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Home My WebLink About06-0091 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff Jl.TTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) NO. )fX)(.p -" 9! C"Vi l COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed wi thout 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 ABOU'l' HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AV1SO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. 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 1MMED1ATAMENT:E, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONIIE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty A venue 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 of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES,P.C. Isl Mark J. Udren, Esquire, Woodcrest Corporate Center 111 Woodcrest Road, Suih~ 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation desi9nated as such in the caption on a precedin9 page, If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A 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: 3 Wayne Circle MUNICIPALITY/TOWNSHIP/BOROUGH: Lower COUNTY: Cumberland DATE EXECUTED: 03/12/04 DATE RECORDED: 04/13/04 BOOK: 1860 Allen Township PAGE: 3171 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6, The following amounts are due on the said Mortgage as of 12/8/05: Principal of debt due Unpaid Interest at 6.25% from 7/22/05 to 12/8/05 (the per diem interest accruing on this debt is $18.71 and that sum should be added each day after 12/8/05) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Late Charges (monthly late charge of $34,17 should be added in accordance with the terms of the note each month after 12/8/05) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $109,247.48 2,574.58 325.00 280,00 136.68 5.462.37 $118,026.11 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 $118,026.11 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \ ~(\~ \ ,-)' jlV Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 " . i ALL THAT CERTAIN TRACT OR PARCEL OF LAND WITH THE IMPROVEMENTS SITUA1rE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY AND PLAN THEREOF, DATED AUGUST 28, 1968, PREPARED BY ROY M.N. BENJAMIN, PROFESSIONAL ENGINEER, AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERLY LINE OF WAYNE CIRCLE, WHICH POINT IS ONE HUNDRED SIXTY-TWO AND FOllR HUNDREDTHS (162.04) FEET EAST OF THE NORTHEASTERLY CORNER OF WAYNE ROAD AND WAYNE CIRCLE; THENCE NORTH FORTY-THREE (43) DEGREES NINETEEN (19) MINUTES THIRTY (3D) SECONDS WEST ONE HUNORED THIRTY-EIGHT ANO FORTY-oNE HUNDREDTHS (138.41) FEET TO A POINT; THENCE NORTH ONE (I) DEGREE THIRTY-SEVEN (31) MINUTES THIRTY (3D) SECONDS EAST TWENTY-FOUR AND NINETY-TWO HUNOREDTHS (24.92) FEET TO A POINT; THENCE NORTH SEVENTY-oNE (71) DEGREES FIFTY-THREE (53) MINUTES THIRTY (3D) SECONDS EAST EIGHTY-FOUR AND NINETEEN HUNDREDTHS (94.19) FEET TO A POINT: THE"CE SOUTH FIFTEEN (15) DEGREES THIRTY-SIX (38) MINUTES THIRTY (3D) SECONDS EAST ONE HUNDRED NINETEEN AND SIXTY-SIX HUNDREDTHS (I I 9.66) FEET TO A POINT ON TIlE NORTHERLY WNE OF WAYNE CIRCLE AFORESAID: THENCE ALONG THE SAME IN ANI ABC HAVING A RADIUS OF FORTY-FIVE (46) FEET IN A SOUtHERLY DIRECTION SIXTEEN ,~ND SEVENTy-oNE HUNDREDtHS (16,71) FEET TO A POINT; tHENCE FURTHER ALONG SAME IN AN ARC HAVING A RADIUS OF NINETY-ONE ANO FIFTY-oNE HUNDREDTHS (91.51) FEET IN A SOUTHWESTERLY DIRECTION TWENTY-tHREE AND TWENTY-NINE HUNDREDTHS (:13.29) FEET TO A POINT, tHE PLACE OF BEGINNING. THE IMPROVEMENTS THEREON BEING KNOWN AS 3 WAYNE CIRCLE. CAMP HILL, PENNSYLVAIIIA 17011. BEING THE SAME LOT OF GROUIID DESCRIBED III A DEED DATED 511111999 AND RECORDED AMOIIG THE LAIID RECORDS OF CUMBERLAND COUNTY, PENNSYLVANII\ IN UBER 199 AND FOLIO 915, WAS GRANTED AIID CONVEYED BY AIID BETWEEII AUDR,EY J. BRANNOII UNTO COLLEEN ELIZABETH BRANNOII. ,~ , . ,~ 10/26/05 AUDREY BRANNON COLLEEN ELIZABETH BRANNON 130 S 3RD ST APT 1107 HARRISBURG PA 17101-2615 COMBINED ACT 91/ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (IHEMAP) may be able to help save your home. This Notice explains how the program works. To see ifHEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency, The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397. Persons with impaired hearing may call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find an attorney. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE AL LLAMAR A ESTA AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEO'WNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. !EXHIHII . HOMEOWNER'S NAME(S): AUDREY BRANNON, COLLEEN ELIZABETII BRANNON PROPERTY ADDRESS: 3 WAYNE CIRCLE CAMPlDLL PA1701l ACCOUNT NUMBER: 0008530685 CURRENT LENDERlSERVICER: HSBC Mortgage Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VB YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU BA VE A REASONABLE PROSPECT OF iBEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the CODSlllDCf credit counseling agencies listed al the end of this Notice. TIllS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TIllS NOTICE CALLED ''HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telenhone numbers of desil!1lllted consumer credit counseling agencies for the county in which the DroDertv is located are set forth at the end of this Notice:. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default), If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program, To do so, you must fill out, siign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit coWlSeling agencies listed at the end of this Noti<:e. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAlL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORm IN TIllS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency m0l1gage 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 Permsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, mE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If ou have filed bankru tc e Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (bring It up to date) NATURE OF mE DEFAULT The MORTGAGE debt held by the above lender on your property located at 3 WAYNE CIRCLE CAMP HILL PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS. You are due and owing approximately $683.44 a month. You are past due since 08/22/05, Other fees may have also accrued on your account. TOTAL AMOUNT PAST DUE:$ 2118.66 HOW TO CURE THE DEFAULT - You may cure this defauh within TIllRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS S 2118.66. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents must be made either by cash. cashier's check.. certified ch<eck or monev order made Davable and sent to: HSBC Mortgage Services P. O. Box 17580 Baltimore, MD 21297 IF YOU DO NOT CURE THE DEFAULT - If you do not cure thl: default within THIRTY (30) DAYS of the date of this Notice. the lender Intends to exercise its ril!bts to accelerate the mortl!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose UDon Your mortl!al!ed nroDertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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, whic:h may also include other reasonable costs. If vou cure the default witbin the THIRTY (30) DAY perIod. vou will not be reouired to naY attorney's fees. OTIiER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE~ - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the riJlht to cure the default and prevent the sale at any time un to one hour before the Sheriffs Sale. You may do so bv oavinl! the total amount then oast due. Dlus any late or other charl!CS then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as soecified in writing bv the lender and bv Derforming anv other reauirements under the mortgage. Curing your defanlt In the manner set forth in this notice will restore your mortgage to the same position as if you bad never defaulted. EARLIEST POSSIBLE SHERIFF'S SALF DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately fiye months from the date oftbis Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure thc: default will increase the longer you wait. You may find out at any time exactly what the recluired payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: HSBC Mortgage Services Address: 636 Grand Regency Blvd., Brandon, F'L 33510 Phone Number: 800-365-6730 Fax Number: 813-571-8680 Contact Infonnation: Loss Mitigation Department EFFECT OF SHERIFF'S SALE You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor -1L may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFFTIDS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO OA VE 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 DEI1AULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCmS SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice that you dispute the validity of this debt or any portion thereGf, tbis office wlll assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail yon a copy of such judgment or verificatiolll. You are lIlso advised that any information which you supply to this office may be used by ns in the coUec:tion of the debt. If you request this office in writing within thirty (30) days after receiving this notice, this office will provide you with the name and address of the original creditor. A1thougb we have reqnested that you make payment or pro'vide a valid reason for nonpayment. you still have the right to make a written request. within thirty days of yonr receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. THE PURPOSE OF THIS COMMUNICATION IS TO COl,LECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. Enclosure: Validation of Debt Notice 6,17 Certified Mail Val.idation of Debt Notice Pursuant to the I'air Debt Col.l.ection Practice Act (Jl'DCPA) (15 USC 1692), a consumer debtor is required to be sent the fo1.1.owing notice: (1) unl.ess the consumer, within thirty (30) days after receipt of this notice, disputes the vaJ.idity of the debt or any portion thereof, the debt wi1.1. be assUlll8d to be va1.id Joy the debt col.l.ector; (2) if the consumer notifi.es the debt col.lector i.n wxiting within the thirty (30) day period that the debt or any portion thereof is disputed, the ciebt co1.1ector wil1. obtain verifi.cation of the debt or a copy of a Judgment against the consume:.: and copy of such verification or Judgment wi1.1 be mai1.ed to the consumer by the debt col.1ector; and (3) upon the consumer's written request wi. thi.n the thirty (30) day period, the debt c011ector wi1lL provide the conSUlll8r with the nama and address of the original. creditor, if different from the current creditor. Our ~d for :imlllediate payment does not eliminate your right to dispute this debt wi thin thirty (30) daytl of receipt of this notice. :tf you choose to do so, we are xequirlld by 1.aw to cease our col.l.ection efforts until _ have mai1ed the di.sputed information to you, AJ.though we have requested that. you makll payment. or provide a valid reason for nonpayment, you stil.l. have the right to make a written reque.t., within thirty (30) days of your receipt of this notice, for IIlOre infoxmation about the debt,_ Your rights are described further, hereinafter_ THIS NOTICE AND UTTER AlUr. AN M'rZHl'T ro COLLECT A DUT AND ANY INFOlINJl.T:ION OBTA:INJ!:D WILL Bl!: I1SED FOR THAT PUlU'OSE _ The Feelera1. orrade C~i ssion has ru1.ed that the FDCPA eIl,.._ not precl.ucla t.he institution of 1.eqa1. action prior to the expi,ration