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Home My WebLink About05-3614 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@Udren.com Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. william S. Rhoades Bonnie S. Stacy NO. () 5 - 3k, [y 510 Sample Bridge Road Enola, PA 17025 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE CI'u~L/~vrr YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escri ta sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante Y requiere que usted cumpla con todas las provisiones de esta demanda. usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR 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 creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address ofthe original creditorif differentfrom the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignments of Record to: Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A Recording Date: 02/22/05 Book: 715 Page: 1703 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g) The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 510 Sample Bridge Road MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Silver Spring COUNTY: Cumberland DATE EXECUTED: 02/05/02 DATE RECORDED: 02/19/02 BOOK: 1749 PAGE: 3073 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 7/5/05: Principal of debt due Unpaid Interest at 9.65% from 5/1/04 to 7/5/05 (the per diem interest accruing on this debt is $40.95 and that sum should be added each day after 7/5/05) $154,873.79 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) Late Charges (monthly late charge of $80.37 should be added in accordance with the terms of the note each month after 7/5/05) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 16,395.45 325.00 280.00 1,241.76 1,305.60 7,743.69 $182,165.29 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $182,165.29 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. /~{t'1/1( (!~ Ma'rk . Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE NORTHEAST CORNER AT A STONE MARK; THENCE RUNNING IN A WESTERLY DIRECTION, ONE HUNDRED EIGHTY-EIGHT (188) FEET TO AN IRON PIN; THENCE IN A SOUTHERLY DIRECTION, ONE HUNDRED EIGHTY-FOUR AND FOUR TENTHS (184.4) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION, TWO HUNDRED TWO (202) FEET TO A STONE IN THE ROAD; THENCE IN A NORTHERLY DIRECTION, TWO HUNDRED FIVE (205) FEET TO A STONE MARK AT THE PLACE OF BEGINNING. CONTAINING LESS THAN ONE (1) ACRE. PARCEL ID NO. 38-04-0367-008B January 3, 2005 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE :~~:~ "~ ~~~:~~~;~t~;:~;,t t::r:':~~i:~ 1I:/~~~ hornp is in '1PfIlIlIt~~~~ t~:~:7::~ . ____ s L_______~_____.. L___ I _ ___;1._1' nlltllrp ofthp rlpfllnlt IS provIQpQ In thp Qttgc-hpr) pnyps. Thp HOMF~~;:~:~:y~~::~~(,:;~:~~I~TAN(,F: PROGRAM (:F:'A:~,:; hI' IIhlp to 1 ~ Notu~p. pvphllnlli: how thp pr~~rQm works. ::0 ;;;:~~:.:;~n~;~H~~I,\;;: ~.F.T WITH A rON~nMF.R r~~~~ ron ~ ~ ... OF THF. DATR OF TH:::~TTrF. TlIkp t~: ~'~ti~~ w~th YOII whpn YOII rnppt with thp rOllnsplinf;' AgI'n..y. ~~~~~ ~rl:= "~ ~:~~~ :::!,pr of ronsnrnpr rrpr!it rOllnsplin: ~~~ ~~ r:;:':;;::';t'~:~ ;~:;~.;;f,~~';: ~.'~:.::;"':i,:;,~~~,;i':~ hp9rinr rAn I'All (717) 7RO..1R(9). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR V1VIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFlCACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNERDs EMERGENCY MORTGAGE ASSISTANCE PROGRAMD EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU IllPOTECA. eXHIBIT A , Page 1 of6 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: William S. Rhoades ~QI!!!,ie_S.Sla~y _.. 510 Sample Bridge Road _EI!Ql<hl'AJ1!!zS----.-....- ....------------ Q!!Qs74HZll_______________________ _.QPDQ!!_Q!!e_MQrJ;g!!ge-CQn!Q!:!!liQ.R-------------------- Wells Fargo Bank Minnesota, National Association as Trustee for Option One Mortgage Loan Trust ._.Z!!!!kAAsset~a~.\l,e!!_Cemfi~ale!'-Se!tesJQQZ:A-----.. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: HOMEOWNERDS EMERGENCY MORTGAGE ASSISTANCE PROGRAM yon MA V RF.lUJf;mT.R FOR FTNAN('IAI. A~~T~TANC.R WHTrH C.A N ~A VR vonR HOMR FROM FORR('I.O~TJRR A NO HFJ.PVOTJ MAKF. FnTnRF. MORTf;A~F. PAVMF.NTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERIls EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE IlACTIl), YOU MAYBE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGffilLITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TRMPOR A RV ~T A V OF FORRC.I.O~TJRR -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Dface-to-faceD meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THTS MF.F.TIN~ MTTST Oc.nTR WITHIN THR NEXT (~) OAV~ IF VOlT DO NOT APPT V FOR FMFRGFNrV MORTGAGF ~~~;:~~F VOlT MTTST RRTNG VOlJR MORTGAGF TTPTO DATF THF PART OFTHTS T T FD DHOW TO rnRF VOTTR MORTGAGF DFFATTI.TD FXPT ATNS HOW TO RRTNG VOlJR MORTGAGF TTP TO DATF C'ON~TTMF.R C'RROIT C'OTJN~F.T .TNf; Af;RNC'TFS -- 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. Thp n"mp< "nnTP<<p< "nn IP]pphonp nllmhPT< of rle~lV1~tf':rl C'ClnS:llmf':r ~rf>:i1;t rOllns:p.1ine ~ep.nr;f':r;;:. fnT thf': (,()llnty 1n whir.h thp. prnpp.rty lr;;:. lnr.::lte:n "TP ,pI forth "I Ihp pnn of Ihi, NOli"p. It is only necessary to schedule one face-to-face meeting. Advise your lender immpni"IPly of your intentions. APPUC'ATTON FOR MORT~A~R A~~T~TANC'R -- 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 Page 2 of6 Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 'face- to-face meeting. YOU Ml1SI FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. Af:FNrV ArTTON _. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can stiIl apply for Emergency Mortgage Assistance.) HOW TO CITRR YOUR MORTGAGR nRFAlJT,T (Rrin~ it lip to rhlte). N A TITRE OF THE nF.F A TTT ,1' __ The MORTGAGE debt held by the above lender on your property located at: 510 Sample Bridge Road Enola, P A 17025 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: ..M!!!!!hJy~!!yme!!t,<;!!L$15J5.1lH9x.J!!!y..l,JQ!!4JhrJ!.J.a!!!!aD'1,2005-.=:.$1!!(i7Ji,z(i............. ..M!!!!thi..YX,ate.Charg~!!f$~!!,~7.J!!rJ!!!yl,.~!!!!4thrnJ)el,;eml>erl,2004....=:.$4~~,z~...... Other charges (explain/itemize): Escrow Advance=$821.32 Suspense Credit=($260.79) .Acc!!lli!!!J!ted.X,ate.Cha.rg~=:$:}.41,16....................... TQTALAM.Q!J!'IT~ASTmJE:...._........ .......................... ~120(if\ 17 .. B. YOU HA VB FAILED TO TAKE THE FOLLOWING ACTION (Do not llSP if not "pplir."hle): lSLA HOW TO rTTRE THE nEF A TTT .1' __ 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 ~1201iO 17 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P~ymf':nt" mll<::t hI" m~np. p.ithf':T hy ~~,h r::l"hiPT', rhpc:k (';prt-ifip.n c.11p.rk or mnnf':Y nrne:T m~r1f': p::l)':1hlp. :'Inn <;;f':ntt()" Tlrlrp.n 1 .~w Offif'p." P.r:. W nolleri'd C:o'1>or~tp. l:p.nteT 111 W oorlrrpd Ro~rl ~nitp. 200 rhprt:}' Hill NT f\1I00~.~(i2f\ You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (no not mp if not "pplic"hlp ): lSLA Page3of6 ,il IF VOl] no NOT rTJRF THE nEFA TH.T .. If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lenrteT intpnrl~ to PyprC'i~p it~ riy)1f~ to Q('('P:lpr~tp the mortf~~p rlpht. 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 forp('lo~p npon yonr mort~~fprl proJ)Prty. TF THE MORTGA(~E TS FORErT ,0SF.n TWON .. The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable 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 yon ('nrl' thl': npf~mlt within thp. THIRTY L~Ol OJ\. V pPrinrlr yon will not he reqnirprt to p~y ~ttornpy'~ fees. OTHER T .ENDER REMEnTES .. The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RTGHT TO rTJRF THE. nEFATH.TPRTOR TO SHERTFF'S SAT,R.. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon ,till h"ve the right to ~'lre the rlefm,1t "nrl prevent the ,"Ie "t "ny time np to one honr hefore the Sheriff", S"te Yon m"y rlo '0 hy ~~~:~~~~~;~:;~ ~:.~~;nt then P",t rlne ph" "ny l"te or other ch"~gr' then rlne re",on"hle "ttomey', fee'. "nrl 1 thf': fnT~f:lnSllTf': s~lf> ~nrl :my nthf':T r.nsts r.nnnf':df':n wlth thf': Shf':nff' s S~If': ~s spf':f:lfif':n In writlne hy thf': If':nnf':T ::Inn hy pf':rforn11ne ::Iny nthf':T Tf':qn1Tf':mf':nts llnnPT thp. mnrtg::lff':. 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. EART.TEST POSSffiT.F SHERIFF'S SAT,E nATI .. It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately li months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO rONT ArT THF T .ENDER' Phone Number: Fax Number: Contact Person: ..Ql!tiQI!Qn~Mm1g!U~~.(;m:p.Qr!!tiQIL........................ 4600 Touchton Road E Building 200 Suite 102 .J!!!;!g;.Q.nYi!!!',FL.1U't6........................d............. .9.!!4c'!66,17~.~~.6173!L.......... ....................... l:\.66c4'!'Z,17(i3..................-............................. ...(;!!~tml!~rS~..D1~~. ...................... ........................ Name of LenderlServicer: Address: EFFErT OF SHERTFF'S SALF.. 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 Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSTTMPTTON OF MORTGAGF .. You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 6 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your deht, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law finn is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003.3620 (856) 669.5400 Page 5 of6 YOl! MAY A1.S0 HAVE THE RT(;HT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITIITED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. rONSTTMRR rRTf,nIT rOTTNSRT ,TN(; A(;E.NrmS SRRVTN(; YOTTR rOTTNTY rl!MRF.RT.ANn rOTINTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 54]-1757 FAX (717) 541-4670 Financial Counseling Services of Franklin 31 Wesl3rd Street Waynesboro, P A 17268 (717) 762-3285 FAX n/a Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17]01 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Comrn of tbe Capital Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Autbority 139-143 Carlisle SI. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of6 '\ v , ~ I 1 ~ o -n ;- -d ~ ~ -I o ~ l;\ z (j\ / ~- ---- O~ ~ J: 2-? r:::--:> ~^ --<; ~ l.1/ /'C) 85' ~ 0 n" >=".. o. "-1( 6 V) ~ ~ o o OC ~~~I:'~ m~7J ::D<. 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Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. M rk J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. p 0 ~ if- T'(f ~ It.. .U( _ t..v U( 6'- -.a C>- ~ ~ ~ r l ~ ~ C"') r-..' _ C~~J - (:) cr.. o .1 ( --I f' ~T~ I 1-:"1;JJ ,C1 ,0 en , ,) ~ =1.: (;...? '" SHERIFF'S RETURN - REGULAR CASE NO: 2005-03614 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS RHOADES WILLIAM S ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RHOADES WILLIAM S the DEFENDANT , at 0014:25 HOURS, on the 19th day of July at 510 SAMPLE BRIDGE ROAD , 2005 ENOLA, PA 17025 by handing to BONNIE STACY a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Ans<~.~ ~ 18.00 8.00 .00 10.00 .00 36.00 R. Thomas Kline 07/20/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: me this ':21. 