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Home My WebLink About06-0302 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Angela E. Smith Edmond P. Petitto 330 Evergreen Street New Cumberland, PA 17070 Defendant(s) NO. JOO(P - 3OP{ CI'v.! 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 without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty 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. ts/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669.5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: 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: 330 Evergreen Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland COUNTY: Cumberland DATE EXECUTED: 09/17/04 DATE RECORDED: 09/22/04 BOOK: 1881 PAGE: 3118 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. S. 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 11/19/05: Principal of debt due Unpaid Interest at 5.763% * from 11/1/05 to 11/19/05 (the per diem interest accruing on this debt is $21.89 and that sum should be added each day after 11/19/05) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $306.19 and that sum should be added on the first of each month after 11/19/05) $138,626.97 2,290.97 325.00 280.00 (24.51) Late Charges (monthly late charge of $31.88 should be added in accordance with the terms of the note each month after 11/19/05) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 59.32 6,931.35 $148,489.10 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $148,489.10 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \){\}v Mark J. ndren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 "\F ../ A.U T1IAT CBRTAIN ITaC' or POlC41 of14nd turd pmnises. sl_ "turd beinr In the BoroulJh of Now Cumber!alld in the ColmO' of Cumberland .md 0,,.,,,0_111I of PenllS)llWlnlil, mon ptUt/cularly docribed os foil".,.: BEGJNN/NG ala point on 1M SOlIi/umlllne afE~ Sl1'OSl at the divisio./ine _en Loa Nos. 118 //lid 119 on lha henlM/lr mIllJttoned p/Qn. whldr pol'" If 300 feet. ",on: or lus,f""" the nOl'1herlJ,.,m ctmIfIr of Oak L_ and EWll'2/'MI Sl1ut: I_In uouth.../CI'Iy direction by said division line. at "Blat angl.. I. EvorgNm S,,*., J 40 fest'" cIIl UfInrrnrd 20 foot higlrway: ./rcna In a southwcstcrly dilYction by 1M line ofrhutlid ""named h41twtzy a dlfltince of so fat 10 a poln. on tlu! dM:ion line bdwH7I La.. N... J 1 7 and J 1 8: .lwtce in a 7ItlI'1h.wt1J""ly dil'llllllon tUo7IJI said dlllision line a dUt//llca of /40 fM to tlu! lIOuthttrly line of EvorgrNn Streel: l/rcna In a no~ dll'Ol1tion by the line of said Evergrun SI7Il., a disran.. of so fe., to tho point and plaCII of BEG/NN/NC. UNDER AND !IUBJECTto 011 nrstrlCU-. resr;Iliirms arttlea:_ ofrecm-d. .~ Washington Mutual Mailstop JAXB2004 P.O. Box 44090 Jacksonville, FL 32231-4090 IIII n Ilnlnlllllll 0684442155 7100 4047 5100 2047 7111 November 15, 2005 000912 IrA EDMOND P PETITTO 330 EVERGREEN ST NEW CUMBERLAND PA 17070 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0684442155 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This j.. :In offic:ial notice that the mortf1l9p. on vour hnmp- is in dernult and the lender intends to foreclO'le Specific: information about the nature of the default is provided in the aUached nal?e5 Thp. HOMEOWNFR'S MORTGAGE ASSISTANCE PROHRAM fHEMAP) may be able to heln to ~ve yom home This Notice f'xplains how the prnl!I'am works To see if HEMAP C<ln help vou must MEET WITH A CONSlJMER CRFDIT COIJNSELING AGENrv WITHIN 30 DAYS OF THF DATF OF THIS NOTICE Tl\\l:.e tn,,,, N011ce with VOl) when yon meet with the f:oun<w.limJ Aefmcy The name address and phone Dllmher of Chn!\nmE'r CrE'.dh Coun!leEng A~eDd~ servin? your f:ollnty are listAd at the end of this Notice lf YOIl have any Questions yOll m::lY cllll the Pennsylvanill HOllsin? Fin:mc.f' AP'P.D(,Y toll free at 1~RlIn~342-23Q7 (Persons with impaired hearin2 ('..an call (717) 7RO-1R6Q) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTlFICACION EN ADIUNTO ES DE SUMA IMPORTANCIA. PUES AFECfA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU lUPOTECA. EXHIBIT ( PA ACT 91 HOMEOWNER'S NAME(S): Edmond P. Petitto PROPERTY ADDRESS: 330 Evergreen St. New Cnmberland PA 17070 0684442155 LOAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVlSlONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELlGIBLE 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. TF.MPORARV STAY OF FORRC.1.0SlJRR. 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 nface-to~face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MRF.TING MlTST OrTlTR WITHIN THE NRXT (30\ DA. YS IF yO{ J DO NOT APPLY FOR FMERGENrv MORTGAGE ASSISTANrF YOn MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALI ED "HOW TO CURE YOUR MORTGACiE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSlJMER rRRDIT COITNSELlNG AGRNCIES - 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 aher the date of this meeting. The nrlmes lid dresses and telephone nllrn~Ts of desiVlllter'l r:nnsumer c.redit c.mmseline- af'endes for the conntv in which the property is loeated are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immp..diately of your intentions. APP1.ICATION FOR MORTGAGR ASSISTANCR - 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 Mongage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-ta-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY. AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGRNCV ACTION ~ Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE, IF YOU ARE CURRENTLY PROTECTED BY THE FlLlNG OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy. you can still apply for Emergency Mortgage Assistance.) 