of the thirty (30) day period. Acceptance of funds and reinstat...nt of the IIIOrtgaqe are both subject to verification by HSBC Mortqaqe Services _ P1.ease note that BSBe Mortgage Services may proceed with foreclosure and that fee_. costs and/or advances by the IIIOrtqaqee may be dDe in addition to the sum quoted above. Please note further that any funds tencl.ez:ed wi1.1. be subject to verification and correctness before the matter is conc1.uded. Please feel free to contact BSBC Mortgage Services '>pon receipt of this notice should you have any questions or concerns. Oate: 10/26/05 HSBC Mortgage Services 636 Grand Regency Blvd. Brandon, FL 33510 800-365-6730 www.hsbcmortgageservices.com 10/26/05 AUDREY BRANNON COLLEEN ELIZABETH BRANNON 3 WAYNE CIRCLE CAMP IDLL PA 17011 COMBINED ACT 91/ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. ' The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see ifHEMAP can help, you must MEET wrm A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIDS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseli~Lg Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397. Persons with impaired hearing may call (717) 780-1869. This Notice contains important legal infonnation. 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 an attorney. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE AL LLAMAR A ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): AUDREY BRANNON, COLLEEN ELIZABETII BRANNON PROPERTY ADDRESS: 3 WAYNE CIRCLE CAMP HILL PA 17011 ACCOUNT NUMBER: 0008530685 CURRENT LENDER/SERVICER: HSBC Mortgage Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE EUGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUfURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF TIlE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) da,ys from the date of this Notice. During that time you must arrange and attend a face-to-face' meeting with one of the consumer credit counscling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WfI1IIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. mE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If Y'~U 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 meetin!l. Thc names, addresses and tclenhone numbers of designated consumer credit counselinlZ agencies for the county in which the nronertv is located are set forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation 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 tile designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TIIE OTIIER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENJED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited, They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proI:eedings 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 PEmION IN BANKRUPTCY. THE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. If au have filed bankru te HOW TO CURE YOUR MORTGAGE DEFAULT (bring it np to date) NATURE OF TIIE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 3 WAYNE CIRCLE CAMP HILL PAl 70 II IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS. You are due ~LDd owing approximately $683.44 a month. You are past due since 08/22/05. Other fees may have also accrued on your account. TOTAL AMOUNT PAST DUE:$ 2118.66 HOW TO CURE TIIE DEFAULT - You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2118.66. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or money order made pavable and sent to: HSBC Mortgage Services P. O. Box 17580 Baltimore, MD 21297 IF YOU DO NOT CURE THE DEF AUL T - If you do not cure the, default within THIRTY (30) DAYS of the date of this Notice, the lender iDtends to exercise its "Ihts to accelerate the mol1l!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed Dropertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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, eyen 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 vou cure the default within the TmRTY (30) DAY period. vou will Dot be reoulred to Dav attornev's fees. OTHER T ENDER REMEDIES - The lender may also sue you pl:rsonally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time un to one hour before the Sheriff's Sale, You mav do so bv paving the total amount then past due, DIllS anv late or other chaNes then due, reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as soecified in writing by the lender and by performing anY other requirements under the mortgalZe. Curing your default in the manner set forth in this notice will restore your mortgage to the sameAposition as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date ofthe Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: HSBC Mortgage Services Address: 636 Grand Regency Blvd., Brandon, FL 335 I 0 Phone Number: 800-365-6730 Fax Number: 813-571-8680 Contact Information: Loss Mitigation Department EFFECT OF SHERIFFS SALE - You should realize that a She:riff's 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. ASSUMPTION OF MORTGAGE - You _ mayor -1L may Dot sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are plud prior to or at the sale and that the other requirements ofthe mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD 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 I>EFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED :LIST. NOTE: Unless you notify this office wlthiD thirty (30) days after receiving this notice that you dispute the validity of this debt or any portion thereof, thia office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain vertrlCation of the debt or obtain a copy of judgment and mall you a copy of snch judgment or verification. You are also advised that any information which yon snpply to this office may be used by us in the collection of the deht. If you request this office in writing within thirty (.30) days after receiving this notice, this office will provide you with the name and :Iddress of the origlnal creditor. Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the right to Dlllke a written request, within thirty days of your receipt of this notice, for more information about the debt. Your righlll are described fnrther, hereinafter. THE PURPOSE OF TIllS COMMUNICATION IS TO COLLECf A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIDS PURPOSE. Enclosure: Validation of Debt Notice 6.10 V&lidatio~ of Debt Notice Pursuant to the Fair Debt Collection Practi,ce Act (FDCPA) (15 USC 1692), a consumer debtor is required to be sent the following notice: (1) unless the consumer, within thirty (30) clays after receipt of this notice, disputes the validity of the debt or any portion thereof, the debt w:i.ll be assumed to be val:i.d by the debt collector; (2) if the consumer ~otifies the debt collector in writi~g within the thirty (30) day period that the debt or an:t" portion thereof is disputed, the debt collector will obtain verific::ation of the debt or a copy of a JUd9m-nt against the consumer and copy of such verification or Judgment will be mail.d to the consumer by the debt collector; and (3) upon the conllUlll8r's written request within the thirty (30) day period, the debt collector will. provide the consumer with the name and addr.ss of the original credi1:or, if different from th. current credi. tor. Our Aam.nd for :i.lmaedi.ate payment does not eliminate your right to dispute this debt within thirty (30) days, of receipt of this notice. :tf you choose to do so, ... are required by law to aease our collection efforts until we have mailed the disputed information to you. Al.though .. have requested that you malte payment or provide a valid reason for nonpayment, you still have the right to make a written request, within thirty (30) days of your receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. TBIS NOTICE AND UT'rEll AIlE AN A'rTEMP'l' TO COLLECT A DEBT AND ANY :INIl'ORMATION OBTA:tNBD WILL BE USED FOR THAT PURPOSE. The Federal Trade COIIUIIission has ruled that the FDCPA de.es not preclude the insti tution of legal action prior to the expiration of the thirty (30) day period. Acceptance of funds and reinstat_nt of the mortgage are both subject to verification by BSBC Mortgage Servic<~s. please note that HSBe Mortgage Services may proceed with foreclosure and that faes, costs and/or advances by the mortgagee may be d'~e in addition to the SUlll quoted above. Please note further that any funda tendered will be subject to verification and correctness before the matter Jls concluded. Please feel free to contact HOC Mortgage Services "pon receipt of this notice should you have any questions or concerns. Date: 10/26/05 HSBC Mortgage Services 636 Grand Regency Blvd. Brandon, FL 33510 800-365-6730 www.hsbcmortgage::l.ervices.com V E R I F I CAT I 0 ~ Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff, a corporation unless desiunated 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 subj ect to the penal ties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorities. \)~U Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C, ~l0 ~ ~ ~ \l....) \J\. ':1 ~ ~\ \\i 4-...) ~ -,..!. ~ ~. ~ 8 r) "..) , ''::;;;) .':-:~ lJ c. -n =;i ~;~ i':\}~, C'1 _..i .-} l~,;} C..., (::; :t:-S nJ SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00091 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BRANNON COLLEEN ELIZABETH ET A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BRANNON COLLEEN ELIZABETH but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , BRANNON COLLEEN ELIZABETH 3 WAYNE CIRCLE CAMP HILL, PA 17011 3 WAYNE CIRCLE IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 13.20 5.00 10.00 .00 46.20 UDREN LAW OFFICES 01/23/2006 Sworn and subscribed to before me this,:y.)J) day of ,-r;rkorj f}OtJG A.,,~_ prJ2'f:~~7 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00091 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BRANNON COLLEEN ELIZABETH ET A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BRANNON AUDREY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , BRANNON AUDREY 3 WAYNE CIRCLE CAMP HILL, PA 17011 3 WAYNE CIRCLE IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10,00 .00 21.00 ~L~ R. omas Kline Sheriff of Cumberland County UDREN LAW OFFICE 01/23/2006 Sworn and subscribed to before me this g;JfJ. day of ,jO.,roL1tli)' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-00091 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BRANNON COLLEEN ELIZABETH ET A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BRANNON COLLEEN ELIZABETH but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On January 23rd , 2006 , this office was in receipt of the attached return from DAUPHIN :~,.:-<!' R. Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 6.00 9.00 10.00 35.25 3.95 64.20 01/23/2006 UDREN LAW OFFICE Sworn and subscribed to before me 30lJ day of :;:;"w'r'} this :;JtlDi.r A~ ~A ~ Pr nowy SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-00091 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BRANNON COLLEEN ELIZABETH ET A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BRANNON AUDREY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On January 23rd , 2006 this office was in receipt of the attached return from DAUPHIN ~/~--? Sheriff of Cumberland County Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 01/23/2006 UDREN LAW OFFICE Sworn and subscribed to before me this " ;) )0' , day of ~~JIl.(.