't: day of o,c'~'" , A. D. O~ ' rothonotary , # SHERIFF'S RETURN - REGULAR CASE NO: 2005-03614 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS RHOADES WILLIAM S ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon STACY BONNIE S the DEFENDANT , at 0014:25 HOURS, on the 19th day of July at 510 SAMPLE BRIDGE ROAD , 2005 ENOLA, PA 17025 by handing to BONNIE STACEY a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answe<~_~ pg 6.00 .00 .00 10.00 .00 16.00 R. Thomas Kline 07/20/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: ~ ~ . riff me this ;u. e day of ()~l' ;2005 A.D. ~r2 'hu;h.,~, . r thonotary , '- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. william S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 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) William S. Rhoades and Bonnie S. Stacy 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 7/6/05 to 8/23/05 Late charges per Complaint From 7/6/05 to 8/23/05 $182,165.29 2,006.55 160.74 TOTAL $184.332.58 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is atta hed hereto. r J. U ren, ESQUIRE torney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: {')(J{t :)L/ ;V-)/l--S" I ,"",CAT~' "4 PROPR Y ~ 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 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Cert~f~cates, Series 2002-A plaintiff ATTORNEY FOR PLAINTIFF , COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. william S. Rhoades Bonnie S. Stacy Defendant(s) NO. 2005-03614 TO: William S. Rhoades 510 sample Bridge Road Enola, PA 17025 DATE of Notice: August 11, 2005 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND'THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WI E USED FOR THAT PURPOSE. . r TI, ~squlre woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certlflcates, Series 2002-A Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. William S. Rhoades Bonnie S. Stacy Defendant(s) NO. 2005-03614 TO: Bonnie S. Stacy 510 sample Bridge Road Enola, PA 17025 DATE of Notice: August 11, 2005 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL E USED FOR THAT PURPOSE. ar. , squlre Woodcrest Corporate Center 111 woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 plaintiff v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2005-03614 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the united States of America or its Allies as defined in the servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: william S. Rhoades Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Bonnie S. Stacy Over 18 As captioned abo Unknown Nam Tit e: Com any: MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. Sworn to and subscribed before me this 23rd day ~:~AU9Ust, 2005. No a~~2~l^!:) k;(j': r , -'....;. .,~ -;.~ INRE: William Samuel Rhoades, Debtor(s) IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA CHAPTER 13 CASE NO. 1-05-bk-00606 MDF Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Corporation Loan Trust 2002-A, AssetOBacked Certificates, Series 2002-A, Movant, vs. William Samuel Rhoades, Debtor(s) I Respondent(s), and Charles J. DeHart, Ill, Trustee I Respondent. ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY Upon consideration of the motion of Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Corporation Loan Trust 2002-A, AssetOBacked Certificates, Series 2002-A for Relief from the Automatic Stay, it is hereby ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided under 11 U.S.c. 9362, is modified with respect to premises: 510 Sample Bridge Road Enola, P A 17025 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. B'Y tile Court. .' 71 ~a~ B '~JUdge (JK) Dated: June 28 2005 This electronic order is signed and filed on the same date. c 1 ~ .JCJ.. L " ....(') Q - F ......... () C) ....., ~ f-;' C::) 0 C-;;;) ("- en -n '- --...... ~ ~ :bo =J1 ~ ~ c:: ~ L, fl'ifJl ~ ", "TJf"'T"i -&:- '::;16 f(' y t " , ? '.,T~:fJ -~ S) ::,-','-(') J:- cjrn --; -~~ -I .< - .~ ~'l1 0 -< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Interest From 8/24/05 to Date of Sale 12/7/05 Per diem @$40.95 $184,332.58 4,340.70 Amount due (Costs to be added) $ ar J. U ren, ESQUIRE ATTORNEY FOR PLAINTIFF r::J ~ ...., a ~ (-:1 = \7:.::1 -n ...... ~ <:: en c...., --I \.:; -(q ~ ~ ........ W :;':,'11" :L::o r- ~ :~ -t -:-G .Crt 6' 6' ........ c::: rl1r- l ........ ~ G' -)rn ~ () V) () Crt N "~lCi ~ C> D 0 C> ..,.. ;'-'),t) D D- C () C () C' 0 .:0'1'::,]"-, Z C> ~~ ~?~10 .......... , .- t (l'- ....... I -~-~ cyli ~ ~ t ~ r ~~ a --\ p "1> --< ~ '-::"". or '.0 "' ~ ~ ~.:2 '< N 0. , .:::: "' "' ~ l "' ~ "' , - ~=e "' , "' - "' - "' t .~ -r- ~ l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3614 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2002-A ASSET- BACKED CERTIFICATES, SERIES 2002-A, Plaintiff (s) From WILLIAM S. RHOADES AND BONNIE S. STACY (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,332.58 L.L. $.50 Interest FROM 8/24/05 TO DATE OF SALE 1217105 - PER DIEM @$40.95 -- $4,340.70 Atty's Cornrn % Due Prothy $1.00 Atty Paid $134.00 Plaintiff Paid Date: AUGUST 24, 2005 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SmTE 200 CHERRY HILL, NJ 08003-3620 Attomey 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 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 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. rk . Udren, ESQUIRE TTORNEY FOR PLAINTIFF C) s: ,..., = c.::,) <:.1'\ """ c:: C;) t" 17 o -n .-\ -C..,., ['\1P .ClP=; ~g~ ';=~\P\ ."," ~~ ..",", :::.