000912/C0826 HOW TO CURE YOUR MORTGAGE DEFAULT IBrin2 it IIn to date). NATlJRF OF THE DRFAIlLT ~ The MORTGAGE debt held by the above lender on your property located at: 330 Evergreen St. New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT BECAUSE, Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly lnstallments: 09/0112005 1O/011200S 1lI0 112005 1899.39 1899.39 1937.35 Other charges (explainJitemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE, 159.32 18.90 10.00 $2804.35 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable), HOW TO CnRF. THR DEFAULT - You may cure the default within THIRTY (30) DAYS of the date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $28005, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaYments must he madp. p.ither hy (".ash ca'lhier's check r.enified cher.k or mon~y order madp. nllv::.hle and sent to' Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee, WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF VOlT no NOT ClJRF. THF. nF.F AllLT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, thp. lenf'lpr intends in p.yerrisp. its rillht~ tn arrelern.tr. th.. mortrrape deht This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the 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 fnrP.C':lrnlp. upon your mortl!'al!'P.d nrll'hertv. *IF THE MORTGAGR IS FORECl.OSRn lJPON 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 $SO.OO. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $SO.OO. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If yon rllrf' th.. default within the THrRTV (3()\ DA V neriod YOU will not be reunired to nay :attorney's fees. OTHF.R 1 RNnF.R REMRnlR<; - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 RICwHT TO ctJRF. THF. OF.FAIII.T PRIOR TO SHERIFF'S SALE.. If you have not cured the default within the THIRTY (30) DAY period add foreclosure proceedings have begun, VOl] mav ~till have the rie-ht to cure the default and prevent the sale at any time lip to one hOllr hefore the Sher-jff'~ Sale YOll mav do so hv n!lYing the total amount then pa.o;t due plm any late or other charges then due reac;onahle attorney's fees and ('.osts connected with the foreclosure sale and any other costs connected with the Sheriff's Sale ao; specified in writ;n" hv the lE!nder and hv tlerformin" any other recllirements under the mortiaie Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. IURI lEST pn~"TRI,E SHERIFF'S SAI.F. OATF. It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff'~ 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: Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281.3914 Collection Department www.wamuhnmelnans.cnm Phone Number: Fax Number: Contact Person: Email Address: F.FFF.CTS OF SHF.RIFF'S SAI.F.. 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 Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSIIMPTION OF MORTGAGE - You _ mayor ..x 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 OFF THIS DEBT. . TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACfING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE AITACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA AC'T 91 Washington Mutual Mailstop JAXB2004 P.O. Box <14090 Jacksonville. FL 32231-4090 111111111111111I m 0684442155 7100 4047 5100 2047 7128 November 15,2005 000913/PA ANGELA E SMITH 330 EVERGREEN ST NEW CUMBERLAND PA 17070 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT# 0684442155 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi~ i~ an offici;:!] notice th::lt the morteaf'~ on your home is in dernnlt and the lender lntend~ to fnredrulp. Specific: infnrmMion ::Ihnllt the nature of the default 1<; nrnvided in the attached m1e:es The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HFMAP) may he ahle to help to save vom home This Notice e1q)lains how the nrngram works To see if HEMA P can heln yOll must MEET WITH A CONSUMER CRRnrr COl JNSELING AGENCY WITHIN in nAYS OF THE DA TR OF THIS NOTlr:F TakP. this Notice with VOll when yOll meet with the C.oun<;p.1ini Agency The n:J.TI1e address and phone number of Consum~r Credit Counseling Agencies servinf" yOllr Connty are listed at the end of this Notice If you have anv questions you may call the Pennsylv;tnia HOlIsinr Fin;tnce AfJencv toll free at I-ROO-,"{42-23'17 (Person.. with impaired hearinQ" can call (717) 7&O-lR69) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCClON INMEDITAMENTE LLAMANDO ESTA AGENClA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA AGr 91 000913/COB26 HOW TO CURE YOUR MORTGAGE DEFAULT (Brin. it un to date). NATlTRR OF THE DF.FA.1TLT - The MORTGAGE debt held by the above lender on your property located at: 330 Evergreen St. New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT BECAUSE, -N(fii~paytiiefir A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 09/0112005 1010112005 11/0112005 $899.39 $899.39 $937.35 Other charges (explainJitemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE, $59.32 $8.90 $0.00 $2804.35 B. YOU HAVE FAlLED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2804.35, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must he made either by cash ca'lhif~r'<; check certified check or monev order made pavahle and sent to. Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee, WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): TF VOl) no NOT ClTRF. THF. nF.FAlTT.T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to eyerr:ise its ril1hts t.o 9rr.eler9h~ the mortfllPp. deht This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the 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 foreclosp upon "our mortgaged nronertv. "'IF THF. MORTGAGE TS FORRCI.OSF.D 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 attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If ynll l"IITP. t.hp. dpf9UIt. within the THIRTY 130\ DAY neriod. "on will not he reunired to nay attorney's fees. OTHER I,RNDF.R RRMRnTES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA AL'T 91 RIGHT TO~ r.nRF. TNI': DEFA.ITI.T PRIOR TO SHF.RIFF'S SALE - If you have not cured the default within the THIRTY (3D) DAY period and foreclosure proceedings have begun, you may !