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Home My WebLink About06-0486 . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY 1.0. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Jeffrey J. Nophsker 1249 Rossmoyne Road Mechanicsburg, PA 17055 Defendant(s) Mortgage Foreclosure ~ NO. 010- J..I!b OW; L 10LWl..- 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 , AV180 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 E8TA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o 81 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R A81STENC1A 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. Is/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003.3620 (856) 669.5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Gateway Funding Diversified Mortgage Services, L.P. Assignments of Record to: Mortgage Electronic Registration Systems, Inc. Recording Date: TO BE OBTAINED 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: 1249 Rossmoyne Road MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 4/30/97 DATE RECORDED: 5/2/97 BOOK: 1379 PAGE: 88 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 1/18/06: Principal of debt due Unpaid Interest at 7.5% from 9/1/05 to 1/18/06 (the per diem interest accruing on this debt is $13.14 and that sum should be added each day after 1/18/06) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $429.08 and that sum should be added on the first of each month after 1/18/06) Late Charges (monthly late charge of $25.45 should be added in accordance with the terms of the note each month after 1/18/06) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $63,963.67 1,822.51 325.00 280.00 2,609.72 101. 80 3.198.18 $72,300.88 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 $72,300.88 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \~ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAXN lot or tract of land, together with the improvements thereon erected, situate in Lower Allen 'l'nwnship, Cumberland County, Commonwealth f Penns Ivania, more particularlY oun ed an e ~ e as 0 lows to wit: BEGINNJ:NG at an iron pin on the northern right-of-way line of Rossmoyne Road at the dividing line of land now or formerly of Thomas O. Williams and the premises herein described, said pin also being located 408 feet more or less (measured along the right-of- way for Rossmoyne Road) from the northeast corner of Rossmoyne Road and the Pennsylvania Turnpike right-of-way. THENCI!: by the northern right-of-way line of Rossmoyne Road North 48 degrees 14 minutes 28 seconds West 156.87 feet to an iron pin at a buried iron pipe; thence by line of land now or formerly of Floyd G. Kautz North 55 degrees 00 minutes 23 secon~s East 154.51 feet to an iron pin over a buried iron pin; thence by line of land now or formerly of Richard E. Hammon and land now or formerly of Thomas O. Williams South 34 degrees 41 minutes 22 seconds East 156.94 feet to an iron pin; thence by land now or formerly of Thomas O. Williams South 57 degrees 04 minutes 10 seconds West 117.80 feet to an iron pin, the place of beginning. CONTAINING 21,036 square feet and having thereon erected a 1 1/2 story brick dwelling and a frame shed known and numbered as 1249 Rossmoyne Road. , ,:~ Washington Mutual Mailstop JAXB2004 P.O. Box 44090 Jacksonville, FL 32231-4090 1111111111111111111 5968142512 7100 4047 5100 2142 4817 December 15, 2005 001796 (f''' JEFFREY J NOPHSKER 1249 ROSSMOYNE RD MECHANICSBURG PA 17055 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# 5968142512 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi~ Ie;:m offici.al nntke that the monf':l.l?p. on vnnr hnrnp. j.. 1n .def:mlt and the ifmder intend.. to {nrf'.cln<ip. Spe.cific information ahOllt the nature of the default is nrnvided in the attached nages The HOMEOWNER'S MORTGAGF ASSISTANCE PROGRAM (REMAP) may be ahle to helD to save your home This Notice explai.n... how the prozrarn works To ~e if REMAP am help vou must MEET WITH A CONSUMER CREDIT rnlJNsEI JNG AGENrv WITHIN 30 nAYS OF THE DATF OF THIS NOTJrF Take this Nntic.e with VOll when you meet with fhf.: Connsplinf" A~n~ Thp. Damp. address and phone number of COnSUrnp.T Crf'.dit C:OUmlp.linl? Aepnclp's servinll your Conntv are listp.d at the end of this Notice If you have any q.uestions von may call the Pp.nnsylvania Hou;<;in~ Finance Agen..)' toll fr'ee at l-ROO-342.n97 (Person"l with impaired hearine- can call (717) 7RO-1RfiQ) This Notice contains important legal information. If you have an, questions, representatives at tbe 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 AFECfA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENlDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (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 mpOTECA. '."" ..,.-- 1 EXHIBIT /' PA ACT 91 '. ... HOMEOWNER'S NAME(S): Jeffrey J. Nophsker PROPERTY ADDRESS: 1249 Rossmoyne Rd Mechanicsburg P A 17055 5968142512 WAN ACCf. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: Washington Mntnal 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 PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACf OF 1983 (THE "ACf"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECf OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF.MPORARV ~TAV OF FORF.r.t.oSlfRR ~ Under the Act, you are entitled to a temporary stay oHoreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Uface-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THI~ MF.F.TTN~ MUST ~C.UR WITHIN THE NF.XT (~) D.4. VS IF YOU DO NOT APPLY FOR EMERClENrY MORTGAGE ASSISTANCE YOU MUST RRINc; YOUR MORTClAGE UP TO DATF THE PART OF THIS NOTTCF CALI FD lIHOW TO r:1:JRE YOUR MORT(JAGR DFFAUT T" FXpr AINS HOW TO BRING YOlJR MORTGAGE UP TO DATE CONSllMER rRRnlT m1JNSF.I .ING AGF.N~IF.S ~ If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The Mmes addres~s and telephone numbers of dB-signated ron'illmer c....edit coun~linp a~encieo; for thp. c.nnntv in which the prOJ}P.rtv is located are set forth at the end of this Notice It is only necessary to schedule one face~to~face meeting. Advise your lender immediately of your intentions. APPLT~ATION FOR MORTGAGE ASSISTANCE ~ Your mortgage is in default for the reasons set forth later in this Notice (see following pages. for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fiU out, sign and file a completed Homeowner's Emergency Assistance Program Applica.tion with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face~to~face meeting. 