-,~ 9 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 v. ~ COURT OF COMMON PLEAS i CIVIL DIVISION \ Cumberland County \ MORTGAGE FORECLOSUE>< ~ NO. 2005-03614 Wells Fargo Bank Minnesota, National Association, as Trustee for option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 plaintiff William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road EnOla, PA 17025 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, as Trustee for option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A, 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: 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 1. Name and address of owner(s) or reputed owner(s): Name Address William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address plaintiff herein. See Caption above. PHFA 211 North Front Street P.O. Box 15628, Harrisburg, PA 17101 5. Name and address on the property: Name of every other person who has any record lien Address none 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17103 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 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 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: August 23, 2005 Mark . Udren, ESQ. Attorney for plaintiff n ~: N '23 0' ,,-" c:: c,-) r....) .r:- -;:'~;~ -:... o -n .-1 -t-ri rnp ~r~~ ;;~.~~S '.-::rn ~:'!" v ~~ - <? :;:~ - UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court jUdgment of $184,332.58, 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. amount due 5400. The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-669- 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 o ~~ N c? (:;:::) U' ? c:. (n (; \ ~ N .r:- '- ~'- " ~~ ...;;.'.. ~ ....... :C..,-, rn? -0 in :c;y \:')() '::l~ :'~1 ~:?, ~7 -C-,-l :.:< '2 .r:- - UDREN LAW OFFICES, P. C. BY~ Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER ~~~ WOODCREST ROAD, SUITE .200 CHERRY HILL, NJ 08003-36.20 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2005-03614 SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Bonnie S. Stacy has filed Chapter 7 Bankruptcy in the Middle District of pennsylvania on September 20, 2005, Bankruptcy Case No. #05-06363. \M Mark J. 'Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff 2) -' ~..- , ' ';::is ~ ,P o Sl.~ - , ?3:: - !'0 --------- \ " , Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A VS William S. Rhoades and Bonnie S. Stacy In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-3614 Civil Term R. Thomas Kline, Sheriff, who being duIy sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Poundage Advertising Levy Mileage Surcharge Law Library Prothonotary Law Journal Share of Bills 30.00 4.52 15.00 15.00 12.80 30.00 .50 1.00 101.00 20.89 $230.71 Sworn and subscribed to before me This JIi. day of t'J~'(t('f\\w- 2005, A.D. SOA~; . ,.-;, - :--< /~ .' 7..... ~ R. Thomas Kline, Sheriff (' o:z Prothonotary (. (1l de :51 SID ~ /1C['f7 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Eno"la, PA 17025 Defendant(s) NO. 2005-03614 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A, 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: 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PHFA 211 North Front Street P.O. Box 15628, Harrisburg, PA 17101 5. Name and address on the property: Name of every other person who has any record lien Address none 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17103 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 ~n the property which may be affected by the sale: Name Address Tenants/Occupants 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 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 Ito unsworn falsification to authorities. ! DATED: August 23, 2005 .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 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp) , PA 17025 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, 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 attorneyTs fees. To find out how much you must pay, you may call: (8561 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. amount due 5400. The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-669- 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 ALL THAT CERTAIN "TRACT OF LAND SITUATE IN"TBE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE NORTHEAST CORNER AT A STONE MARK: THENCE RllNNING IN A WESTERLY DIRECTION, ONE HlJNDRED EIGHTY-EIGHT (~88) FEET TO AN IRON PIN: THENCE IN A SOUTHERLY DIRECTION, ONE HUNDRED EIGHTY-POUR AND FOUR TEN'l'HS (~84.41 FEET TO AN IRON PIN: THENCE IN AN EASTERLY DIRECTION, TWO HUNDRED TWO (202) FEET TO ~. STONE IN THE ROAD: THENCE IN A NORTHERLY DIRECTION, TWO HUNDRED FIVE (205) FEET TO 1<. STONE MARE AT THE PLACE OF BEGINNING. CONTAINING LESS THAN ONE ( ~) ACRE. PARCEL ID NO. 38-04-D367-008B BEING KNOWN AS: TWP) , PA 17025 510 SAMPLE BRIDGE ROAD, ENOLA (SILVER SPRING PROPERTY ID NO. : 38-04-0367-008B TITLE TO SAID PREMISES IS VESTED IN WILLIAM S. RHOADES AND BONNIE S. STACY BY DEED FROM WILLIAM S. RHOADES DATED 02/05/02 RECORDED 02/19/02 IN DEED BOOK 250 PAGE 2169. . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on December 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call, (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the 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 ALL THAT CERTAIN "TRACT OF LAND SITUATE IN "THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEG:rNNJ:NG AT 'I'HE NOR'I'HEAST CORNER AT A STONE MARK; THENCE RUNNING IN A WESTERLY DIRECTION, ONE IlUNIlRED EIGIITY-EIGIIT (~88) FEET TO AN IRON PIN; THENCE IN A SOU'l'HERLY DIRECTION, ONE HUNDRED EIGHTY-FOUR AND FOUR TENTHS (U4.4) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION, '!'WO IlUNIlRED TWO (202) FEET TO A STONE IN = ROAD; THENCE IN A NORTHERLY DIRECTION, '!'WO HDNDRED FIVE (205) FEET TO A STONE MARK AT THE PLACE OF BEGINNING. CONTAINING LESS THAN ONE (1) ACRE. PARCEL J:D NO. 3S-04-0367-008B BEING KNOWN AS: TWP) , PA 17025 510 SAMPLE BRIDGE ROAD, ENOLA (SILVER SPRING PROPERTY ID NO. : 38-04-0367-008B TITLE TO SAID PREMISES IS VESTED IN WILLIAM S. RHOADES AND BONNIE S. STACY BY DEED FROM WILLIAM S. RHOADES DATED 02/05/02 RECORDED 02/19/02 IN DEED BOOK 250 PAGE 2169. . ,', WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3614 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2002-A ASSET- BACKED CERTIFICATES, SERIES 2002-A, Plaintiff(s) From WILLIAM S. RHOADES AND BONNIE S. STACY (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,332.58 L.L. $.50 Interest FROM 8/24/05 TO DATE OF SALE 12/7/05 - PER DIEM @$40.95 -- $4,340.70 Atty's Comm % Due Prothy $1.00 Atty Paid $134.00 Plaintiff Paid Date: AUGUST 24, 2005 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court lD No. 04302 (of,"") c:;:a ~ fi - Real Estate Sale #24 On September 0 l, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, P A Known and numbered as 510 Sample Bridge Road, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 01, 2Q05 .. -..^ '. -" .' . ~~!". (;~J:?' ByJofuJ ~8-. Real Estate Sergeant , L~:' {": (-',""; in, . 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 (/k.rL? ./u~.J /'1 dOO.s- 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. // )L(1 - SWORN TO AND SUBSCRIBED before me this /~ dayof ~ cJ.~05 ~~~~)L. ,--_..Netary ~:;);,,;< ~~ REAL ESTATE SALE NO. 24 Writ No. 2005-3614 Civil Wells Fargo Bank Minnesota. National Association, as Trustee for Option One Mortgage Loan Trust 200Z-A Asset~Backed Certificates, Series 2002-A VS. William S. Rhoades & Bonnie S. Stacy Atty.: Mark J. Udren ALL THAT CERTAIN tract of land situate in the Township of Silver Spring. County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at the northeast COT- ner at a stone mark; thence run- ning in a westerly direction, one hundred eighty-eight ( 188) feet to an iron pin; thence in a southerly direction, one hundred eighty-fouf and four tenths (184.4) feet to an iron pin: thence in an easterly di- rection. two hundred two (202) feet to a stone in the road: thence in a northerly direction. two hundred five (205) feet to a stone mark at the place of Beginning. CONTAINING less than one 0) acre. PARCEL ID NO. 38-04-0367- 008B. BEING KNOWN AS: 510 Sample Bridge Road. Enola (Silver Spring Twp), PA 17025. PROPERlY ID NO.: 38-04-0367- 008B. TITLE TO SAID PREMISES IS VESTED IN William S. Rhoades and Bonnie S. Stacy by deed from WilHam S. Rhoades dated 02/05/02 reo . corded 02/19/02 in Deed Book 250 Page 2169. . . o. q-I! -0(. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due $184,332.58 ,j Interest From 8/23/05 15,561.00 to Date of Sale SeDtember 6, 2006 Ongoing Per Diem of $40.95 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. 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 ~11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 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: 510 Sample Bridge Road Enola (Silver Spring Twp), PA 17025 SEE LEGAL DESCRIPTION ATTACHED Amount due $184,332.58 Interest From 8/23/05 15,561.00 to Date of Sale September 6, 2006 Ongoing Per Diem of $40.95 to actual date of sale including if sale is held at a later date (Costs to be added) By ~ Clerk Date , COURT OF COMMON PLEAS NO. 2005-03614 ===================================== Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A vs. William S. Rhoades Bonnie s. Stacy ------------------------------------- ------------------------------------- WRIT OF EXECUTION ------------------------------------- ------------------------------------- REAL DEBT $ 184,332.58 INTEREST $ 15,561.00 from 8/23/05 to Date of Sale September 6, 2006 Ongoing Per Diem of $40.95 to actual date of sale including if sale is held at a later date COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ ), PA 17025 ark J. Udren, ESQUIRE REN LAW OFFICES, P.C. OODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856) 669-5400 . . ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLV1INIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT TIlE NORTHEAST CORNER AT A STONE MARK; THENCE RUNNING IN A WESTERLY DIRECTION, ONE HUNDRED EIGHTY-EIGHT (188) FEET TO 1IN IRON PIN; THENCE IN A SOUTHERLY DIRECTION, ONE HUNDRED EIGHTY-FOUR AND FOUR TENTHS (184.4) FEET TO AN IRON PIN; THENCE IN AN ZASTERLY DIRECTION, TWO HUNDRED TWO (202) FEET TO A STONE IN THE ROAD; THENCE IN A NORTHERLY' DIRECTION, TWO HUNDRED FIVE (205) FEET TO A STONE MARK AT THE PLACE OF BEGINNING. CONTAINING LESS THAN ONE (l) ACRE. PARCEL ID NO. 38-04-0367-008B PROPERTY ID NO. : 510 SAMPLE BRIDGE ROAD ENOLA (SILVER SPRING TWP), PA 17025 38-04-0367-008B BEING KNOWN AS: TITLE TO SAID PREMISES IS VESTED IN WILLIAM S. RHOADES AND BONNIE S. STACY BY DEED FROM WILLIAM S. RHOADES DATED 2/5/02 RECORDED 2/19/02 IN DEED BOOK 250 PAGE 2169. \..)J ~-l , ...J 'l~ ~~ -~~\ c--... ('i"I , ' ~ ., ~ ~~;; ~~, ~~ ~~ - - b G --.0-.1 ~ _uv,J<?\- u..J..... L""""'0"':"'1 c><..J'>,-:S\~ ' '0- ~ " ~~~c;O -i~ -. ~ ~ ~ cg.. .-' ~ .-;~-n ....\."1 0"\~,\ ~ ~(\\....- -;;, ~~--:~-'~!'~) .'). '~\-\ :?' .; --,,:~~/\ ....;',. '-'.::\ ~ '"l;....) o .