\till haw the rip-ht to Cllre the default llnd pnwent the <>ale:lt :lnv time IIp to one hour hefore the Sheriff~ Sale You may do ro hy parin!?" the total amount then pa..t due nlus any late or other charie~ then due rea<;()nable attornev's fP.es and costs connected with the forecl()!l;nre "ale and anv other costs connl>.cted with the Sheriff's Sale &'l snecified in writim. hv the lender )mD hy performini any other requirements under the rnortpal:!'e Curing your default in the manner set forth in this notice will restore yClur mortgage to the same position as if you had never defaulted. F.A."RLlF.RT Prnt"nu.F. SHF.RTFF'S SA.I.F. DA.TI': - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LRNDER: Name of Lender: Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866.926.8937 904-281.3914 Collection Department www.wamuhomeloans.com Phone Number: Fax Number: Contact Person: Email Address: EFFF.r.T~ OF S.HI':"RIFF'S SA.LE' - 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 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 MO"RTGAGE - You _ mayor X 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. yon 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 THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACnON BY THE LENDER. . TO SEEK PROTECl'ION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PAACT91 V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. \Jrl) Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Jc::::, ~ \J-~ (3; ~ ~ >-1 C1 r-...,' "- ~ ~ " ~ ~ ~-- " "II <:0 ~ - ~ --- ~ G; ~ (N ~ ;,;:" .. U' ~ c.> SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00302 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS SMITH ANGELA ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SMITH ANGELA E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , SMITH ANGELA E 330 EVERGREEN STREET NEW CUMBELAND, PA 17070 330 EVERGREEN ST APPEARS VACANT, BUT JUNKY. DEFT'S ADDRESS IS 8355 MOUNTAIN RD. HBG, PA 17112 Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 15.84 5.00 10.00 .00 48.84 ~~ R. Thomas Kl' e Sheriff of Cumberland County UDREN LAW OFFICE 01/25/2006 Sworn and subscribed to before me this 3ij~ day of .:JO:0W1Jy ,):0& A.D ?tLn . ~ ~'h~Y 1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00302 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS SMITH ANGELA ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PETITTO EDMOND P but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 330 EVERGREEN STREET NEW CUMBERLAND, PA 17070 , NOT FOUND , as to , PETITTO EDMOND P 330 EVERGREEN ST APPEARS VACANT, BUT JUNKY. DEFT'S ADDRESS IS 8355 MOUNTAIN RD HBG, PA 17112 Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 So answ~rs: ~ ~ ~homas Kline Sheriff of Cumberland County UDREN LAW OFFICE 01/25/2006 Sworn and subscribed to before me this 3o'/-{ day of 0/d'u,",,/ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA Plaintiff v. Angela E. Smith Edmond P. Petitto Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-302 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: February 27, 2006 UDREN LAW OF~CES, P.C. \/~ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ___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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 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) Angela E. Smith and Edmond P. Petitto 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 ~laintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/20/06 to 5/2/06 Late charges per Complaint From 11/20/06 to 5/2/06 Escrow payment per Complaint From 11/20/06 to 5/2/06 TOTAL $148,489.10 3,589.96 159.40 1.837.14 $154.075.60 I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, copy of Plaintiff and been given in hereto. rk J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: (Yl';:l'( d ::JtJob , INDlCAT"" c2; . .~ PRO PROTH!~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY 1.0. NO. 04302 WOODCREST CORPORATE CENTER 111 WOOD CREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA Plaintiff ATTORNEY FOR PLAINTIFF v. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Angela E. Smith Edmond P. Petitto Defendant(s) NO. 2006-302 Angela E. Smith 8355 Mountain Road Harrisburg, p A17112 DATE of Notice: April 19, 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 REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OB AI WILL BE USED FOR THAT PURPOSE. s . n, Esgu~re Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 ODREN LAW OFFICES, P.C. BY: Mark J. Odren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SOITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA Plaintiff ATTORNEY FOR PLAINTIFF v. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Angela E. Smith Edmond P. Petitto Defendant(s) NO. 2006-302 TO: Edmond P. Petitto 8355 Mountain Road Harrisburg, p A17112 DATE of Notice: April 19, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFlCACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUEA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WI BE USED FOR THAT PURPOSE. s . ,en, squ~re 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2006-302 STATE OF NEW JERSEY AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Edmond P. Petitto Over 18 As captioned above Unknown Angela E. Smith Over 18 As captioned abov Unknown Sworn to and subscribed before me this 2nd day ~' 200~ o ry ~liC . U. -,.... -'," ",.j . ',V..-');'; .fil.._.....>. ~ "''-'';;l:!!