\,r"" / fJ.m~ A.D. @ffb.':t of tltc ~4criff William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy MichaelVV.Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MORTGAGE ELECTRONIC REGISTRATION SYSTE vs County of Dauphin BRANNON AUDREY Sheriff's Return No.0032-T - -2006 OTHER COUNTY NO. 2006-91 AND NOW:January 17, 2006 at 2: 05PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon BRANNON AUDREY by personally handing to AUDREY BRANNON DEFT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 130 SOUTH 3RD ST, APT. 1107 HB, PA 17101-0000 Sworn and subscribed to So Answers, ?f~ before me this 18TH day of JANUARY, 2006 Sheriff of Dauphin County, Pa. ~~ '177.~ ~UrfLeL By NOTARIAL SEAL MARY JANE SNYDER. Notary Public Highspire, Dauphin County My Commission Expires Sept. 1,2006 Deputy Sheriff Sheriff's Costs:$35.25 PD 01/13/2006 RCPT NO 213748 ME In The Court of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systems Inc VS.. 1 Colleen Ellzabeth Brannon et a SERVE: Audrey Brannon 06-91 civil No. Now, Janua:i:y6, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~~..~ Sheriff of Cum berland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made lmown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERV1CE MILEAGE AFFIDAV1T $ $ In The Co'urt of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systemslnc VS. ' Colleen Elizabeth Brannon et al SERVE: Colleen Elizabeth Brannon 06-91 civil No. Now, Januatv6. 2006 , I, SHERIFF OF CUNffiERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~~<:~ Sheriff of Cum berland County, P A Affidavit of Service Now, within upon at by handing to a and made mown to Sworn and subscribed before me this _ day of ,20_ ,20-, at 0' clock M served the copy of the original the contents thereof. So answers, Sheriff of County, PA COSTS SERVICE ' , MILEAGE AFFIDAVIT $ $ @{{ire (If ilTc ~1rcriff William T, Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MORTGAGE ELECTRONIC REGISTRATION SYSTE vs County of Dauphin BRANNON AUDREY Sheriff's Return No, 0032-T - -2006 OTHER COUNTY NO. 2006-91 AND NOW:January 17, 2006 at 2: 05PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon BRANNON COLLEEN ELIZABETH by personally handing to AUDREY BRANNON MOTHER OF DEFT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 130 SOUTH 3RD ST, APT, 1107 HBG, PA 17101-0000 Sworn and subscribed to So Answers, Jf~ Sheriff of Dauphin County, Pa. 71~IL~eL before me this 18TH day of JANUARY, 2006 ~A/ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. I, 2006 Deputy Sheriff Sheriff's Costs: $35.25 PD 01/13/2006 RCPT NO 213748 ME ~ 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v, Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaint,iff and against the Defendant(s) Colleen Elizabeth Brannon and Audrey Brannon for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 12/9/05 to 2/21/06 Late charges per Complaint From 12/9/05 to 2/21/06 $118,026.11 1,403.25 102.51 TOTAL $119.531.87 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 attached hereto. UDREN LAW OFFICES, P.C. DAMAGES ARE HEREBY ASSESSED AS DATE :J-i' _I.- ..:2:3 ;) 66fr, I UDREN LAW OFFICES, P,C, BY: Mark J, Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, COURT OF COMMON PLEAS Inc, CIVIL DIVISION Plaintiff Cumberland County ATTORNEY FOR PLAINTIFF v. Colleen Elizabeth Brannon Audrey Brannon Defendant (s) NO, 2006-91 Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 DATE of Notice: February 9, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER 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 OFIC1NA, 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 BE USED FOR THAT PURPOSE, \~A)\) Mark J. Udren, Esqulre Woodcrest Corporate Center III 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 Mortgage Electronic Registration Systems, COURT OF COMMON PLEAS Inc. CIVIL DIVISION Plaintiff Cumberland County ATTORNEY FOR PLAINTIFF v, Colleen Elizabeth Brannon Audrey Brannon Defendant(s) NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 DATE of Notice: February 9, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQDIRIDA DE SD 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 DSTED EN CORTE 0 ESCDCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SD CONTRA, DSTED PUEDE PERDER BrENES 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 DlRECCION SE ENCDENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PDEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Associatio~ 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.~ USED FOR THAT PURPOSE, \'~1J Mark J~-Udren, Esqulre 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 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. NO. 2006-91 Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN 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: Colleen Elizabeth Brannon Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Audrey Brannon Over 18 As captioned above Unknown Sworn to and subscribed before me this 2pt day of ~ebrua~ 2006. 1'r!A,nhM, ,1\J\I~ctL Notary pul:ilic ,..smt N"_ If PWC<< w:JUM1WICt:6NIW _ C . ~- ....IIS.,.. Name: Title: Company: E ,ESQ, ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C, eN ~:\l ~ i ~ " IU l/1 ~~ () ~ 'i~ \> \~ ~r :E .4._ ----L... ( ~ "") ".(, -"-, 0"j c0 ~'>} (...j :-. ...~ ~ ~ -) '.1", c .r- :::1 C" ." "JV.J'1 ir?t~"';"" ,,~~~:$ ~. \\'~ tp:; '0;" ''1..r:& _\!(.