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Home My WebLink About06-0937 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 p1eadings@udren.com Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) NO. 0(." - 937 CIULC j-ER-~ 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. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escri ta sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa 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 ofthe original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. Isl Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, 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: 720 Bloserville MUNICIPALITY/TOWNSHIP/BOROUGH: Upper COUNTY: Cumberland DATE EXECUTED: 04/30/03 DATE RECORDED: 05/02/03 BOOK: 1809 Road Frankford Township PAGE: 3135 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 2/1/06: Principal of debt due Unpaid Interest at 8.0% * from 6/1/05 to 2/1/06 (the per diem interest accruing on this debt is $20.33 and that sum should be added each day after 2/1/06) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $302.14 and that sum should be added on the first of each month after 2/1/06) Late Charges (monthly late charge of $33.70 should be added in accordance with the terms of the note each month after 2/1/06) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $91,551.83 5,001.18 325.00 280.00 2,254.58 235.90 4,577.59 $104,226.08 * 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 $104,226.08 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. J'0 Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 " LEGAL DESCRIPTION / ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER FRANKFORD TOWNSIDP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED ACCORDING TO A SURVEY BY STATLER AND LAHR DATED JULY 24, 1984 AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE BLOSERVILLE ROAD, AlK/A PA A-5749, AT LINE OF LANDS NOW OR FORMERL Y OF A. SCOTT CLARK AND ,WDITH A. CLARK; THENCE ALONG SAID LINE SOUTH 85 DEGREES 30 MINUTES WEST A DISTANCE OF 195.00 FEET TO A POINT ON THE EASTERLY SIDE OF A 10 FOOT WIDE ALLEY; THENCE ALONG SAID ALLEY NORTH 4 DEGREES 30 MINUTES WEST A DISTANCE OF 49.5 FEET TO A POINT ON THE SOUTHERLY LINE OF LANDS NOW OR FC)RMERLY OF WAYNE C. ANDERSON AND SONDRA L. ANDERSON; THENCE ALONG SAID LANDS NORTH 85 DEGREES 31 MINUTES EAST A DISTANCE OF 117.20 FEET TO A POINT; THENCE NORTH 4 DEGREES 30 MINUTES WEST A DISTANCE OF 2.20 FEET TO A POINT; THENCE NORTH 85 , DEGREES 30 MINUTES EAST A DISTANCE OF 15.84 FEET TO A POINT; THENCE SOUTH 4 DEGREES 30 MINUTES EAST A DISTANCE OF 2.20 FEET TO A POINT; THENCE NORTH 8g DEGREES 31 MINUTES EAST A DISTANCE OF 61.96 FEET TO A POINT IN THE BLOSERVILLE ROAD; THENCE ALONG THE BLOSERVILLE ROAD SOUTH 4 DEGREES 30 MINUTES EAST A DISTANCE OF 49.5 FEET TO A POINT, THE PLACE OF BEGINNING. BEING KNOWN AS LOT #15 IN THE VILLAGE OF BLOSERVILLE AND A SMALL PORTION OF THE LOT IMMEDIATELY TO THE NORTH OF TIDS LOT. BEING KNOWN AND NUMBERED AS 720 BLOSERVILLE ROAD, NEWVILLE, PA 17241, FORMERLY KNOWN AND NUMBERED AS R.D. #3, BOX 354 (FORMERLY DESIGNATED AS R.D. #3, BOX 68A.) . /!S LITTON LOAN SERVICING LP AnAtfiliate ore-BASS 4828 Loop Central Dr, Houston, Texas 77081 www.litlonloan.com Telephone 800-999-8501 Fax 7139668906 Tom Raudabaugh Date: 91612005 Page lof5 720 Blaserville Ruad Newville, P A 17241 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortl!alre on vour home is in default. and the lender intends to foreclose. SDecific information about the nature of the default i. nrovided in the attached Da!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) ma, be able to belD to save vour home. This Notice exnlains how to nroeram works. To see if HEMAP can help, ,ou mnst MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITH IN 30 DAYS OF lHE DATE OF lHIS NOTICE. Take this Notice with ,ou when ,ou meet with the CounseliD!! AIrencv. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pepnsylvania Housing Finance Agency toll free at 1-800-342.2397.(person. with impaired hearing can call (717)780-1869. This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer Credit Coup.eling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar l\llsociation may be able to help yon rmd a lawyer, LA NOTIFCACION EN ADJtJNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VlVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFlCACI0N OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCV) SIN CARGOS AL NUMERO MENCIONADO ARRIDA, PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU H1POTECA. EXHIBIT !