-\,7~>:'''-:__!:'-_V . i',.:", ":: Nam Tit Com MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. , c }:J (J ~ ~4 .Q- "1'. ....0 0 C:,:,' ~~.-{\ c.~; ,j'''' \t- .....:" '1- \\ \) ..;,.,., .- v' f:':., .-('-,(: "1.-" ';...-- ...-,'>~' \) \"\'\ " \ ,~" -.",' \ -.'\1;' r l'-' - ~ ~. ~e:f )"(~ .~-, \ \, ..::z '>'"' ,",: -C;? -;:>\ ~ ~ - ~ ~ 0 IU' W :p 0 ~ ?-J -i- \f -...0 -r-- --'-- r ,. ~ 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 TO: Angela E. Smith 8355 Mountain Road Harrisburg, PA 17112 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Judgment in Replevin pr?:ii-J:tj -X- Judgment by Default Money Judgment 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 pumber: 856-669-5400 , 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road HarriSburg, PA 17112 Defendant (s) NO. 2006-302 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) Angela E. Smith and Edmond P. Petitto 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 11/20/06 to 5/2/06 Late charges per Complaint From 11/20/06 to 5/2/06 Escrow payment per Complaint From 11/20/06 to 5/2/06 TOTAL $148,489.10 3,589.96 159.40 1.837.14 $154,075.60 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, COPYi\f which is attache~hereto. UDRENLAW FFI S, P.c.) / rk J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: INDICATED ~ . ~.... PRO PROTHY fJh~ ~7 "" " 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006 -302 TO: Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 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 Money Judgment Judgment in Replevin ~ -K- Judgment by Default 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, Esauire At this telephone number: 856-669-5400 r , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 2Do CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2006 -302 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) Angela E. Smith and Edmond P. Petitto 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 11/20/06 to 5/2/06 Late charges per Complaint From 11/20/06 to 5/2/06 Escrow payment per Complaint From 11/20/06 to 5/2/06 TOTAL $148,489.10 3,589.96 159.40 L 837.14 $154,075.60 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, . copy of which is attached hereto. UDRB~FFI S, P.C. / DAMAGES ARE HEREBY ASSESSED AS DATE: rk J. Udren, ESQUIP~ Attorney for Plaintiff '::~:J2~ ~ 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $154.075.60 Interest From 5/3/06 2.780.03 to Date of Sale September 6. 2006 Ongoing Per Diem of $21.89 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. Mar J. Udren, ESQUIR ATTORNEY FOR PLAINTIFF ;z) (f'I 'o.s r ~ -;vT:r cY:J ~ 4r- '1... lf1. III - 4J +- ..:z: - f> ..:z: ~ w ~ ~ :th r. +- tJ ~ () r-- ~ ~~~ -...::::r ~ ~~ .J:: ~--{) - ""I;) Vl ~ ~ . ~,-') 0 ~ C r~-:;"! -.-1 ~ VI Q ~ ~ r;:'.'::< -- \' 111. ~ ,-f' Q ..J::. C ..t. _'c" "" C C C \) ..~:.". C ";.-,p V) \ \ I -;;' \;. ~ \ \ \ \ \ ~~ \ "" 'r- ~ - - - -. ... ... - - - lQ... ;- - ... ... "9 ... ... - - - ~ 0 ... - '" - ... 0 f" ... -:, - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-302 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA Plaintiff (s) From ANGELA E. SMITH AND EDMOND P. PETITTO (I) You are directed to levy upon the property ofthe 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $154,075.60 L.L. $.50 Interest FROM 5/3/06 TO DATE OF SALE 9/6/06 - $2,780.03 - ONGOING PER DIEM OF $21.89 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comrn % Atty Paid $247.68 Plaintiff Paid Date: MAY 2, 2006 Due Prothy $1.00 Other Costs (Seal) Prothonotary By: 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 ill 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 NO. 2006-302 Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF rS', ~. .;;> 4;' -....., :.;.:: \ ~ ~>: (5 .' C' C q, ?-n ~f~\ -~, )--) 1:";;-- i>'>:~'?\ :;~ . , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 NO. 2006-302 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, 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: 330 Evergreen Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Angela E. Smith 8355 Mountain Road Harrisburg, PA 17112 Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none . ~ 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept 1 Courthouse Sq, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St 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 330 Evergreen Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 2, 2006 Mark J. Udren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. r-' c-:-~ ceo ..;.J-~ :;:i: ~"'~ -"" ~ \ r'-' -..,-. s,:':. B c...') o ~ . 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Angela E. Smith 8355 Mountain Road Harrisburg, PA 17112 Your house (real estate) at 330 Evergreen Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $154,075.60, 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 TAKI! 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 . . <) rc; 0 c;~:;) -f\ , ,>..... \ r--:> ~,: ......... - C;; ,....--, 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 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Your house (real estate) at 330 Evergreen Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $154,075.60, 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 HAVI! 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 -H .--I -r:,-..-. ,"\IP- <:1\':c\ ~,,-'> '..,.' \1:-_' ,~:\ :-) :~;'\ I"~ ~_ ~ _..:';,liJ, "~;.:~ ~i'J -":.t;. ~. -- ~ o CJ .