&_L.." I~;' f bnREN 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt, 1107 Harrisburg, PA 17101 Defendant(s) TO: Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 ./ YDREN 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt, 1107 Harrisburg, PA 17101 Defendant(s) 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(sJ Colleen Elizabeth Brannon and Audrey Brannon for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mort9aged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 12/9/05 to 2/21/06 Late charges per Complaint From 12/9/05 to 2/21/06 TOTAL $118,026.11 1,403.25 102.51 $119,531.87 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 attached hereto. UDREN LAW OFFICES, P.C. ,'\ i\ /\ " \ / \ Mark J. Uapen, ~SQUJR.E At!9"'ney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY IIJ; - - 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ; COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon Audrey Brannon NO. 2006-91 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) TO: Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -K- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 ......, REN LAW OFFICES, P.C. ~: 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) 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) Colleen Elizabeth Brannon and Audrey Brannon for failure to file an Answer to Plaintiff's Complaint within 2C1 days from service thereof and for foreclosure and sale of the mort>;:Jaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 12/9/05 to 2/21/06 Late charges per Complaint From 12/9/Cl5 to 2/21/Cl6 SUB, Cl26.U 1,4C13.25 102.51 TOTAL $119,531. B7 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 attached hereto. UDREN LAW OFFICES, P.C. r /\.'\ , '\ " \;' \, Mark ,3. Udden, ~SQUJR,E At:!:9"'ney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $119,531.87 Interest From 2/22/06 1,983.26 to Date of Sale June 7, 2006 Ongoing Per Diem of $18,71 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C, \ ~ark J. A Y r0 C .- 0 l'i ~ ~ ~ "J tV -L ..t:. ""'v \,"" \"'~ l ~ ~. ':!- W l :4:: Ir) \) t () ;-~ ;- ~ v,-6"'?Jl:~ ~ Il..., --C 0 S- ..c. -:- II ~ ...0 . , " \)' '.t "' \) Vz \) b () 't B OC;()CC t I \ ~ I I I \ \ ~ 0>?=- - :: ~ ~ ::- -:: -- ~ I~ ... ~ ~ :::. ~ "-1-..:t.- I""-? C) ,'.:..'. ~ ' p-~ c~:; ;'<;' c.,) C'') ~i) ---.- (:~) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-91 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff(s) From COLLEEN ELIZABETH BRANNON AND AUDREY BRANNON (1 ) You are directed to levy upon the property of the defendant (s)and to sell SE,E LEGAL DESCRIPTION, (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof: (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $119,531.87 L.L. Interest FROM 2/22/06 TO DATE OF SALE 6/7/06 - ONGOING PER DIEM OF $18.71 - $1,983,26- TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Connn % Due Prothy $1.00 Other Costs Atty Paid $229.40 Plaintiff Paid Date: FEBRUARY 23, 2006 CURTIS R. LONG (Seal) Proth=.2;ry __By: ' 0-,. D P'~/,?~J'-/ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORA TE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No, 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt, 1107 Harrisburg, PA 17101 Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. , /\/\/\ ~. Udre\l, E~UI~ A ORNEY FOR PLAINTIFF c> ,. G~~: J ..j (..,) r ,.. :--:;!- ~' i' I I' 'l.. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v, Colleen Elizabeth Brannon NO. 2006-91 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., plaintiff in the above action, by its attorney, Mark J, Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 3 Wayne Circle (Lower Allen TownshiplCamp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 2. Name and address of Defendant(sl in the judgment: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a None ,t '- 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Citifinancial Services, Inc. 2146 White Street York, PA 17404 5. Name and address of every other person who has any record lien on the property: Name Address None 6, Name and address in the property and Name of every other person whose interest may be Address who has any record interest affected by the sale: Real Estate Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 21, 2006 1\ II E~'b laint~ :~~ -n :-;1 r'...~ c.) c G) , - 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) NO. 2006-91 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Your house (real estate) at 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $119,531.87, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s Sale~ you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorneyls 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 le9a1 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.) I _ 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 paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 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 ~ .'.'., ('.?\ --j f' ,:.Yj 1',': :;<) C;) c_:> 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 Mortgage Electronic Registration Systems, Inc, 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) NO. 2006-91 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Your house (real estate) at 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $119,531,87, 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 paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 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'. -~""; .