- (Page 2 of 6) APPENDIX A Page 2 of 5 HOMEOWNER'S NAME(S): Tom Raudabaugb MAILING ADDRESS: 720 Blosenine Rd Newl'iIIe, PA 172419710 PROPERTY ADDRESS: 720 Blosenille Road NeWl'ille,PA 17241 LOAN ACCT. NO,: 11634796 ORIGINAL LENDER: CURRENT LENDER/SERVICE: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTIJRE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRc;UMSTANCES BEYOND YOUR CONTROL, U' YOU HA VEA REASONABLE PROSPECT 010' BEING ABLE TO PA V YOUR MORTGAGE PAYMENTS- AND IF YOU MEET OTHER ELEGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice, During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of the Notice, TIDS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "BOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and teleohone numbers of designated consumer credit counseling agencies for the county in which the orooertv is located are set fonh at the end of this Notice, It is only necessary to schedule one face-to-face meeting, Advise your lender inunediatell' of your intentions, APPLICATION FOR MORTGAGE ASISTANCE-Yourmortgage is indefanlt for the reasons set fonh later in this Notice (see following pages for specific information abont the naUlre of your default) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmanciaI assistance from the Homeowner's Emergency Mortgage Assistance Program, To do so, you must fill out, sign and me a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the (Page 3 of 6) APPENDIX A Page3of5 end of this Nolice, Only consumer credit counseling agencies have applications for the program and tliey wil1 assist you in submitting a complete application to tlie 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 LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, AGENCY ACTION - Available funds for emergency mortgage assistance are veI}' limited, They Will be disbursed by tile Agency under tlie eligibility criteria established by tlie Act Tlie 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 pursed against you if you have met tlie time requirements set forth above, You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLWWING 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 Emernency Mortp;ap;e Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brim! it uo to date), NATURE OF THE DEFAULT- The MORTGAGE debt held by the above leoderon your property located at 720 Bloserville Road IS SERIOUSLY IN DEFAULT because: A, YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 7/li2005 through 9/1/2005 at $976,21 toWing $2,928.63 Other charges Late Charges $ 67.4 Deterred late charges $ 0 TOTAL AMOUNT PAST DUE $2,996,03 B, YOU HA VE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if 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 $$2,996,03 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TIllRTI (30) DAY PERIOD, Payments must be made eitlierbv cash. cashier's check. certified check or money order made navable and sent to: Litton Loan Servicinl! LP, 4828 LOOD Central Dr Houston. TX 77081-2226, You can cure any other default by taking the following action within THIRTY (30) DAYS of the date ofthis letter: ffiQ not use if not annlicable.) (Page 4 ot" 6) APPENDIX A Page 4 of5 IF YOU DO NOT CURE THE DEFAULT - If you do not cure U,C dcfaull wiUrin TIfIRTY (30) DAYS OfU,C da!c of this Notice, the lender intends to exercise its rit!hts to accelerate the mort!!a!!e deht. This means that the entire outstanding balance of this debt will be considered due immediately and you may losc the chance to pay thc mortgage in monthly installments, If full payment of the total amount past due is IlOt made within TIfIRTY (30) VA YS, tile lender also intcnds to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed property, IF THE MORTGAGE IS FORECLOSED UPON - Thc mortgagcd property will bc sold by tilC ShcrifTlo pay o[[thc 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 fee that werc actually incurred, up to $50,00, However, if legal proceedings are started against you, you will mve to pay all reasonable attorney's fees actually incurred by thc Icnder cvcn if the cxcced $50,00, Any attorncy's fees will bc added to the amount you owe the lender, which may also include other reasonable cost If vou enre the default within the THIRTY (30) DAY neriod. YOU will not be reouired to nay attomev's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal halance and all other sums due under the mongage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you mve oot cured the default within the TIfIRTY (30) DAY period and foreclosure proceedings have hegun, vou still havc the ri~ht to cure the default and orevent the sale at any time un to one hour before the Sheriff's Sale. You may do so bv pavine the total amount then vast due DIus anv late or other coomes then due. reasonable attorney's fees and costs connected with the foreclosure sale and an\' other costs connected with the Sheriffs Sale as snecified in writin2. bv the lender and bv oerfonrnne anv other reaulrements under the mort1l3.e:e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you bad never defaulted, EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such as Sheriff's Sale of tite mortgaged property could be held would be approximately 6 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 eure 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: LITTON LOAN SERVICING Add ress: 4828 Loop Central Dr, Houston, TX 77081 Phone Numher: (800)999-8501 or (713) 960-9676 Fax Number: (713) 966-8906 Contact Person: Collection Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit !O reloove you and your furnishings and other belongings could he started by the leuder at any time, ASSUMPTION OF MORTGAGE - You _ mayor _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee wllO will assume the mortgage debt, provided that all the outstanding payments, charges and anomey's fees and costs arc paid prior to or at the sale and that the other requirements of the mongagc arc satisfied. (page 5 of 6) APPENDIX A Page5 of5 