-J AU17UT CBRTAlN tract ",. PruC4/ of14>rd anti prom...., sl_ 1yinf anti bCnJln the 1l0l'0Ulh ~ Now CUmberW14 in tire COlRI'Yof ClIIl1b1rland Imd c,,""""""'""'tir ~ P01IIJS)IIvo1IUz. 11IM< ]XVtIeWaJ'i)i d...oribed os follows: BEGINNING at 0 poto, on lhe :owhmll1n. of E~ s...... at tir. dl.,;;,ioolinc _.. Lau Nos.118twi /19..,/uJ~"lIURIttonedpUm. whlchpoillllr300f=1. "",,"orl=.f""" ,h. norrirMwml_ ofOok L.... /DId E...".... SIne: rIIftMB to a .ordJl=tt:rly dirocti.. by said _ 11M. at ",h",orla 10 ~ Sua,. UO/Hl1O 111I WIll"""'" 20f_ h/gfrway: t/uJna In astOltir_lY d_lion by 1M JiM ofllll/Jatd wmamtd m,hwtty a dlrl40Cfl of so fat 10 0 point on rM dllllMn,l1ne between Lou NOI. 117 anti 118: liuJIta In 0 7lOI'IhweJrer/y dil'fCdon ilJo1l6 stli4 divllion line a dintuu:a of 140 fn( 10 the solltlterly 1m. ~Everg/wtI SIred: Ih",," in a oo1'lhMurrly di1Wllt1"" by the w.. of soid ~o Strot a dl.rUDI.. of so fn: to the point Imd pIoce of BEGINNING. UNDERAND SUB./ECTtooU restricti.... ~antI.a:_ ofreami. 'If' BEING KNOWN AS: 330 EVERGREEN STREET NEW CUMBERLAND, PA 17070 PROPERTY rD NO. : 26-23-054l-189C TITLE TO SAID PREMISES IS VESTED IN ANGELA E. SMITH AND EDMOND P. PETITTO BY DEED FROM DANIEL J. HOUSER AND SUZANNE HOUSER, HUSBAND AND WIFE DATED 7/24/03 RECORDED 7/28/03 IN DEED BOOK 258 PAGE 1629. , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-00302 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS SMITH ANGELA ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent search and , Sheriff or Deputy Sheriff who being and inquiry for the within named DEFENDANT PETITTO EDMOND P but was unable to locate Him deputized the sheriff of DAUPHIN , to wit: in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On March 31st , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 03/31/2006 UDREN LAW OFFICE Sworn and subscribed to before me this I( +I. day of ~y d..Obfo -)to ~A ~~y County In The Court of Common Pleas of Cumberland County, Pennsylvania Washington Mutual Bank VS. Angela E. 9nith et al SERVE: Edmond P. Petitto 06-302 civil No. Now, March 7) 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 Cumberland County, PA Affidavit of Service Now, ,20-, at 0' clock M. served the within upon at by handing to a copy of the original and made mown to the contents thereof. So answers, Sheriff of County, PA , COSTS SERVICE :MILEAGE AFFIDAVIT $ Sworn and subscribed before me this _ day of 20 '- $ @iiite of tlp~ ~4~riff 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 WASHINGTON MUTUAL BANK FA vs County of Dauphin PETITTO EDMOND P Sheriff's Return No. 0382-T - -2006 OTHER COUNTY NO. 2006-302 AND NOW:March 27, 2006 at 12: 18PM served the within REINSTATED COMPL.MORTGAGE FORECLOSURE upon PETITTO EDMOND P by personally handing to DEFT 1 true attested copy(ies) of the original REINSTATED COMPL.MORTGAGE FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY PRISON HBG, PA 17111-0000 So Answers, Jf~. Sheriff 6'f uprrrn:' coUi'rty, Pa. Sworn and subscribed to before me this 27TH day of MARCH, 2006 ~ , . By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1,2006 Deputy Sheriff Sheriff's Costs: $41.25 PD 03/10/2006 RCPT NO 215596 GMILLER SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-00302 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS SMITH ANGELA ET AL 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: SMITH ANGELA E but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within COMPLAINT - MORT FORE County, Pennsylvania, to 31st , 2006 , this office was in receipt of the On March attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 18.00 9.00 10.00 41. 25 1. 59 79.84 03/31/2006 UDREN LAW OFFICE County Sworn and subscribed to before me this (/4 day of ~ d--<;of- d~- ( ~ry In The Court of Common Pleas of Cumberland County, Pennsylvania Washington Mutual Bank VS. Angela E. anith et al SERVE: Angela E. anith No. 06-302 civil Now, March 7) 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. . Lr~~~~ Sheriff of Cumberland 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 !mown to the contents thereof. So answers, Sheriff of County, PA , COSTS SERVICE . MILEAGE AFFIDAVIT $ Sworn and subscribed before me this_day of ,20_ $ @iiite of tly~ ~4~riff 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 WASHINGTON MUTUAL BANK FA vs County of Dauphin PETITTO EDMOND P Sheriff's Return NO.0382-T - -2006 OTHER COUNTY NO. 2006-302 AND NOW:March 27, 2006 at 11:03AM served the within REINSTATED COMPL.MORTGAGE FORECLOSURE upon SMITH ANGELA E by personally handing to DEFT 1 true attested copy(ies) of the original REINSTATED COMPL.MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 8355 MOUNTAIN RD HBG, PA 17112-0000 Sworn and subscribed to before me this 27TH day of MARCH, 2006 So Answers, Jfc#L Sheriff of Pa. By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. I, 2006 Deputy Sheriff Sheriff's Costs: $41.25 PD 03/10/2006 RCPT NO 215596 GMILLER 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-302 v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: August 8, 2006 , Esquire laintiff . -" "':.~.. . . Service of Process by APS International, Ltd. 1-800-328-7171 Washington Mutual Bank, FA, ej. al., Plaintlff(s) VI. Angela E. Smith, et. aI., Defendant(s) APS International Plaza 7800 Glenroy Rd. Mluneapolls, MN 55439-3121 APS File #: 078101-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Edmond P. Petitto Court Case No. 2006-302 UDREN LAW OFFICES Ms. Hennl Crommarty 111 Wondcrest Rei, Suite 100 Cherry Hill, NJ 08003-3610 - - - - -n~ - - - - -.- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Stateof: ~AJ S'I L lilt AI '1\ ) ss. County of: SN~ i)(1t ) Name of Server: '1l'4 U 1>. ~ fI} t:tfl., e.,p S7/t'lfLt. ,undersigned, being duly sworn, deposes and says , that at the time of service, slbe was of legal age and was not a party to this action; Datefflme of Service: that on the ...L:/....dayof .JJ(L- 'I , 200..k., at lo1;~'clock PM . Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: at Perry County Jail - 300 S. Carlisle Street ,10 New Bloomfield. PA 17068 the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Edmond P. Petitto ~ By personally delivering them into the hands of the person to be served. o By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Edmond P. Petitto at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex J!L Skin Color 14 II,'rf ; Hair Color "J" ~~. I. J ; Facial Hair If" S Approx. Age '37 ; Approx. Height S't: . ; Approx. Weight I J 0 D\l To the best of my knowledge and belief, said person was not engaged in the US Military at , . the time of service. Undersigned declares under penalty of perjury that the foregoing is true and correct. /~?::2f# 4.~ Signature erver. APS International, Ltd. ,200 " Service of Process by APS International, Ltd. 1-800-328-7171 ........ Washington Mutual Bank, FA, el. al., Plalntiff(s) , VS. Angela E. Snrllh, el. aI., Defendanl(s) APS lnlemational Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 077586-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Angela E. Smith Court Case No. 2006-302 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcr"l Rd, Suile 200 Cherry Hill, NJ 08003-3620 tj- - ~----------------------------------- St~t;of~ - nil (1 ;1 ( .[ WI [ CI. ) ss. Countyof: DCWfkrt'\ ) ct\~\S, ~. f((E IT"> Name of Server: Dateffime of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; that on the <1 t"- day of ~ v N ~ ,20 !L!.t, at 2-:3So'clock LM at 8355 Mounlain Road ,in Harrisbul1l. PA 17112 the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property A true and correct copy ofthe aforesaid document(s) was served on: Angela E. Smith t8l By personally delivering them into the hands of Ihe person 10 be served. o By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Angela E. Smith at the place of service, and whose relationship 10 the person is: The person receiving documents is described as follows: J Sex E; Skin Color WI.llTE ; Hair Color B42.0\.1\I N ; Facial Hair roi { A Approx. Age z..., ; Approx. Height <;'3 ; Approx. Weight \ q5 o To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. ed declares under penalty of perjury regoin an correct. Signature of Server APS International, Ltd. Ncur'a1 s~ LlndaJ..hJnper. NoIBIy P<lIJlic CIotIoIe Il<xo, Cl.rnbedand Ccu1ly Mr ~..I.wlOR e.pilw >>123. 20Cll _.p.,.-............ boll.. .00NaIIIIII i , I 1".r""~' L_'::';~. .. """'f.,it,,"''': ~'" (") "" ".. g c: "" ;llffi ~ ~.j;! c::: Z;,C' G"> zr;. ~~ W".. 0 --< .. _.~~ ,<C-i -0 ~:D J..-....C. :x ( (") Z ,_.1 -,~( ) m >.c: c..> ~ ~ ,- 0 ~ s:- .,1'1 }" ., ,. ;,.~,. , ,..': '1:-';::' .~,: ",.rJ,..."#~" ~V{~;'" ',1 ( *,,,,,,..q UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit IIAII, was sent to every recorded lienholder and everr other interested party known as of the date of the filing of the Praec1pe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "BII. 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit IIBII. 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit IIBII. All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to relating to unsworn falsification Dated: September I, 2006 4904 BY: Mar J. U ren, Esqu1re Attorney for Plaintiff ODREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCRBST CORPORATE CENTER 111 WOODCRBST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 NO. 2006-302 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, 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: 330 Evergreen Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Angela E. Smith 8355 Mountain'Road Harrisburg, PA 17112 Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Perry County Jail 300 S. Carlisle Street New Bloomfield, PA 17068 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 American Express 1804 Washington Boulevard Baltimore, MD 21230 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept 1 Courthouse Sq, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St 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 330 Evergreen Street New Cumberland, PA 17070 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 elating to unsworn falsification to authoriti DATED: September 1, 2006 rk J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-302 v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, FA 17112 Defendant(s) DATE: May 2, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'SSALE OF REAL PROPERTY OWNER(S): Angela E. Smith and Edmond P. Petitto PROPERTY: 330 Evergreen Street, New Cumberland, PA 17070 ~provements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the cumberland County Sheriff IS Sale on Se~tember 6, 2006, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 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W ~ g.;:a & "Cilia; C::W"C lDlDl::: lD .. lD E:gcn ~<o ~~ .~ .~ 'a: ! :x;i CI.)&I... .. 0 ~~ :e~ t::l t-- <z 2tii enD.. ! ::l .... z o .~~ Zt\I :i: ,-po ent\l <0 ~~ ~uf ma: .....0 cn~ en-- wti a:< D...al x . we za: <~ Qw a:...J w::> ~o cCal . f..~..b./ ~ <)jl\ F ~ "IF \?\ I~ If t~ : '_ ~ .7\"; ".. ~~ .2.2 .~i. .t.I]. ..I.~'" E!!J : ! I-.]~ iE :> .j...ilii € ".i.i E.42 ~i~~l ~~..15!! ! .~.51~h' i~~1~8'1S II..~.'I.. ]'1 !iil"' ..~ .~...I..' ..Ej..=.I. -.....1.=. l ..~.I. .,. ~lSr f..... ;tl it~'I- Jj/ 5. ..1'.2'0.1 I. ~!= - -j ~ 'iii ~I~_ IS .0!2! ~ ~..l~.lt! ~ 'tg!.1 ]; ~ 1<~Il?i...15 _l!:'O 8. J'15f ..:tl! 'O.ti ,:.e~lBl ~.;I..I.e....lt .... ~i~!~ i~ilj! :-- '- ~u fiN ! ait,.snv ~" (i. ~'t\~ . :; . "t cf- ~ ~ ~ '= ~ ~) 1 \' E "@ D.. , .' ljl D..6 'O!- l~ ElD ::Ii z> ~l t-a: fI) 0 a: 8 j t\I D.... ~ 0 w 'O~ ~ ale Z ~ ..c: C\I ::Ez z .!~ ~ IS 55 w ~ :I: E>. ::1.0 =i 0 ..... C\I ('I) "It LO ~1i5 ('I) "It LO co ,... CD 0> .... .... .... .... .... .... t-::l EXHIBIT A C\I : 111 A. - : is A. ~ 113 .... o ..ai: .5 .: ! ... ! >- .Q " ~ Q. E o (.) 111 .Q 1$ ::I 2 E .... o u. ......~ "It 0> 0> .... ~ as :::J ... .0 8? ~ CD C') E o u. C/J Q. 