustee for
MASTR Asset Backed Securities Trust
2003-0PTl Mortgage Pass-Through
Certificates Series 2003-0PTl
VS
Joseph D, Miller, Jr, and Dana Miller
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No, 2005-2078 Civil Term
William Cline, Deputy Sheriff, who being duly sworn according to law, states that
on December 06, 2005 at 8:04 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: Joseph D, Miller, Jr" by posting the premises located
at 34 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, pursuant to
the order of court, by law.
R, Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry for the defendant, Dana Miller, at 34 West Keller
Street, Mechanicsburg, Cumberland County, Pennsylvania, but was unable to locate her
at that address, The Mechanicsburg Post Office provided a forwarding address of905
Scottish Court, Mechanicsburg, Cumberland County, Pennsylvania. Deputies attempted
service at the latter address, only to be advised by Dana Miller's ex-husband that she does
not reside at 905 Scottish Court, Mechanicsburg, PA, only he resides there, Sheriff Kline
therefore returns the within Real Estate Writ, Notice of Sale and Description in the above
entitled action as NOT FOUND as to the defendant, Dana Miller,
William Cline, Deputy Sheriff, who being duly sworn according to law, states that
on January 12,2006 at 12:59 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 Joseph D, Miller, Jr. and Dana Miller located at 34 West Keller Street,
Mechanicsburg, Pennsylvania, according to law,
R. Thomas Kline, Sheriff, who being du1y 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: Joseph D, Miller, by regular mail to his last known address of 34 West
Keller Street, Mechanicsburg, PA 17055. This letter was mailed under the date of
January 10, 2006 and never returned to the Sheriffs Office,
R. Thomas Kline, Sheriff, who being du1y 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 April 05, 2006 at 10:00 o'clock A,M, He sold the same for the
sum of $1.00 to Attorney Mark Udren for Wells Fargo Bank, N,A., as Trustee for
MASTR Asset Backed Securities Trust 2003-0PTl Mortgage Pass-Through Certificates
Series 2003-0PTl, It being the highest bid and best price received for the same Wells
Fargo Bank, N.A., as Trustee for MASTR Asset Backed Securities Trust 2003-0PTl
Mortgage Pass-Through Certificates Series 2003-0PTl ofP.O, Box 57038, Irvine, CA
92619, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of
$935,74,
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Postpone Sale
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Postage
Posting
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
$30,00
17,96
15,00
15,00
30,00
10,00
20,00
.50
1.00
28.40
1.95
15,00
30,00
,78
6,00
341.00
287,60
21.05
25,00
39,50
$ 935,74
Sworn and subscribed to before me
This 10 t day of
2006, A.D.
S~~ ,;~'"
r~r---rf ~
R. Thomas Kline, Sheriff
ByUocLJl~i0
Real Estate Sergeant
~
3 o. U'O (lde..
) ,sD
c.k..53~JI
~. 1'11733
~(
UD~EN 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, N,A" as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D. Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129,1
Wells Fargo Bank, N,A" as Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1 Mortgage Pass-Through Certificates
Series 2003-0PT1, 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: 34 West Keller Street
Mechanicsburg, PA 17055
1, Name and address of Owner(s) or reputed Owner(s) :
Name Address
Joseph D, Miller, Jr,
34 West Keller Street
Mechanicsburg, PA 17055
2, Name and address of Defendant(s) in the judgment:
Name Address
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Hampden Township
230 South Sporting Hill Road,
Mechanicsburg, PA 17050
Keystone Oil Products
PO Box 157, Camp Hill, PA 17011
..
4.. Name and address of the last recorded holder of every mortgage
or record:
Name - Address
Plaintiff herein, See Caption above,
5, Name and address of every other person who has any record lien
on the property:
Name Address
None
6. Name and
interest in
the sale:
N~e
address of every other person who has any record
the property and whose interest may be affected by
Address
Real Estate Tax Dept,
1 Courthouse Square, Carlisle, PA
17013
Domestic Relations Section
13 N, Hanover Street, Carlisle, PA
17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept, 280946
Harrisburg, PA 17128-0946
7, Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants
34 West Keller Street
Mechanicsburg, PA 17055
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief, I understand that false statements herein are made
subject to the penalties of 18 Pa,C,S, sec, 4904 relating to
unsworn falsification to authorities,
DATED: October 7, 2005
ark J, Udren, ESQ,
Attorney for Plaintiff
,
.