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 OF THIS DEBT. TO HAVE TInS DEF AUL T CURED BY ANY TInRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE TInS RIGIIT TO CURE YOUR DEFAULT MORE THANTIfREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTIffiR LAWSUIT INSTITUTED UNDER mE MORTGAGE DOCUMENTS, TO ASSERT ANY OTIffiR DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER mE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Connseline Aeencies listed in Aouendix C. FOR THE COUNTY in which the oronerty is located. usin!! additronal Da!!eS if necessarv). CumberlandCountv CCCS of Western Pennsvlvania.lnc. 2000 Lin!!lestown Road Harrishul1!.PA 17102 (717(541-1757 Financial Counselln!! Services of Franklin 31 West 3rd Street Wavneshoro.PA 17268 (717)762-3285 Urban Lea!!Ue of Metronolitan Harrisbul1! N. 6tb Street Harrisbul1!.PA 17101 (717)234-5925 FAX(717)234-9459 YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(717)731-9589 (Page 6 of 6) Communitv Action Comm of the Canital Re!!ion 1514 Derrv Street Harrisbure. P A 17104 (717)232-9757 FAXJ717)234-2227 Adams Countv Bousin!! Authority 139-143 Carlisle SI GettvsbuI1!. PA 17325 1717)334-1518 FAX(717)334-8326 . 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 subj ect to the penal ties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. 0 i4. 8 p In 7'\l V1 \f Ir1 r' ~ _.~) (' : "[1 0 ....... - crt ," ~ tv r , --- -.::?- _,1 ..t:::. .;,C ~ ~ ~ 1- ." , .. .. ,.. ., CJ t . UDREN LAW OFFICES. P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) NO. 06-937 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Tom L. Raudabaugh 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 2/2/06 to 4/11/06 Late charges per Complaint From 2/2/06 to 4/11/06 Escrow payment per Complaint From 2/2/06 to 4/11/06 TOTAL $104,226.08 1,402.77 67,40 604.28 $106,300.53 I hereby certify that (1) the addresses of th Defendant are as shown above, and (2) that notice ha accordance with Rule 237.1, a copy of which is attached Plaintiff and been given in hereto. J. n, ESQUIRE ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: DiJll..;[ II J. 0010 --'-'1 I INDICATED k/ aJ//~ PRO P THY .-;) ;zV: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 856-669-5400 Mortgage Electronic Registration Systems, Inc. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh Defendant(s) NO. 06-937 Civil Term TO: Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 March 29, 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. DATE of Notice: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ar en, Esqulre Woodcres Corporate Center 111 Woodc st Road, Suite 200 Cherry Hill, New Jersey 08003-3620 j . UDREN LAW OFFICES. P.C. BY: MARK J. UDREN. Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-937 Civil Term 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 folIo s: Defendant: Age: Residence: Employment: Tom L. Raudabaugh Over 18 As captioned abo Unknown Sworn to and subscribed before me this 11th day of April, 2006. ~~\qd~^O V' ',.> Na Tit e: Company: MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. 0 .l0- G r:J r'k. ..(j "t\- C> ~ C. ~ - (j( .) ~ ) ~ ...::c r -,\ ?, -- "'Q -- :::.~ r- 0-() n ;"'.1 ;-,\ IlS ..c 0- +- ...-.,-- ~ ~ +-- - F --L ...,'.-. - . ~ - '.\ - ., ~ ,,-, UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) NO. 06-937 civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $106,300.53 Interest From 4/12/06 3,008.84 to Date of Sale September 6, 2006 Ongoing Per Diem of $20.33 to actual date of sale including it sale is held at a later date (Costs to be added) $ UDREN OFFICES, P.C. ?C..J G \ T.-J i-; --&} s: ~ f:t - -kt. - ~ ~ -l.1 -() V( ---- --- ~ ...a VI --< h ~ -- C:1 ~ 6 '" V( C) ~ ~ C> ~ C) "'Q \) \) "V C>- _-I -" .~.,' f' ~ \ I I \ f 0- G:J-J ..". -D (- 0 ," ~ I ~ : ~ ()-- r - ~ ~ - D p-- t, - ~ ~ ~ . --I- - - ::'r:cJ~ - - - ...-' t{ ~ .. -, :< <: 1/\ L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-937 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From TOM L. RAUDABAUGH (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION, (2) You are also directed to attach the property of the defendant(s) not levied upou iu 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 trom paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $106,300,53 LL $,50 Interest FROM 4/12/06 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $20.33 - TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,008.84 Atty's Comm % Due Prothy $1.00 Atty Paid $119.68 Plaintiff Paid Other Costs Date: APRIL 11, 2006 CURTIS R, LONG (Seal) Prothonotary ~y: UAJ:J.-...p., _0 .7fCJ?/Uh ;- Deputy REQUESTING PARTY: Name MARK J, UDREN, ESQUlE Address: UDREN LAW OFFICES, P,C, WOOD CREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No, 04302 UDREN LAW OFFICES. P,C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 NO. 06-937 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ""-:> n-::1 , - UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 NO. 06-937 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 720 Bloserville Road. (Upper Frankford Township), Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 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. Mortgage Electronic Reg. Systems, Inc. 10790 Rancho Bernardo Road San Diego, CA 92127 C/o Terrance J. McCabe, Esquire 123 South Broad Street, Ste. 2080 Philadelphia, PA 19107 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 720 Bloserville Road (Upper Frankford Township) Newville, PA 17241 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: April 11, 2006 '- ~ < . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) NO. 06-937 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Your house (real estate) at 720 Bloserville Road, (Upper Frankford Township), Newville, PA 17241 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 $106,300.53, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call: (8561-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. 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 .'- - - ......" .' ::1 {yo SHERIFF'S RETURN - REGULAR CASE NO: 2006-00937 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS RAUDABAUGH TOM L SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon the RAUDABAUGH TOM L , 2006 DEFENDANT , at 0019:15 HOURS, on the 6th day of March at 720 BLOSERVILLE ROAD NEWVILLE, PA 17241 TOM L. RAUDABAUGH by handing to a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavi t Surcharge 18.00 9,68 .00 10.00 .00 37.68 Sworn and Subscribed to before me this ~i~ day of ~ J.()0~ A.D, ~ So Answers: ~ "~f:#' R, Thomas Kline 03/07/2006 UDREN LAW OFFICES B~,J~ U _ eputy Sherlff UDREN LAW OFFICES. P.C. BY: Mark J. Udren Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY RILL. NJ 08003-3620 856-669-5400 pleadingsludren.com Mortgage Electronic Registration Systems, Inc. ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh Defendants NO. 06-937 Civil Term MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant, Tom L. Raudabaugh by regular mail and certified mail and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant at 720 Bloserville Road, Newville, PA 17241, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit "An. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "B". 3. Said investigation was unable to determine an alternate address for said Defendant. 4. The last known address of Defendant is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said Defendant, Tom L. Raudabaugh by regular mail and certified mail and by posting the mortgaged premises. UDREN By: Mark J. Ud en, Esquire Attorney fo Plaintiff Mortgage Electronic Registration Systems, Inc. VS Tom L. Raudabaugh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-937 Civil Term R. Thomas Kline, Sheriff, who being du1y sworn according to law, states he made a diligent search and inquiry for the within named defendant to wit: Tom L. Raudabaugh, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriffs Sale and Description as NOT FOUND, as to the defendant, Tom L. Raudabaugh. Twelve attempts at service were made but no one was home, Shawn Harrison, Deputy Sheriff, who being du1y sworn according to law, states that on June 23, 2006 at 12:34 o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Tom Raudabaugh located at 720 Bloserville Road, Newville, Cumberland County, Pennsylvania according to law, So Answers: r~~-t:~/~ R. Thomas Kline, Sheriff BY \1 o~ kth Real Estate ergeant EXHIBIT A /' ~".,,:--,",.,.- , .ra-Player's Association 636 230 0558 , 7-541 P,017/047 F-961 .. Players National Locator, Inc. , i ! AFFIDAVIT OF GOOD FAITH INVESTIGATION I , ::Ii ! l' I ~ I ii 'I; Loan Number. 08010720 Attorney Firm: MARK J UDREN & ASSOCIATES CaH Number: i ;1.' . ! .,' ! Subject: Tom Raudabaugh , I 'i , i AK.A.:. Tom L Raudabaugh Last Known AddlllSB: 720 BIoHrYfIIe Road Nnvvllle, PA 17241 , I i ~8t Known Number: ( ) . Me~ Kozma, ~10!l duly sworn acoordlng to law, deposes and says: . I. : .. . ;. i , , . ..' I 1, 1m employed In the cap&clty of LocatIon SpecialiSt for Playere National Lcx:ator, Ino. . ! 2: On D8109I2008, I conduCllld an investigation Into tha whel8abouts of !he ~ nmlld ~ndant(s), The resullsofmyInvestlgallonare as foIIow8:, .. I I. I I J ! i " i' ii I CREDIT INFORMATlON- A SOCiAl SECURITY NUMBER(S):180-M06298 B. EMPLOYMENT SEARCH: We _.unable to vertfy curnnt empllIfIIlent for Tom Raudabaugh. , I C. INQUIRY OF CREDITORS:. ' , ! .. , . Credllon IncIIcldlId tIIelaat reportlld a~ for Tom Rauciabaugll Ia 720 "'0UIV11Ie Road, Newville, PA 17241 wlth no valid home number, . . , ; i INQUIRY OF TELEPHONE COMPANY. , ! . A DIRECTORY ASSISTANCE SEARCH: ," i , ." . . ! Directory _Matlcs had no IlatJng for Tom RallCllbauGh. I we cau,d (717)77.....1 and apoke wItIIa reIatJ\te who 8Iat8d Tom RaUdabaugh Ie living at 720 Bloeemlla Road, N.wvIH., PA 17241. i". , , INQUIRY OF NEIGHBORS. , I . ' I ! NlA . i INQLIRY OF POST OFFICE - ' : . A NATIONAl ADDRESS UPDATE: .. I' . Ala Of AIIgm 08, 2008 the National Chang. of Add_ (NCOA) ....no chang. for Tom R41ud..rgh from ~ BloaenrlJl. Road, N8W'Iln., PA~724r'. , MOTOR VEHICLE ~EGISTRATlON - . ., I, : I A. MOTOR VEHICLE & OW OFFICE: . .......l....l I . , w. __ "nllble to v~ curre,nt drtvere IIcenae I"'-~'-in forlT~ Ra1-baugh. OTHER INQUIRIES- '. I. I A. DEATH RECORDS: : .:mt. ' : M of AIlgm 08, 2006 the 80cIaISecurlty Admlnlalratlon .. no dad! recOrd on tile for Tom R41ud..ugIr andfor A.K.A" under Ill. 80CIItIeecurlty in r prcwldad. . ! , 8, PUBUC( UCEN15eS ( PILOT, REAL ESTATE. ere. ): ' None Found. i . I ~e , , l ,ran-Player's Association 636 Z30 0558 1 , 7-541 P,018/047 F-961 A~TYVOTER REGISTRATION: .,. wen unable to conflnn a Ilstlng with the County Vota~ Raglatratlon Ofllca. ",10NAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: . July 1974 I :1 'I l 'I - NOTARY. SEAL: . KrlIlInI II, 8colI, NlllIIY. F'llbIlc . LauII~, _ci1 Maul My.