-l ~\; '11 ." ::.;.. i'" ';'<1 C>,) c;:) UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland county 'NO.2006-91 v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) DATE: February 21, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Colleen Elizabeth Brannon and Audrey Brannon PROPERTY: 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 7, 2006, at 10:00 A.M., at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judqment 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. l~:" -';"i r'"J (,) CC i ALL THAT CERTAIN TRACT DR PARCEL OF LAND WITH THE IMPRDVEMENTS SITUATE IN LOWER ALLEN TOWNSHIP. CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SUt=:\VEY ANa PLAN THEREOF, DATED AUGUSi 2B, 196a, PREPARED BY ROV M.N, BENJAMIN, PROFESSIONAL ENGINEER AS FOLLOWS, BEGINNING AT A PDINT DN THE NDRTHERLY LINE DF WAYNE CIRCLE, WHICH POINT IS DNE HUNDRED SIXTY.TWD AND FOUR HUNDREDTHS (152.04) FEET EAST DF THE NORTHEASTERLY CORNER OF WAYNE ROAD AND WAYNE CIRCLE; THENCE NORTH FORTY-THREE (43) DEGREES NINETEEN (19) MINUTES THIRTY (3D) SECDNDS WEST ONE HUNDRED THIRTY.EIGHT AND FORTY-ONE HUNDREDTHS (138.41) FEET TO A POINT: THENCE NORTH ONE (1) DEGREE THIRTY-SEVEN (37) MINUTES THIRTY (30) SECONDS EAST TWENTY-FOUR AND NINETY-TWO HUNDREDTHS (24.92) FEET TO A POINT; THENCE NORTH SEVENTY-DNE (71) DEGREES FIFTY. THREE (53) MINUTES THIRTY (301 SECONDS EAST E1GHTY-FOUR AND NINETEEN HUNDREDTHS (94.19) FEET TO A POINT; THENCE SOUTH FIFTEEN 115) DEGREES THIRTY-SIX (36) MINUTES THIRTY (30) SECONDS EAST ONE HUNDRED NINETEEN AND SIXTY-SIX HUNDREDTHS (119.66) FEET TO A POINT ON THE NORTHERLY UNE OF WAYNE CIRCLE AFORESAID; THENCE ALONG THE SAME IN AN ARC HAVING A RADIUS OF FORTY-FIVE (45) FEET IN A SOUTHERLY DIRECTION SIXTEEN AND SEVENTY-DNE HUNDREDTHS (16.71) FEET TO A POINT; THENCE FURTHER ALONG SAME IN AN ARC HAVING A RADIUS OF NINETY-ONE AND FIFTY-oNE HUNDREDTHS 191.S1) FEET IN A SOUTHWESTERLY DIRECTION TWENTY-THREE AND TWENTY.NINE HUNDREDTHS (23.29) FEET TO A POINT, THE PLACE OF BEGINNING. THE IMPROVEMENTS THEREON BEING KNOWN AS 3 WAYNE CIRCLE, CAMP HILL. PENNSYLVANIA no". BEING THE SAME LOT OF GROUND DESCRIBED IN A DEED DATED 511111999 AND RECORDED AMONG THE LAND RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN L1BER 199 AND FOUO 915, WAS GRANTED AND CONVEYED BY AND BETWEEN AUDREY J. BRANNON UNTO COLLEEN ELIZABETH BRANNON. BEING KNOWN AS: 3 WAYNE CIRCLE (LOWER ALLEN TO~~SHIP) CAMP HILL, PA 17011 PROPERTY ID NO. : 13-24-0797-137 TITLE TO SAID PREMISES IS VESTED IN COLLEEN ELIZABETH BR?~ON AND AlmR~Y BRANNON BY DEED FROM COLLEEN ELIZABETH BRANNON DATED 3/1=:/04 RECORDED 4/13/04 IN DEED BOOK 262 PAGE 2295. Mortgage Electronic Registration Systems, Inc. VS Colleen Elizabeth Brannon and Audrey Brannon In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-91 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Colleen Elizabeth Brannon and Audrey Brannon, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice of Sheriffs Sale and Description according to law. Dauphin County Return: And Now, March 17,2006 at 12:00 pm served the within Real Estate Writ, Notice of Sheriffs Sale and Description in the above entitled action upon Colleen Elizabeth Brannon and Audrey Brannon, by making known unto Colleen Brannon personally, and adult daughter of Audrey Brannon, at 130 South 3rd Street, Apt. 1107, Harrisburg, PA 17101. So answers: Jack Lotwick, Sheriff of Dauphin County, Pennsylvania. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2006 at 4:33 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 Colleen Elizabeth Brannon and Audrey Brannon located at 130 South 3rd Street, Apt. 1107, Harrisburg, PA 17101, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Colleen Elizabeth Brannon and Audrey Brannon by regular mail to their last known address of 130 South 3rd Street, Apt. 1107, Harrisburg, P A 17101. These letters were mailed under the date of April 06, 2006 and never re.turned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriffs Costs: Docketing Poundage Advertising Levy Posting Handbills Out of County Dauphin County Prothonotary Mileage 30.00 20.17 15.00 15.00 15.00 9.00 35.25 1.00 11 .44 ~/~ R. Thomas Kline, Sheriff .~ B~jOC~~ Real Estat Sergeant Certified Mail Surcharge Law Journal Patriot News Share of Bills 1.83 30.00 497.00 328.40 19.57 $1,028.66 91K-- t,/d3J()& c/ Sworn and subscribed to before me This day of 2006, A.D. Pro~h.IiII1lI~eJlf3' 1.&0 Ck <;'1020 if ~. j1q5JJ ...,.. .1:" . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 NO. 2006-91 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 3 Wayne Circle (Lower Allen Township)Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 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 Addre~s Plaintiff herein. See Caption above. Citifinancial Services, Inc. 2146 White Street York, PA 17404 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 21, 2006 // Mark jY. Udre At~ney for o I :E d h Z 933 QOOl Vd 'AHHIOJ Uirvld3BWnJ J.::!IH3HS 3Hl .::10 3JI.::!,jO f~ 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) NO. 2006-91 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Colleen Elizabeth Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Your house (real estate) at 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $119,531.87, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ;~ , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not.stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 o I :f d h l 933 QOOl Vd 'AHmO~i uN'j'ltl3ClrJft3 d.:HU3HS 3Hl .10 331.1.10 ~ 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 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Colleen Elizabeth Brannon Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Defendant(s) NO. 2006-91 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Audrey Brannon 130 South 3rd Street Apt. 1107 Harrisburg, PA 17101 Your house (real estate) at 3 Wayne Circle (Lower Allen Township) Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $119,531.87, 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.) I YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the pr~ce bid by calling 856-669-5400. 