o
"
UOREN 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, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates series 2003-0PT1
P,O, Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D, Miller, Jr,
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West Keller Street, Mechanicsburg,
PA 17055 is scheduled to be sold at the Sheriff's Sale on March
8, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $132,734,15, obtained by Plaintiff above (the mortgagee)
against you, If the sale is postponed, the property will be
relisted for the Next Available Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1, The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2, You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3, You may also be able to stop the sale through other legal proceedings,
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
,
.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RiGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
,
1, If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the pr"ce 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 SHOULp TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU PO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTEp BELOW TO
FINO 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
ATTORNEY tv..
~,
UQREN LAW OFFICES, P.C. ,
BY: Mark J. Udren, Esqu~re
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
, .
.
Wells Fargo Bank, N,A., as
Trustee for MASTR Asset Backed
Securities Trust 2003-0PT1
Mortgage Pass-Through
Certificates Series 2003-0PT1
P,O. Box 57038
Irvine, CA 92619-7038
COURT OF COMMON PLEAS
CIVIL DIVISION
cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v,
Joseph D, Miller, Jr.
Dana Miller, Mortgagor
34 West Keller Street
Mechanicsburg, PA 17055
NO, 05-2078 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Joseph D. Miller, Jr.
34 West Keller Street
Mechanicsburg, PA 17055
Your house (real estate) at 34 West Keller Street, Mechanicsburg,
PA 17055 is scheduled to be sold at the Sheriff's Sale on March
8, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA , to enforce the court judgment
of $132,734,15, obtained by Plaintiff above (the mortgagee)
against you, If the sale is postponed, the property will be
relisted for the Next Available Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669- 5400,
2, You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered,
You may also ask the Court to postpone the sale for good cause.
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 contac
one, the more chance you will have of stopping the sale. (See notice
page two on how to obtain an attorney,)
,A
,
YelU MAY ST,ILL BE ABLE TO SAVE YOUR. PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S &KLE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
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
.'
~L THAT CERTAIN HOUSE AND LOT OF GROUND (KNOWN AS LOT NO. ~5) SITUATE AND BEING ON
XHE NORTH SIDE OF WEST KELLER STREET IN THE BOROUGH OF MECHANICSBURG, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT AT THE C01Ull!:R OF LOT NO. ~3, NOW OR FORMERLY OF ELPA M.
BASCOM, BEING ALSO ON THE BUILDING LINE OF SAID WEST KELLER STREET; THENCE BY SAID
LOT NO, ~3 NORTHWARD, ONE HUND1U!:D FIFTY -NINE (~59) FEET, MORE OR LESS, TO A 'l'WENTY
(20) FOOT ALLJ;:Y; THENCE BY SAID ALLEY, EASTWARD, THIRTY - FIVE (35) FEET, MORE OR
LESS, TO LOT NO, ~ 7, NOW OR FORMERLY OF BRINDLE; THENCE BY SAID LOT , SOUTHWARD, ONE
HUNDRED FIFTY-NINE (~59) FEET, MORE OR LESS, TO A POINT IN THE BUILDING LINE OF
WEST XELLER STREET, AFORESAID; THENCE BY SAID BUILDING LINE, WESTWARD, THIRTY - FIVE
(35) FEET, MORE OR LESS, TO A POINT AT THE PLACE OF BEGINNING,
HAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND OTHER BUILDINGS, KNOWN
AND NUMBERED AS 34 WEST KELLER STREET,
BEING KNOWN AS:
34 WEST KELLER STREET, MECHANICSBURG, PA 17055
PROPERTY ID NO,
16-23-565-l24
TITLE TO SAID PREMISES IS VESTED IN JOSEPH D, MILLER, JR" MARRIED
PERSON BY DEED FROM MARY E, PAUL AND ELWOOD C, PAUL, HUSBAND AND
WIFE DATED l2/i5/99 RECORDED l2/23/99 IN DEED BOOK 213 PAGE 836,
WRIT OF EXECUTION a'Jdlor ATTACHMENT
,
,>
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-2078 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., AS TRUSTEE FOR
,MASTR ASSET BAKCED SECURITIES TRUST 2003-0PTl MORTGAGE P ASS-THROUGH
CERTIFICATES SERIES 2003-0PTl Plaintiff (s)
From JOSEPH D MILLER, JR., AND DANA MILLER, MORTGAGOR, 34 W. KELLER ST.,
MECHANICSBURG PA 17055.