~Elqlm~ I : , I , , [' I .,'" ; Players National Locator, Inc. 174 Clarlcson RoBel, SiJite 225 St.Louis, MO 63011' Phone: (636)230-9922 Fex:!(636)2:wJossS , I l l , I' , ' I ~e VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark J. Udren Attorney for Date: ~ \- ~.d-OCl-l... UDRBN 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 pleadings8udren.com Mortgage Electronic Registration Systems, Inc, ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh Defendant NO. 06-937 Civil Term MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. , ' As set forth in the Return of Service marked Exhibit A, the Sheriff andlor Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendants by regular mail and certified mail. UDREN LAW OFFICES, P.C, By: Mark J. Attorney f . ' UDREN LAW OFFICBS, P.C. BY: Mark J. Odren Bsquire ATTY I.D. NO. 04302 WOODCRBST CORPORATB CENTBR 111 WOODCRBST ROAD, SOITB 200 CHERRY HILL. NJ 08003-3620 856-669-5400 pleadings@Udren.com Mortgage Electronic Registration Systems, Inc. ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh Defendant NO. 06-937 civil Term CERTIFICATB OF SBRVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person named herein at their last known address or their attorney of record by: x Regular First Class Mail Certified Mail Other Date Served: ~\- S \ :l..o Qi.. TO: Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 UDREN , Esquire Plaintiff By: Mark J. U Attorney for (") c:: s, ...., ~ ,,-,,, cr- (/) r'l -.:1 I ..... ,'"-'\ \.-;,-:. :~ ". -~ -~ ~ ~~ -~ r-n :;'1:( (~(~,l . "-Y, ~,'\ (] (~) ;;-::,rn '::.::1 "JE '< 9 w \.D ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND ~T'Jl: J:,' CIVIL DIVISION SEP U 8 {'DUb Mortgage Electronic Registration B Systems, Inc. Y: Plaintiff v. Tom L. Raudabaugh Defendant NO. 06-937 Civil Term o R D E R ,. A_ j AND NOW, this l "2- day of )'Oftw'~ consideration of Plaintiff's Motion and the Affidavit 2006, upon of Good Fai th investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Tom L. Raudabaugh, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Tom L. Raudabaugh at 720 Bloserville Road, Newville, PA 17241 and by posting the mortgaged premises located at 720 Bloserville Road, (Upper Frankford Township) Newville, PA 17241. DV A) ~\ (5 '1' ,:=) c'.J -, 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 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 NO. 06-937 Civil Term Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant (s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: September 27, 2006 Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: October 6, 2006 Mar /'1' , .~- , SEP 0 8 2006 lEY: flIli IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Plaintiff 06-937 Civil Term v. Tom L. Raudabaugh Defendant o AND NOW, this J ~ day of 2006, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Tom L. Raudabaugh, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Tom L. Raudabaugh at 720 Bloserville Road, Newville, PA 17241 and by posting the mortgaged premises located at 720 Bloserville Road, (Upper Frankford Township) Newville, PA 17241. BY THE COURT: ~ - I~ '~ !~- :2' Q) Oc. _,_00 I.~;_O_ X-::It'-- m4::tlAt~ :tJ<cn ::D 0 ,:..J1 t;. -<00;.;:: :J:~C<:; - :nO F ' "'O"'l - mo~ ~!!l:oo O:D~m ~om!l' a~i~ ~ 0 Z...J!-3 roNO ~ 0 S l-'.tJj t"1 I-' I-' ' 1-'0 ro {Jl :;d ~ , ro PI IU~R ~ H :t:' 1-" PI n I-'tr' I.2J I-'I-'PI ...J t1> s:: 0 N to '1iI ~:;dP' 1-'0 OJ PI ~ 0. IiI.l ::0 H '1iI '1iI OJ OJ lJ:" t" I.2J 0 '1iI ~ ~,~ 00 ~;~ o 0 .-=1.-=1 1"-'1"- ~'~ D"'" D"'" u.s. Postal Servicem CERTIFIED MAILm RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Postage $ .-=1,.-=1 0,0 0:0 0, 0 Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) 010 .-=Ii.-=l 0:0'0:0 0;0 ..D . ..D OiO oio I"-il"- Certified Fee Total Postage & Fees $ USE Flostmark Here entTo "'........... Tom L. Raudabaugh ",freet, Apt. I 1 . ~~&x^720 B oserv~lle Road citY;'SiBte~; Newville, PA 17241 PS Form 3800, June 2002 See Reverse for InstructIons rj/#{I 7JI/ 'tl !'> :'" . . . 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NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 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. BY: Mark J. Udren, Attorney for Date: October 6, 2006 /'" ,.,,~ ~~ ! SEP 0 8 2006 IBY: /U1i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Mortgage Electronic Registration Systems, Inc. Plaintiff NO. 06-937 Civil Term v. Torn L. Raudabaugh Defendant o AND NOW, this } ~ day of 2006, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Torn L. Raudabaugh, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Torn L. Raudabaugh at 720 Bloserville Road, Newville, PA 17241 and by posting the mortgaged premises located at 720 Bloserville Road, (Upper Frankford Township) Newville, PA 17241. BY THE COURT: J.2 ;..., <( .... Service of Process by ~ APSl~~:~:~~;:;i Ltd. I APSIN'fV.RNA1'10NAL J AI'S International Plaza \~~ 1800 Glenroy Rei \\,~/ Minneapolis: MN 55439-3122 ------- _/ .