~ ~ WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-3614 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, N A, AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2002-A ASSET-BACKED CERTIFICATES SERIES 2002-A Plaintiff (s) From WILLIAM S RHOADES AND BONNIE S. STACY, 510 SAMPLE BRIDGE ROAD, ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 510 SAMPLE BRIDGE ROAD, ENOLA P A 17025 (SEE LEGAL DESCRIIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,332.58 L.L. Interest FROM 8/23/05 TO 9/6/06 @ $40.95 PER DIEM - $15,561.00 Atty's Comm % Due Prothy $1.00 Arty Paid $377.21 Other Costs Plaintiff Paid Date: APRIL 18,2006 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name MARK J UDREN, ESQ. Address: WOODCREST CORPORATE CENTER 111 WOODCREST RD., STE 200, CHERRY HILL NJ 08003-3620 Attorney for: PLAINTIFF Telephone: (856) 669-5400 Supreme Court ID No. 04302 OF18 (Official Fonn 18)(10105) il65- 3~/f ~ United States Bankruptcy Court Middle District of Pennsylvania Case No. 1:05-bk-06363-MDF Chapter 7 In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden. and trade): Bonnie Sue Stacy 125 Market St 1st Fl West Fairview, PA 17025 Last 4 digits of Social Security No(s).: xxx-xx-8544 Employer's Tax LD. No.: DISCHARGE OF DEBTOR It appearing that the debtor is entitled to a discharge, IT IS ORDERED: The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). BY TIlE COURT Dated: 1/23106 -ry~AJ6t~ United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. "'"\J\)' r;"'j' '--1',- o c: :;:" ,..0 = (;::::J CC' .". --0 :;;0 -" Q, .... J:-r't rnE: -n" -);': co -r:; '1?' ;e: ~ ~" r;~ c? 1'.0 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2005-03614 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. ark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF o ~ c -'\.16-' rT:r" ,....., "" (::;::--.) <f' ~ ?" ";7' <:.i'] - CO r: ~ . _ 'c .- 1, _ _ _ y"'~,~ ~ ." -- 9r, ::;l ,...,., f\\r::, -nU.: :,;~~ ~~c" -c. > >~;::./ ",~_ \ I , ~ o N ~D ::< , - UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A, 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: 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 1. Name and address of Owner(s) or reputed Owner(s) : Name Address William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address David B. Killian, DMD 305 S Hanover St, Carlisle PA 17013 , "- 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PHFA 211 North Front Street P.O. Box 15628, Harrisburg, PA 17101 5. Name and address on the property: Name of every other person who has any record lien Address none 6 . Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17103 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 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 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 sworn falsification to authorities. ark J. Udren, Q. Attorney for Plaintiff DATED: April 12, 2006 .......,,;\ dJ~. ;;J ~~ o <;; ~ r;':? c~';~ 0"' "0 -;::;.:J .- d> ..." -'~ - ,~';' (~ ):;. C-- -T ";:ecI -<. o -n 9...,., f"ne -7:)\::,::: I:.:~ r' ", "':"-;; 1';'" o (.., .. I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. william S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, 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 tees. 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. r ) 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 ~,=- C.. -'/ :::) ~ ~.~ c~) ~? d" ":'l~'" ~) :;:0 -- cP -0 ---". ..-" Q, ':? --n 0"1-;::- \4:~ ~'(1 \--;. :n'i~ :..\(,t -:'C..,..;c ~'.~~ "f}'" "22 r:-? o v.' , I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff , ~COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, 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 Sheriffls Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. TO find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. I , 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 o ~ '''''J(:'~ '!'i.""':~ \"~'i f,>,.: (:.:~ ..-:, ~ if' ~ iP - cP .:"', S.S~; ~ --'- ~ q, ~-:P r\"'e;~\ '5\\:::; ..j,<::), '.', ~..(). -::;-" '\-';;) ",'rn \.2i ~ '.4 r9 o v:> UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". This Affidavit is made subject to relating to unsworn falsification Dated: September 1, 2006 forth by Pa Rule C.P. All Notices were served within the ti 3129. . Section 4904 BY: Mark J. Udren, Esqu1re 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 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2005-03614 v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) DATE: April 1~, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S}: William S. Rhoades Bonnie S. Stacy PROPERTY: 510 Sample Bridge Road Enola (Silver Spring Twp), PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 6, 2006, at 10: 00 am, at the. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A .~. _. ..l .~J. .- It z I. I ;Cd u.!: . '"- :I I' .~ clt i 1.i.i5 r6~~ l8 , \~j! ~.~ 'S::. ~..>w If' iLl' . '"1 ";..' ;>.'\!.. c-" ',' _.... ,'-i. "'- ":'.. ,'~. ~.. .... ~;...; : "'ID '.-. ~.~ ...... ... ;;;; .~ I'~ I i . I! . .1 "-!I!: -= ".Go /;'< t[r~rl .. ...; I; l ...~~~ :a I ,. ;h f";Jt~. ......,..-4 ....;h'.r 'F'; .,> .... .. .: k i 1" 1+.. - . f.' '., ~ I " f' 'tJi "'c' ....... .'. ..I,d, ..,. . ; .' ~. !ts I .... II: .~.; _. J .DCII31d !i; I ,(" -.' z'l_j 1& ,. 0: ,\Qf 'E ! I~ i_', ... l ..... f. ci'J:! 11;'< .. C ii :/,. is ';' ~10:. ~ '. :I. , - '0';: ,.;( . .~ ,a u- ,:D; Q:~ 'ID "' ! ,'" " i ~;'lC ,:.,...... .. ota: tL. It '(i' ~ " 1 ... i 1\ J II .. . it" ~'i; lIIri ~l\cl ,:i> " u,- ~; J I' li 01; .... Ii ) !UJ; .,. , :f!. i: i . ;z: .