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-302 v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: Mark ~, Esquire Attorney for Plaintiff August 8, 2006 BY: (') ~ ......:s:: ut.::r mn~ 2.'-.' -"..-'. <,--,- CD ~J:. :<-,,- \~; '1 1'0.,) c:::. c:::. Q"\ .):a. c:: CI) ~ ~:23 :oFt::; ~9 5!~ b::D a~ ~ -<: (:) -0 ::r w " o .r::- EXHIBIT 8 I . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-302 v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: August 8, 2006 , Esquire Plaintiff EXHIBIT B Service of Process by APS International, Ltd. 1-800-328-7171 Washin~on Mutual Bank, FA, et. al., Plaintiff(s) vs. Angela E. Smith, et. aI., Defendant(s) APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 078101..{)OOl AFFIDAVIT OF SERVICE -- Individual Service of Process on: UDREN LAW OFFICES -Edmond P. Petitto Court Case No. 2006-302 Ms. Henni Crommarty 111 Woodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 - - - - -n- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - State of: filII/AI Sf( L u It U 'j" ) ss. County of: 5' N ~ i) ( It ) Name of Server: blf4( (,~ 1>. f!4 tJ ~ if/.., f!tJp ~71t1J(..t. , undersigned, being duly sworn, deposes and says I that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the ~day of JilL- 'I , 200-'t., at IcJ;~'c1ock PM . Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: at Perry County Jail- 300 S. Carlisle Street , In New Bloomfield, PA 17068 the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Edmond P. Petitto ~ By personally delivering them into the hands of the person to be served. D By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Edmond P. Petitto at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex m; SkinColor lull l'rf ; HairColor ~~U ; FacialHair r~.S Approx. Age ~ 7 ; Approx. Height 5"" " ; Approx. W~ight / J 0 []J To the best of my knowledge and belief, said person was not engaged in the US Military at , . the time of service. Undersigned declares under penalty of perjury that the foregoing is true and correct. /.~ 4+- Signature erver APS International, Ltd. ,200~ (Commission Expires) EXHIBIT B . . Service of Process by APS International, Ltd. 1-800-328-7171 Washington Mutual Bank, FA, et. aI., Plaintiff(s) vs. Angela E. Smith, et. aI., Defendant(s) APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 077586..{)OOl AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Angela E. Smith Court Case No. 2006-302 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 -----n----~-------------- State of: r U\ ~ ~1l ~ P-..t1 t 0\ ) ss. County of: D CW f k r t'\ ) Name of Server: C H-t2- \ ~ (f. RZ.~ ITA- S Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; that on the q t~ day of :J '" N ~ , 20 Q..k, at 1--/35o'c1ock LM at 8355 Mountain Road , in Harrisbur2. PA 17112 the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property A true and correct copy ofthe aforesaid document(s) was served on: Angela E. Smith ~ By personally delivering them into the hands of the person to be served. D By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Angela E. Smith at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: I Sex L; Skin Color WH ('TE ; Hair Color B~\..", rJ ; Facial Hair rJ t A. Approx. Age z.., ; Approx. Height ':=)'3 ; Approx. Weight \ q5 D To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. APS International, Ltd. NolIr'41 s;-a' U1daJ. J~, NotaJy P<.:IJflc C8rilIIe Bolo. Cl.InbeIlancI Cou'lly _ Q..ft8iCIn 8rPNI Jtit 23. 2mI .......PwI~,..., ,Wir 'lOlNcltlllla EXHIBIT B =-=1 -< ,....., = C::;;) CI" ~ -4 :L" fn c:: l) tL~ ~5~5 --.-- " ';1 ~~:~ \.._) --I ~ -< (./') P1 -0 I co 3: (-;? w .f COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Washington Mutual Bank FA is the grantee the same having been sold to said grantee on the 6th day of ~ A.D., 2006, under and by virtue of a writ Execution issued on the 2nd day of May, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 302, at the suit of Washington Mutual Bank FA against Angela E Smith & Edmond P Petitto is duly recorded in Deed Book No. 276, Page 4415. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A9 day of M- , A.D. d--D 0 b ~ fJ. ~ d ~rder of Deeds RecoIdIr 01 Oetoa. ~ ~ CIrIIII. PA MrCtlnRlwk.. e-. lie Fftl""':' 01_ 2010 Washington Mutual Bank, FA VS Angela E. Smith and Edmond P. Petitto In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-302 Civil Term Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on June 28,2006 at 10:49 o'clock A.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 Angela E. Smith and Edmond P. Petitto located at 330 Evergreen Street, New Cumberland, Pennsylvania, 17070 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 ofthe action to the within named defendants, to wit: Angela E. Smith and Edmond P. Petitto, by regular mail to their last known address of 330 Evergreen Street, New Cumberland, Pennsylvania, 17070. These letters were mailed under the date of July 13,2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 06, 2006 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attorney Mark Ddren for Washington Mutual Bank FA. It being the highest bid and best price received for the same, Washington Mutual Bank FA of 1270 Northland Drive, Suite 200, Mendota Hieghts, MN 55120, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$855.04. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge $30.00 16.77 15.00 15.00 30.00 10.00 .50 1.00 14.96 15.00 30.