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. AGENr.v A~TION ~ 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, jf you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE, IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. (If you have tiled bankruptcy, you can still apply for Emergency Mortgage Assistance.) 0017gelc.0826 HOW TO CURE YOUR MORTGAGE DEFAULT !BriaR it un to date). NATlTRF. OF THF. OF.FAIJLT - The MORTGAGE debt held by the above lender on your property located at: 1249 Rossmoyne Rd Mechanicsburg P A 17055 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 Installments: 1010 1/2005 11101/2005 12101/2005 $938.11 $938.11 $938.11 Other charges (explain/itemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE, $50.90 $8.90 $0.00 $2874.13 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAULT- You may cure tile default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2874.13. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THB THIRTY (30) DAY PERIOD. P~ent.<; mm;t he made either hy ca~h ca..hier's check certified check or money order marlc navable 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 YOU no NOT r.1.1RF. TlIF. DF.FAln.T - Uyou do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend" to exerdH! it" rights to accelerate thr. mortvage deht This Dleans that tile entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the Dlortgage 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 forerln~e IIpon your martgav:ed nrqperh. *IF THF. MOR'fG-AG-E IS FORFC-LOSRD HPON 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 awe the lender, which may also indude other reasonable costs. If rOil rllre thp. dr.f:lUllt within the THIRTY (3m DAY neriod. you will not he renuired to nav attorney's fees. OTHER T ,ENDER RF.MF.DIES - The lender Dlay also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 RIGHT TO rITRF. THF. nF.FAIJI T PRIOR TO SHF.RIFF'S SALE- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you rn&y !'ltill h:we the rip"ht to cure thp. default and prevent thp. sale at any time lip to one hnllr before the Sheriff's Sale You may do !'lO by payin~ the total amount then past due pIu" any late or other charges then om": rea!';()TIahlp. attornev's fees and CO!'lts connected with the foreclosure !'lale and anv other costs connt'r.ted with the Sheriff's Sale ll.'\ "pecified in writing hv the lender and hv nerforminp" ;my other requirements under the morte-ape 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. F.ARLIEST Prn;:SIRI F. SHF.RTFF'S SAT.R DATF. - It is estimated that the earliest date that such a Sheriffs 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 Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THF. I.ENDER: Name of Lender: Address: Washington Mutnal Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281-391' Collection Department www.wamuhnmelnans.cnm Phone Number: Fax Number: Contact Person: Email Address: F.FFF.r.TS OF ~HRRTFF'~ 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. ASSIJMPTION OF MORTGAGF. - 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 AL.fiilO 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 TIDS 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 MAY HA VB TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaw. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA AC'Y 91 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. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. wU (:) .cc.. 8 ;D ?' lr) lL \\. ~ --- (-<, , U'( L_ - --J. !J\ () w --. -cJ c; . vJ ~ N IN F- , --J.. ' Ii .....;) - . ~ .' ,+,-. --.(.. ------- - SHERIFF'S RETURN - REGULAR CASE NO: 2006-00486 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS NOPHSKER JEFFREY J SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE NOPHSKER JEFFREY J was served upon the DEFENDANT , at 2039:00 HOURS, on the 30th day of January 2006 at 1249 ROSSMOYNE ROAD MECHANICSBURG, PA 17055 JEFFREY NOPHSKER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 12.32 .00 10.00 .00 40.32 So Answers: ~.~4 ~,/ /~~ r~.'~'- (~,i-.~;:"-._ "..",- /'",/ "".;;~"'/~'. .....~,- :-:1--"."-,'0.--":";"'."-".. "".," .. ,<~,y,~~ .. . ,;;..--.. .,';" -... R. Thomas Kline 01/31/2006 UDREN LAW OFFICE me this Sworn and Subscribed to before By: w '7~ day of ~... " UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Jeffrey J. Nophsker Defendant(s) NO. 06-486 Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. UDREN LAW OFFICES, P.C. DATED: March 7, 2006 I BY: ~ ., ,. V E R I F I CAT ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 02/20)66 , ~--- N e : Rick Wilken itle: Vice. Pre Si~ent Company'~ . '1Iol~';'l J {[ !Jm{ ~1 i51TaJ;,'rJ ! ~7s!e~ Jeffrey J. Nophsker Loan #5968142512 MJU #06010450 --,I, l'" ";,; ..----- Jeffrey J. Nophsker 1249 Rossmoyne Road Mechanicsburg, P A 17055 717-554-9845 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suit 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON CUMBERLAND COUNTY V. Jeffrey J. Nophsker 1249 Rossmoyne Road Mechanicsburg, P A 17055 Defendant MORTGAGE FORECLOSURE NO. 06-486 Civil Term RESPONSE IN MORTGAGE FORCLOSURE As instructed I am writing to obtain verification of any debt information you can provide. At this time, I am unable to admit or deny any part of this complaint due to the lack of information. Please send correspondence to the above address. I would also like to request payoff \ reinstatement figures through 3\31 \05. Thank you for your attention in this matter c;. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-486 civil Term v. Jeffrey J. Nophsker 1249 Rossmoyne Road Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO MARK SETTLED. DISCONTINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED, upon payment of your costs only. ~~ Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff DATED: Mav 10. 2006 \.D -r;. f'J ,,~ _J