- AI'S File #: 079334-000 I AFFIDAVIT OF SERVICE - Individual Mortgage Electronic Registration Systems, Inc., ct. aI., Plaintiff(s) vs. Tom L. Raudabaugh, et. ai" Defendant(s) Sen'ice of PrO<<.'ss on: -Tom L.. Raudabaugh, by posting Court Case No. 06-937 Civil Term HDREN LAW OFFICES Ms. Henni CrollJlTlJlrt)' III Wood crest Rd. Suite ZOO Cherry Hili, NJ 08003-3620 State of: .V~ 7\'1~N" a mm ) ss. m County of: f't\ -a. tJ \< \;' N ) Name of Server: cl~ht<e~C~ L. Ca1<-tj J :r;;. . , undersigned, being duly swom, deposes and says that at the time of lEvice, s/he \~'as or legal age and was not a party to this action; Date/Time of Service: that on the ~day of Ser ,~........ bq.'tt., 20 0 (;, at l.:t ~J;Q:clock ....eM Place of Service: Documents Served: Service of Process on: Person Served, and Method of Senrice: Description of Person Recching Documents: Signature of Server: at 720 Bloservllle Road (Upper Frankfurt! Twp) . In Newville, P A 17241 the undersigned served the documents described as: Notice of Sheriff's Sale of Real wi Order A true and correct copy of the aforesaid document(s) \vas served on: Tom L. Raudabaugh, by posting By personally delivering them into the hands of the person to be served, By delivering them into the hands of , a person of suitable age. who verified, or who upon questioning stated, that he/she resides with TomL Raudabaugh, by posting at the place of service, and whose relationship to the person is: The person receiving documents is described as foHows: Sex _: Skin Color : Huh' Color : Facial Hair Approx. Age ; Approx.llcight Approx. Weight 'ro the best of my knowledge and belief, said person was not engaged in the US Military at the time of service, Subscribed and sw ~f NOUlry Pubhe '?5 () ,c;:? -n (J"," C> :.? (~'.c -"'l 5 o .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 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) NO. 06-937 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". 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: December 1, 2006 4904 P.C. BY: M r J. U ren, Esqu1re Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esguire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER ~11 WOOD CREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3'620 856-'669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff A~TORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) DATE: April 11, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER (5): Tom L. Raudabaugh PROPERTY: 720 Bloserville Road, (Upper Frankford ~ownship) Newville, PA ~7241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the CUmberland County Sheriff's Sale on September fi, 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. EXHIBIT A :; -: ".Ci3l ." 15 ii'; en u. CD-U1 III =15~ ~ , ,- l!' '0 ~ a:; 3l !I::, =.. 1l 0:: u. ; '~ ,I r:s .c_~ 1 ~ g.~- "'0 E.... oW c_ tl'l.~ J ~~ ~ ~:tlt CD ... =~." ::I- e( lS~ Q;; 0 ~! .s !'l!~ ~ 9l~- g C::1 2i f!!!-:' CD iiI-ii"!!! aL..:.E!>i "Cii-I'tfO:: [~l; c( l:. a,ill. 0 III .siiR Q liD~.D~ ~ ~ 00:: li~ J:V .s ~ a "9i i.= ~ 'O. 0::.; !!l.::E e'" · i oj ;.!!: ::; o::U 1:! "~ 0100 i Ii i ll"'o!E i::loi u:;!oo 0000 '" t a: ~ w (OJ 8 !z I'~ ~ > i O'w W ." i:: w - a.:J~.~ ~ ~ii!!l I IE 8. t;..~ I o I- ~J i 10U..l -a ~. !iex ~ zlii ~ !....~ ~ ~~u .. 'OCI)~ CCI)"O aI!5i ~'tIcn ~~o ~I IL;~ a~ "tii& 0:: :i3l (lju. 3l u. I I 'r-'<'; GI lCIJ i Q ll. 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CJ) c:: CD a.. 1! 15 A. i >. .a i I .I 1 :IE E o II. 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 Mortgage Electronic Registration Systems I Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 NO. 06-937 Civil Term (') ~J~ n~i~<' ~;"' ; r--..:> = = 0-" o 'Tl -l ::r; Ii nt-.. ]~ .~.J~t' C) r) -I Defendant(s) ~--" " .~-::: c:"'-' r~ . 0 :,:s fT"; --j ..c, '"l-.... ::::1 0 :';J -. -- .< The undersigned hereby verifies that he is counsel for Plaintiff' in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant (s) I by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER DATE MAILED: September 27, 2006 Tom L. Raudabaugh 720 Bloserville Road Newville I PA 17241 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN Dated: October 6, 2006 Mar EXHIBIT B UDREN LAW OFFJ:CES, P.C. BY: .Hark J. Udren, Esquire ATTY J:.D.NO. 04302 WOODCREST CORPORATE CENTER l~~WOODCREST ROAD,SUJ:TE 200 CBERRYHJ:LL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems,Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant (s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: September 27, 2006 Torn L. Raudabaugh 720 Bloserville Road Newville, PA 17241 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: October 6, 2006 Mar e EXHIBIT B - /~~ SEP 0 8 2006 BY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO'ON'l'Y CIVIL DIVISION Mortgage Electronic Registration Systems, Inc. Plaintiff ~ NO. 06-937 Civil Term v. Tom L. Raudabaugh Defendant o AND NOW, this J~ day of , 2006, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Tom L. Raudabaugh, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Tom L. Raudabaugh at 720 ~ Bloserville Road, Newville, PA 17241 and by posting the mortgaged premises located at 720 Bloserville Road, (Upper Frankford Township) Newville, PA 17241. BY THE COURT: J2 ~...., . - " EXHIBIT B l' j .~ f '1~ ~ i ! d rl n li r I I I ! ! I I I 2:...,J~ CDl\.lO ~ 0 S 1-'- tl:l tt I-' I-' . 1-'0 CD to :;u .. CD III Ii '~ It:I<:o. :t:' 1-'- III I-'tr I-' I-' III ...,J~ ~ tv lQ ~:;UP"' 1-'0 III P. ~ o ~ Ii H n I1iI o "IiI In G1 :::d H "IiI "IiI In In lJlI t" Il!1 o "IiI ~ ,~ :?' Cl)) Dc. OJ~BD ::C~::II'& m.