(I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 34 W. KELLER ST., MECHANICSBURG PA 17055 (SEE LEGAL
DESCRIPTION) ,
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated,
Amount Due $132,734.15 L.L. $.50
Interest FROM 10/8/05 TO 3/8/06 @ 222.67 PER DIEM = $3,445.84
Atty's Comm % Due Prothy i. /)0
Ally Paid $180.54 Other Costs
Plaintiffpaid
Date: OCTOBER 10, 2005
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQ.
Address: 111 WOODCREST RD., STE. 200
WOODCREST CORPORATE CENTER
CHERRY HILL NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: (856)669-5400
Supreme Court ill No, 04302
, .
Real Estate Sale # 12
On November 30, 2005 the Sherifflevied upon the
defendant's interest in the real property situated in
Borough of Mechanics burg, Cumberland County, PA
Known and numbered as 34 West Keller Street,
filed with this writ and by this reference incorporated herein,
(ii)
~
c:::=a
<3i>
G'\N
Mechanicsburg, more fully described on Exhibit "A"
Date: November 30, 2005
By: Jn~ ~
Real Estate Sergeant
'111 :8 '\j \ \ DO SUUl
"id ')'\Ld':d~:,t. I", ,-
.:I:!\B3HS ;i\IJ eol
_..",1:
Ij.::iL
I' \
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
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co" a cOlporation organized and existing under the laws of
the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and
The SundayPatriot.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 in the 24th and 31st day(s) of January and
the 7th day(s) of February 2006, That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317,
PUBLICATION
COPY
SALE#12
.
NOTARY. UBLIC
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
..
I
PROOF OF PUBLICA nON OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No, 587, approved May 16, 1929), p, L.1784
STATE 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:
January 20,27, February 3,2006
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal pCliodical 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 ofpubJication are true.
AND SUBSCRIBED before me this
day of February. 2006
~~ N1ao/,,6~p~
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Wrtt No, 2005-2078 CMI
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securttles Trust 2003-0PTI
Mortgage Pass-Through
CertifIcates Series 2oo3-0PTI
vs.
Joseph D, MUler, Jr, and
Dana MUler
Atly,: Mark Udren
ALL that certaln house and lot of
ground Iknown ... Lot No, 151 oItu-
ate and belng on the North 8Ide of
West I!dIer Street In the Borough
of Mechanicsburg. County of Cum~
berland and State of Pennsylvania.
bounded and descrtbed as follows.
to wit:
BEGINNlNG at a point at the cor-
ner of Lot No. 13. now or formerly
of Elda M, Bascom, being also on
the building line of said West Keller
Street; thence by sald Lot No. 13
northward. one hundred fifty-nine
{I59) feet, more or less, to a twenty
(20) foot alley; thence by said alley.
eastward. thlrly-flVC (35) feet, more
or less, to Lot No. 17, now or for-
merly of Brtndle: thence by said lot.
southward, one hundred fifty-nine
(159) feet, more or less. to a point
In the buildIng line of West Keller
Street. aforesaid; thence by said
bullding line. westward. thirty-five
(35) feet, more or less. to a point at
the place of beginning,
HAVING thereon erected a two-
story frame dwelling house and
other buildings, known and num-
bered as 34 West Keller Street.
BEING KNOWN AS: 34 WEST
KELLER STREET. MECHANICS,
BURG. PA 17055,
PROPER1Y lD NO,: 16-23-565-
124,
TITLE TO SAID PREMISES IS
VESTED IN Joseph D, MUler. Jr..
marrted person by deed from Mary
E. Paul and Elwood C. Paul. hus-
band and wife dated 12/15/99 re-
corded 12/23/99 In Deed Book 213
Page 836,