- IL, % :;. '.0 ..... 0 .;( i::'- ...- ..... ~- & " .. ~ I ; - iii it... ... :I. Ie I. I 01\ I .~ i3'.~ il ~ ,I,ll - ~ a l~ 11'1 '. II I' 0 c 0 ... 'CIII m ... an ::J .. N co .... U) CD ..... CD . .- .. .. .- ..... ..... ~::J EXHIBIT A I l' "Go' i ..... ~ ~ ;! & s LL UJ J:l.. FRct1 : DR DAVID B KILLIAN ~~r-u~&,uU~ \~~ U~~\\ ~~ , . . FAX NO. :7~7-24~-0172 Sept 06 2006 09:29AM. Pi F~ NO. P, 02 'trDa.- L&Jt' OPJ'lCBS S!'; Kart 3 D ' P .c. .l'-"1"r . h.., -qu.1~e . I.D. ao. 043D2 ~ OOUOBW CBift..aR CUb ~ AOAIl, stJln 200 '1'-6:'~O .'" 0'003-3.630 Wel~. F&%'9o ~ Minneaota Nat~onal Aasoc1ation as ' Tna-e.e :eor OptiOtl. ~ Mortgage LaIUl Trust 3002-A As.e~-Backed C~tificatGc S.r!e. .2002-A I AftOan 1PO~ PL.Uw.rIPI' ~ ; COt1!t'!" OJ' COMlCON ~LE.As . CXVtL DIVtSION : CUmbe.la..~d CQUAty . : HO.4005"O~614 Plaintiff v. Willi_ S. Ilho.des Bonnie S. Staoy . . netenc1ant(8) NO'nCB OF SHDJi'i" S SALi AND WAlVD OJ' MO'1'Xa 'X'O: David a. Xillian DDS 305 S. BaDov.~ St..at Carli.l., PI. l'Ol~ 1 hereby aeeept. se"i~. of the Jrotioe of Sb.riff r. S.J.. relating to the ilbove aapti023.d tMtt.r for aru! on bebalf of David ~. Killien 00., an4 hereby waive the ~h1:ty (30) d~y notice provision of PeDDaylvania ~ule of eivil Proce~e 312P.l ee seq. in ooanection w1tl1. the Sheriff r. Sale of 510 SiIlIIple Brid.ge Road, BnOla (Silve. Spring Twp), FA 170~5 (the prope:rty) on september 6, 2006. DATa'. By,~~:r~ Acoepted for and an behalf of Da.v:id a. X:i.l1iu t):DS '" " . '".,-, . . ',,' '.i :... . .... EXHtBtT B . "t,-, . ,'.' . e _ . Wells Fargo Bank Minnesota, NA VS William S. Rhoades and Bonnie S. Stacy In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-3614 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2006 at 7:58 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: William S. Rhoades and Bonnie S. Stacy, by making known unto Bonnie S. Stacy, personally, at 125 Market Street, 1st Floor, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2006 at 2:12 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 William S. Rhoades and Bonnie S. Stacy located at 510 Sample Bridge Road, Enola, Pennsylvania 17025 according -to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: William S. Rhoads and Bonnie S. Stacy, by regular mail to their last known address of 125 Market Street, 1st Floor, Enola, Pennsylvania 17025. These letters were mailed under the date of June 26, 2006 and never returned to the Sheriff's Office. So Answers: ~~~~ R. Thomas Kline, Sheriff BY Jo~Jnii1i Real Estate S rgeant EXHIBIT a - .. '- -- J-.... - '. (') s; ~~; ~ = = <f' (/) r'i V I CO :s (-!;) o -n -~ x-n me:: -rJill -~10 ~;;..S J, "-1~-:) ~JS ;~ ~2. ==1'\ , .,' ~'::;I '!> ~.o ~ w . . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Option One Mtg Loan Trust 2002-A tr is the grantee the same having been sold to said grantee on the 6th day of Sept AD., 2006, under and by virtue of a writ Execution issued on the 18th day of April, AD., 2006, out ofthe Court of Common Pleas of said County as of Civil Term, 2005 Number 3614, at the suit of Option One Mtg Loan Trust 2002-A Tr against William S Rhoads & Bonnie S Stacy is duly recorded in Deed Book No. 276, Page 4433. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c5ZCf day of -~ , AD. J-f) () b ~f3'~/~ . oIDeedI.Cumbertend~.CIIIIII. ~ Recorder of Deeds MyConviJlalo,. __ tie Filtliloldarol.... 2010 Wells Fargo Bank Minnesota, NA VS William S. Rhoades and Bonnie S. Stacy In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-3614 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2006 at 7:58 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: William S. Rhoades and Bonnie S. Stacy, by making known unto Bonnie S. Stacy, personally, at 125 Market Street, 1st Floor, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on June 28,2006 at 2:12 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 William S. Rhoades and Bonnie S. Stacy located at 510 Sample Bridge Road, Enola, Pennsylvania 17025 according -to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: William S. Rhoads and Bonnie S. Stacy, by regular mail to their last known address of 125 Market Street, 1st Floor, Enola, Pennsylvania 17025. These letters were mailed under the date of June 26, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 6, 2006 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Mark Ddren for Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan Trust 2002-A, asset Backed Certificates, Series 2002-A. It being the highest bid and best price received for the same, Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan Trust 2002-A, asset Backed Certificates, Series 2002-A. of P.O. Box 57038, Irvine, CA 92619, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $730.90. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed $30.00 14.33 15.00 15.00 30.00 . r , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) NO. 2005-03614 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A, 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: 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 1. Name and address of Owner(s) or reputed Owner(s) : Name Address William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address David B. Killian, DMD 305 S Hanover St, Carlisle PA 17013 , I * 4. ~ame and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PHFA 211 North Front Street P.O. Box 15628, Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17103 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17103 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 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 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: April 12, 2006 ark J. Udren, Q. Attorney for Plaintiff ~EN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enol~, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: William S. Rhoades 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, 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. IP YOU DO NOT HAVE A LAWYER OR CANNOT APPORD ONE, GO TO OR TELEPHONE THE OPPICE LISTED BELOW TO PIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REPERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank Minnesota, National Association, as Trustee for Option One Mortgage Loan Trust 2002-A Asset-Backed Certificates, Series 2002-A P.O. Box 57038 Irvine, CA 92619-7038 Plaintiff v. William S. Rhoades Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2005-03614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Bonnie S. Stacy 510 Sample Bridge Road Enola, PA 17025 Your house (real estate) at 510 Sample Bridge Road, Enola (Silver Spring Twp), PA 17025 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $184,332.58, 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 canceled 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. , . . . f 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 TAICE 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 ALL THAT'CERTAINTRACT OF LAND SITUATE INTRE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE NORTHEAST CORNER AT A STONE MARK; THENCE RUNNING IN A WESTERLY DIRECTION, ONE HUNDRED EIGHTY-EIGHT (188) FEET TO AN IRON PIN; THENCE IN A SOUTHERLY DIRECTION, ONE HUNDRED EIGHTY-FOUR AND FOUR TENTHS (184.4) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION, TWO HUNDRED TWO (202) FEET TO A STONE IN THE ROAD; THENCE IN A NORTHERLY DIRECTION, TWO HUNDRED FIVE (205) FEET TO A STONE MARK AT THE PLACE OF BEGINNING. CONTAINING LESS THAN ONE (1) ACRE. PARCEL ID NO. 38-04-0367-008B BEING KNOWN AS: 510 SAMPLE BRIDGE ROAD ENOLA (SILVER SPRING TWP), PA 17025 38-04-0367-008B PROPERTY ID NO. : TITLE TO SAID PREMISES IS VESTED IN WILLIAM S. RHOADES AND BONNIE S. STACY BY DEED FROM WILLIAM S. RHOADES DATED 2/5/02 RECORDED 2/19/02 IN DEED BOOK 250 PAGE 2169. WRIT OF EXECUTION and/or ATTACHMENT COMMONwEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3614 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, N A, AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2002-A ASSET-BACKED CERTIFICATES SERIES 2002-A Plaintiff (s) From WILLIAM S RHOADES AND BONNIE S. STACY, 510 SAMPLE BRIDGE ROAD, ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 510 SAMPLE BRIDGE ROAD, ENOLA PA 17025 (SEE LEGAL DESCRIIPTION) . (2) You are also directed to attach the property of the defendant( s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,332.58 L.L. Interest FROM 8/23/05 TO 9/6/06 @ $40.95 PER DIEM - $15,561.00 Arty's Cornm % Due Prothy $1.00 Arty Paid $377.21 Other Costs Plaintiff Paid Date: APRIL 18, 2006 4 CURTIS R. LONG (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name MARK J UDREN, ESQ. Address: WOODCREST CORPORATE CENTER 111 WOODCREST RD., STE 200, CHERRY HILL NJ 08003-3620 Attorney for: PLAINTIFF Telephone: (856) 669-5400 Supreme Court ID No. 04302 Real Estate Sale # 39 On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, P A Known and numbered as 510 Sample Bridge Road, filed with this writ and by this reference incorporated herein. o \\ \\ ~ Enola, more fully described on Exhibit "A" Date: May 22, 2006 By: R~~e~itL, I Z; :b '\j S - AVH qOOZ "id 4)\li';,;~no:) UI;~ i j(J~"t]r ~J .:L:.mElHS 3Hl JO TJIJJO PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA SSe 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 21, July 28, and August 4, 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. SWO 4 o AND SUBSCRIBED before me this day of August. 2006 NOTARIAL SEAL LOIS E. SNYDER. Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2009 IlBAL BSTATB SAL& NO. 39 Writ No. 2005-3614 CMl Wells Fargo Bank Minnesota, NA vs. William S. Rhoades and Bonnie S. Stacy Atty.: Mark Udren ALL mAT CERTAIN tract of land situate in the Township of Silver Spring. County of Cumberland and State of Pennsylvania. bounded and described as follows. to wit: BEGINNING at the northeast cor- ner at a stone mark; thence run- ning in a westerly direction. one hundred eighty-eight (ISS) feet to an iron pin; thence in a southerly direction, one hundred eighty-four and four tenths (184.4) feet to an iron pin; thence in an easterly di- rection, two hundred two (202) feet to a stone in the road; thence in a northerly direction. two hundred five (205) feet to a stone mark at the place of beginning. CONTAINING less than one (1) acre. PARCEL 10 NO. 38-04-0367- OOSB. BEING KNOWN AS: 510 Sample Bridge Road. Enola (Silver Spring Twp), PA 17025. PROPER1Y ill NO.: 3S-04-0367- OOSB. TITLE TO SAID PREMISES IS VESTED IN William S. Rhoades and Bonnie S. Stacy by deed from Will- iam S. Rhoades dated 2/5/02 re- corded 2/19/02 in Deed Book 250 page 2169. . . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; 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 19th and 26th day(s) of July and the 2nd day(s) of August 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 S ALE #39 I / CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 .. ,1. ~ ~...I ". ..t l' ..