~.-Z ~O~r- -<Oo1po :l:g, 0 ". ~ . -... .31'0 F=. ,. ,"] - ."'O~ ~~~O 1:D;.,.fm om!'> .. .~. 0;1" '. CI., P 'g' .:r .:r cc .:r .:r a a n,n ~'~ .:rl.:r IT'ilT' nin cic CICl c;a clc nln cOt cO c;c ..01..0 cia clc ~I~ _. U.S, Posta' Ser"!ce CERTiFIE: 1'J~p t~,i ::~t:::~H:': (Domestic Ma.! Orll/' No Insurallcr' vu"erage ProvlOeu, .. ~.. .. u's..e, P(l8bIge CertIfled Fee Relurr\ ~Fe8 (EndorselTllllll ~equlred) RestrICltlld DelIvery Fee (Endorsement Required) Total Postsge& F'ees $ ~arl< Here ent 0 ~APCj TotnL. Raud~augh orP08oX^ 720 BloservJ.lle Road CitY;-SiBi8;~Newvi lIe I PA 17241 --....--...-.....---- PS Form 38QC Ju,1{ 20". Sp( Rt'vC't~,C' lor IrbtrucllOfl' ~ .' EXHIBIT 13 ., ~-..'."".:"~:;. , 'i -~ t-- I i --+--~----- I , I l._cc:C..::", ...r/#Ie ffl1 'tJ ~ i ii ~ Iz COa'3 ::3i - "'.. "J1 l 2 2' ~ I N 8 .... ~ c C tr c ' .Q:I I:-' C !2:....,J!-3 (DtvO ~O:3 ....-tJ:l t" ~~. ~o (ll m ::0 , (ll $ll ttl~g, ~~~ r-o~$ll ....,J (ll ~ tv u:l ~::o::r' r-oO $ll 0. ~ i!:lO f ~ ! i !.! flU~ ...D ~~!. ~ i ~ 1m ~ lP3ii C "'" ::Dill ~~f 'S cr .. ~ CIl a :J P> ::I Q, ih CIl C C C I:-' o -J. CD :-" . . .' ~() Q ~.~ ~S' 0, g~ g: a 3 ~'.' if 0+ :r a '< .... 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NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: o c z- :L~ /'"o...:l = = 0'" a () -, o ., ~ -- 1'" mp::' rrt ? '. ) ..:"'[:', Kindly file the attached Proofs of Service with ~ a :~~~f' regar~ t~h~ .J;:-'~ ..--c captioned matter. Date: October 6, 2006 UDREN LAW OFFICES, P.C. ( BY: Mark J. Udren, Attorney for EXHIBIT B -. \- , 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. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 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: October 6, 2006 ( BY: Mark J. Udren, Attorney for EXHISIT S / I SEP 0 8 2006 IBY: 11/lL _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Mortgage Electronic Registration Systems, Inc. Plaintiff v. Torn L. Raudabaugh Defendant I NO. 06-937 Civil Term o AND NOW, this ) ~ day of 2006, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Torn L. Raudabaugh, shall be complete when Plaintiff or its counselor agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Torn L. Raudabaugh at 720 Bloserville Road, Newville, PA 17241 and by posting the mortgaged premises located at 720 Bloserville Road, (Upper Frankford Township) Newville, PA 17241. BY THE COURT: ~ :.- EXHIBIT B :t ~/, .. Service of Process by APS International, Ltd. 1-800-328-7171 Mortgage Electronic Registration Systems, Inc" et. ai., Plaintiff(s) vs. Tom L. Raudabaugh, et. al., Defendant(s) r- I APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 079334-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Tom L. Raudabaugh, by posting Court Case No. 06-937 Civil Term UDREN LAW OFFICES Ms, Henni Crommarty 111 W oodcrest Rd, Suite 200 Cherry Hill, NJ 08003-3620 -St~te of: et.hJ ~ r l,,~..., ~ a ) ss. County of: (t\ ~ tJ \< \, t-J ) Name of Server: d3~<'t.)C~ L Ca.(C..tj J ~ . , undersigned, being duly sworn, deposes and says that at the time of ,fEvice, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the ~B day of ~~ ~\AA 10 Q. vt , 20 0 G, at I ~ : J ~c1ock -E.M Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: at 720 Bloserville Road (Upper Frankford Twp) , m Newville, PA 17241 the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property wi Order A true and correct copy of the aforesaid document(s) was served on: Tom L. Raudabaugh, by posting D 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 Tom L. Raudabaugh, by posting at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex _; Skin Color ; Hair Color ; Facial Hair Approx. Age ; Approx. Height Approx. Weight 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. ~- PdIID ~~~ '. EXHIBIT B o c <: (_. :::~ --.... .-< f'o..) = c""' <;;n o rr; n I .&:'" o -n :r:n m,- -om :'J9 8~1 15 ::D -~ (") om '--j ~ -0 ~ --- w Q) 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 Bank of New York Tr Co N A Tr/aifis the grantee the same having been sold to said grantee on the 6th day ofDec A.D., 2006, under and by virtue of a writ Execution issued on the 11 th day of April, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 937, at the suit ofMtg Elec Reg Systems Inc against Tom L Raudabaugh is duly recorded in Deed Book No. 278, Page 2301. IN TESTIMONY WHEREOF, I have hereunto set my hand / 9 '-tk and seal of said office this ~ tiA if day of , A.D. c9f1CJ7 ecorder of Deeds Mortgage Electronic Registration Systems, Inc. VS Tom L. Raudabaugh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-937 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states he made a diligent search and inquiry for the within named defendant to wit: Tom L. Raudabaugh, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriff's Sale and Description as NOT FOUND, as to the defendant, Tom L. Raudabaugh. Twelve attempts at service were made but no one was home. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 23,2006 at 12:34 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Tom Raudabaugh located at 720 Bloserville Road, Newville, Cumberland County, Pennsylvania according to law. 