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 335.00 257.00 19.31 25.00 40.50 $ 855.04 / 10/6 ()O~ 9- ;;~~ R. Thomas Kline, Sheriff BvC:J~~ Real Estat ergeant ~A_ 0#- 3 () ,Iff) I ')-1) . CI<. SS~33 R-u--. ) f10/9' I t ., '" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 NO. 2 0 06 - 3 02 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, 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: 330 Evergreen Street, New Cumberland, PA 17070 1. Name and address ,of Owner(s) or reputed Owner(s): Name Address Angela E. Smith 8355 Mountain Road Harrisburg, PA 17112 Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 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 I 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept 1 Courthouse Sq, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St 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 330 Evergreen Street New Cumberland, PA 17070 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: May 2, 2006 \ Mark J. Udren, ESQ. . Attorney for Plaintiff ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Angela E. Smith 8355 Mountain Road Harrisburg, PA 17112 Your house (real estate) at 330 Evergreen Street, New cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $154,075.60, 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 I 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 THJ:S PAPER TO YOUR LAWYER AT ONCE. J:F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFJ:CE LISTED BELOW TO FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ..-; ~ , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~l~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Angela E. Smith Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Defendant(s) NO. 2006-302 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Edmond P. Petitto 8355 Mountain Road Harrisburg, PA 17112 Your house (real estate) at 330 Evergreen Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff1s Sale on September 6, 2006, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $154,075.60, 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.) - It ... J 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 - :r .J ALL T1L4T CERTAIN tract tJ1' Ptv~ afUmd andpnmi8es. silUlJU.lyinr and"'" in the Bol'OUJh 01 Nn- Cumberlmd in tire CC1IIIIty "1 Cambtrland tmd CommolfWfNJirh Gj' Pen1fS)llwmtlZ, ~ ]1tI1'tlcuJID'IJI d~cribed C&J fol/tJW8: BEGINNING at ~ poilU on the $OIItMm line of EVI1'f"U1l Srner at tM divUion liN! ___ 1.Du NO!. JI 8 tINi 1I9 on eM ~" 1IUI1Ition64 pkm. which poirJI ", 300 /~ man: or Ias.from the 1IfJ1'IMtum71 CD1TIllT of Oak Lrme tmd ~ SI1wl: duma ill II JOrdJu:luu:rly direction by 3aid division/1M. fit ri8At IUIgI.. to ~ Slnet. 140 fM 10 tUl vnnlUllfld 20 foot higlrwa.y; l'-rt:s bJ II southwaterly di1wction by 1M lill_ ofthl3atd WI1IfJIIffd /rirhwt&y (f disltlltce of 50 I- /o G point 011 tM dMM1f,/ine Htw.n Lou NfJ6. J J 7 fI1IIl J 18: tlwIee in Clltt>>'fhwcuter/.)l dfTfIClitm aJoIIJ! 3tZid diviMon IiM a dintl1lClC of 1401_ 10 1M 3fJ1ltlIel'ly I. of ~ Srr<<l; th~ in II no~ dlrtJetion by the lbr. of mid Ewrgran SI1'Ut G tlUumo. 0150 f- to 1M point and plactf of JJEGlNNING. UNDER.4ND SUBJECT to tlU r<<micstmu, ~ aPlti eMfIMnU afncmrl. 'T PROPERTY ID NO. : 330 EVERGREEN STREET NEW CUMBERLAND, PA 17070 26-23-0541-189C BEING KNOWN AS: TITLE TO SAID PREMISES IS VESTED IN ANGELA E. SMITH AND EDMOND P. PETITTO BY DEED FROM DANIEL J. HOUSER AND SUZANNE HOUSER, HUSBAND AND WIFE DATED 7/24/03 RECORDED 7/28/03 IN DEED BOOK 258 PAGE 1629. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-302 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due W ASIDNGTON MUTUAL BANK, FA Plaintiff (s) From ANGELA E. SMITH AND EDMOND P. PETITTO (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $154,075.60 L.L. $.50 Interest FROM 5/3/06 TO DATE OF SALE 9/6/06 - $2,780.03 - ONGOING PER DIEM OF $21.89 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Arty's Comm % Due Prothy $1.00 Arty Paid $247.68 Other Costs Plaintiff Paid Date: MAY 2, 2006 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SillTE 200 CHERRY IllLL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 38 On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, P A Known and numbered as 330 Evergreen Street, New Cumberland, more fully described on Exhibit "A" ~ ~ filed with this writ and by this reference incorporated herein. Date: May 22, 2006 By: ~~ Real ~stQ 'Sergeant (( :b '\I S - ^ VH qUUl Vd 'AlIUWJ UN'v'WJBWliJ .:J.j/H3HS 3Hl .dO 3:JU.:JO ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. .~... V.lar 11.11 . '.' ....... '.. . ...... . . !,dr:; .,. PUBLICATION COPY S ALE #38 ~....,...~,.~.:",.. .AlL ~. ."orPla ellllld ....... ',." ....~~^.~.._d "-'f'~~.~1=.'."'..~o.y...... ~ ..' . . . .... . ... '. ,."')1-. .........,.,....,~.. of ~....."'.I~iJll[...... Loll N&tta__..v-.' 'n .~~ -. ........ir'..... __.... ...........&..- dae. - .~.f.:... *'!f:.a.::_ ": ~+.... .....~ ..,~ ,. .~ ~,"IIlIt"'''''.,_",,~ ---~,_t....I,A;..&.._....., ,_' ....""'''-~ CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July 21, July 28, and August 4,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 38 Writ No. 2006-302 CMI Washington Mutual Bank. FA vs. Angela E. Smith and Edmond P. Petitto Atty.: Mark Udren ALL THAT CERTAIN tract or Par- cel of land and premises, sUuate. lying and being in the Borough of Now Cumberland In the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- scribed as follows: BEGINNING at a point on the southem line of Evergreen Street at the division line between Lots Nos. 118 and 119 on the hereinafter mentioned plan, which point is 300 feet. more or less, from the north- eastem corner of Oak Lane and Evergreen Street; thence In a south- easterly direction by said division line, at right angles to Evergreen Street. 140 feet to an unnamed 20 foot highway; ~en:e ~ a so..~\V=s~: SWORN TO AND SUBSCRIBED before me this 4 day of August. 2006 ~~~~ NOT ARI~L SEAL f":OIS E. SNYDER: Notary P~~IK: Carlisle Boro, Cumberland County My Commission Expires March 5,. 2009