2. You maybe 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 01 :[ d IlZ 93:1 qOOZ Vd 'AHU10:.! lmV'I~38WnJ .:l.:.HH3HS 3Hl jO 3~1:J:JO j AlL THAT CERTAIN TRACT OR PARCEL OF LAND WITH THE IMPROVEMENTS SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCOROANCE WITH A SURVEY AND PLAN THEREOF, DATED AUGUST 28, 1968, PREPARED BY ROY M.N, BENJAMIN, PROFESSIONAL ENGINEER, AS FOI,.LOWS: BEGINNING AT A POINT ON THE NORTHERLY UNE OF WAYNE CIRCLE, WHICH POINT IS ONE HUNDRED SIXTY-TWO AND FOUR HUNDREDTHS (162.04) FEET EAST OF THE NORTHEASTERLY CORNER OF WAYNE ROAD AND WAYNE CIRCLE; THENCE NORTH FORTY-THREE (43) DEGREES NINETEEN (19) MINUTES THIRTY (30) SECONDS WEST ONE HUNDRED THIRTY.EIGHT AND FORTY-DNE HUNDREDTHS (138.41) FEET TO A POINT; THENCE NORTH ONE (1) DEGREE THIRTY-SEVEN (37) MINUTES THIRTY (30) SECONDS EAST TWENTY-FOUR AND NINETY-TWO HUNDREDTHS (24.92) FEET TO A POINT; THENCE NORTH SEVENTY-QNE (71) DEGREES FIFTY.THREE (53) MINUTES THIRTY (30) SECONDS EAST EIGHTY-FOUR AND NINETEEN HUNDREDTHS (94.19) FEET TO A POINT; THENCE SOUTH FIFTEEN (15) DEGREES THIRTY-SIX (36) MINUTES THIRTY (30) SECONDS EAST ONE HUNDRED NINETEEN AND SIXTY-SIX HUNDREDTHS (119.66) FEET TO A POINT ON THE NORTHERLY UNE OF WAYNE CIRCLE AFORESAID; THENCE ALONG THE SAME IN AN ARC HAVING A RADIUS OF FORTY-FIVE (45) FEET IN A SOUTHERLY DIRECTION SIXTEEN AND SEVENTY-QNE HUNDREDTHS (16.71) FEET TO A POINT; THENCE FURTHER ALONG SAME IN AN ARC HAVING A RADIUS OF NINETY-ONE AND FIFTY-DNE HUNDREDTHS (91.51) FEET IN A SOUTHWESTERLY DIRECTION TWENTY-THREE AND TWENTY-NINE HUNDREDTHS (23.29) FEET TO A POINT, THE PLACE OF BEGINNING. THE IMPROVEMENTS THEREON BEING KNOWN AS 3 WAYNE CIRCLE, CAMP HILL, PENNSYLVANIA 17011. BEING THE SAME LOT OF GROUND DESCRIBED IN A DEED DATED 5111/1999 AND RECORDED AMONG THE LAND RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN LIBER 199 AND FOLIO 915, WAS GRANTED AND CONVEYED BY AND BETWEEN AUDREY J. BRANNON UNTO COLLEEN EUZABETH BRANNON. BE ING KNOWN AS: 3 WAYNE CIRCLE (LOWER ALLEN TOWNSHIP) CAMP HILL, PA 17011 13-24-0797-137 PROPERTY ID NO. : TITLE TO SAID PREMISES IS VESTED IN COLLEEN ELIZABETH BRANNON AND AUDREY BRANNON BY DEED FROM COLLEEN ELIZABETH BRANNON DATED 3/12/04 RECORDED 4/13/04 IN DEED BOOK 262 PAGE 2295. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-91 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From COLLEEN ELIZABETH BRANNON AND AUDREY BRANNON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the 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 $119,531.87 L.L. Interest FROM 2/22/06 TO DATE OF SALE 6/7/06 - ONGOING PER DIEM OF $18.71 - $1,983.26- TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $229.40 Plaintiff Paid Date: FEBRUARY 23, 2006 (Seal) CURTIS R. LONG pmiliZ Q ~ <.Jy: ~ . ~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 61 On March 02, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 3 Wayne Circle, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 02,2006 By: ~ocL..( Svvufh Real Estate Sergeant ~@.~ ~~~\~~ bO :f. d \1l 93:\ ~fiU1. .. . ,.'" '.. \,iJ 8\4 n J \Jd '^HhllfJ 0(\'~ 3(.)513.:10 :unGHS 3111 jO . ' 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: April 7, 14,21,2006 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. - TO AND SUBSCRIBED before me this 21 day of April, 2006 NOTARIAL SEAL LOIS E. SNYDER, Notary Public CatJi::;!e B0m, Cumberland County My COiT:ni:;s:llf1 Mi'!rch 5. 2009 REAL ESTATE SALE NO. 61 Writ No. 2003-91 Civil Mortgage Electronic Registration Systems, Inc. vs. Colleen Elizabeth Brannon and Audrey Brannon Atty.: Mark Udren ALL THAT CERTAIN tract or par- cel of land with the improvements situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed in accordance with a sur- vey and plan thereof, dated August 28, 1968, prepared by Roy M.N. Benjamin, Professional Engineer, as follows: BEGINNING at a point on the northerly line of Wayne Circle, which point is one hundred sixty-two and four hundredths (162.04) feet east of the northeasterly corner of Wayne Road and Wayne Circle; Thence North forty-three (43) degrees nine- teen (19) minutes thirty (30) seconds West one hundred thirty-eight and forty-one hundredths (138.41) feet to a point; Thence North one (1) degree thirty-seven (37) minutes thirty (30) seconds East twenty-four and ninety-two hundredths (24.92) feet to a point; Thence North sev- enty-one (71) degrees fIfty-three (53) minutes thirty (30) seconds East eighty-four and nineteen hun- dredths (94.19) feet to a point; Thence South fifteen (15) degrees thirty-six (36) minutes thirty (30) seconds East one hundred nineteen and sixty-six hundredths (119.66) feet to a point on the northerly line of Wayne Circle aforesaid; Thence along the same in an arc having a radius of forty-five (45) feet in a southerly direction sixteen and sev- enty-one hundredths (16.71) feet to a point; Thence further along same in an arc having a radius of ninety- one and fifty-one hundredths (91.51) feet in a southwesterly di- rection twenty-three and twenty- nine hundredths (23.29) feet to a point, the place of beginning. THE IMPROVEMENTS THERE- ON BEING KNOWN AS 3 WAYNE CIRCLE, CAMP HILL, PENNSYLVA- NIA 17011. BEING TIlE SAME lot of ground described in a Deed dated 5/ 11 / 1999 and recorded among the land records of Cumberland County. Pennsylvania in Liber 199 and Fo- 110 915, was granted and conveyed by and between Audrey J. Brannon unto Colleen Elizabeth Brannon. BEING KNOWN AS : 3 WAYNE CIRCLE, (LOWER ALLEN TOWN- SHIP) CAMP HILL, PA 17011. PROPERlY ID NO.: 13-24-0797- 137 TITLE TO SAlD PREMISES IS VESTED IN Colleen Elizabeth Brannon and Audrey Brannon by Deed from Colleen Elizabeth . . . 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 since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 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#61 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013