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 December 06,2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for The Bank of New York Trust Company N.A. as successor to JP Morgan Chase Bank, as Trustee by Residential Funding Company, LLC fJk/a Residential Funding Corporation, Attorney in Fact, (MERS is actinglhas acted as the agent for the real party in interest or beneficial owner). It being the highest bid and best price received for the same, The Bank of New York Trust Company N.A. as successor to JP Morgan Chase Bank, as Trustee by Residential Funding Company, LLC flk/a Residential Funding Corporation, Attorney in Fact, (MERS is actinglhas acted as the agent for the real party in interest or beneficial owner) of 4828 Loop Central Drive, Houston, TX 77081, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$1,004.61. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 20.14 15.00 15.00 30.00 10.00 .50 1.00 35.20 Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 15.00 20.00 20.00 401.00 328.40 19.31 25.00 41.50 $ 1,027.05 So ~w:ll' #-4 ~~~ . . , R. Thomas Kline, Sheriff B\\"b~ Real Estate ergeant .; .01 \'~J. o~ ~~ o.D~ k?J)'~ rl ~ \. '? (.!'\cP ' '* ,9 I-\L.\ C~ \1>'1>0 p" ; , .-4 " " ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER ~~~ WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tom L~ Raudabaugh 720 Bloserville Road Newville, PA 17241 NO. 06-937 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ~, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 720 Bloserville Road. (Upper Frankford Township), Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s); Name Address Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 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 f' .'" l I 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Mortgage Electronic Reg. Systems, Inc. 10790 Rancho Bernardo Road San Diego, CA 92127 C/o Terrance J. McCabe, Esquire 123 South Broad Street, Ste. 2080 Philadelphia, PA 19107 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 720 Bloserville Road (Upper Frankford Township) Newville, PA 17241 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: April .11, 2006 b 0 :t d Z I UdV qOOZ ~d 'All1nOJ ONV1Cl38~n:) .:L:iIH3HS 3Hl jO 3:lI.:UO ~ UDREN LAW OFFICES, P. C. BY: Mark J.. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER ~J.J. WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856--669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 7708l Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 1724l Defendant (s) NO. 06-937 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~O: Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Your house (real estate) at 720 Bloserville Road, (Upper Frankford Township), Newville, PA l724l 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 $106,300.53, 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'l'HE 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 '1'AKE 'THIS PAPER '1'0 YOUR LAWYER A'1' ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT iAFFORD ONE, GO 'TO OR 'TELEPHONE THE OFFICE LISTED BELOW '1'0 FIND 0U'l' WHERE YOU CAN GET LEGAL EELP. 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 bO :( d Z I UdV qOOl 'lid ')dNnO::J llNV'Hf:l8..HlJ .:L:HH3HS 3Hl ;/0381.:1.:10 ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 1.11. WOODCREST ROAD, SUITE :200 CHERRY BILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-937 Civil Term v. Tom L. Raudabaugh 720 Bloserville Road Newville, PA 17241 Defendant(s) DATE: April 11, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER (S): Tom L. Raudabaugh PROPERTY: 720 Bloserville Road, (Upper Frankford Township) Newville, PA 1.'7241. Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff1s Sale on September 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. 01 :( d Z I UdV qOOZ 'fd 'AINflO;J ONV'I~38Wn3 :HIH3HS 3Hl .::10 3:l1.:f.:lO ,~ ~ <# , LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED ACCORDING TO A SURVEY BY STATLER AND LAHR DATED JULY 24,1984 AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE BLOSERVll..LE ROAD, A/KJA PA A-3749, AT LINE OF LANDS NOW OR FORMERLY OF A. SCOTT CLARK AND JUDITH A. CLARK; THENCE ALONG SAID LINE SOUTH S5 DEGREES 30 MINUTES WEST A DISTANCE OF 195~OO FEET TO A POINT ON THE EASTERLY SIDE OF A 10 FOOT WIDE ALLEY; THENCE ALONG SAID ALLEY NORTH 4 DEGREES 30 MINUTES WEST A DISTANCE OF 49.5 FEET TO A POINT ON THE SOUTHERLY LINE OF LANDS NOW OR FQRMERL Y OF W AYNE,C. ANDERSON ANDSONDRA L. ANDERSON;THENCEALONGSAIDLANDSNORTHS5DEGREES31MINUTES EAST A DISTANCE OF 117.20 FEET TO A POINT; THENCE NORTH 4 DEGREES 30 MINUTES WEST A DIST.t\.NCE OF 2.20 FEET TO A POINT; THENCE NORTH S5 DEGREES 30 MINU1I'ES EAST A DISTANCE OF 15.84 FEET TO A POINT; THENCE sourn:4 DEGREES 36 MINUrESEASTA-DISTANCE OF 2.2() FEET TO A POINT; THENCE NORTHSS DEGREES 31 MINUTES EAST A DISTANCE OF ~1.96 FEET TO A POINT IN THE BLOSERVILLE ROAD; THENCE ALONG THEBLOSERVILLE ROAD SOUTH 4 DEGREES 30 MINUTES EAST A DISTANCE OF 49..5 FEET TO A POINT, THE PLACE OF BEGINNING. BEING KNOWN AS LOT =#15 IN THE VILLAGE OF BLOSERVILLE AND A SMALL PORTION OF THE LOT IMMEDIATELY TO THE NORTH OF THIS LOT. BEING KNOWN AND NUMBERED AS 720 BLOSERVILLE ROAD, NEWVILLE, PA 17241, FORMERLY KNOWN AND NUMBERED AS R.D. =#3, BOX 354 (FORMERLY DESIGNATED AS R.D. #3, BOX 6SA.) BEING KNOWN AS: 720 BLOSERVILLE ROAD (UPPER FRANKFORD TOWNSHIP) NEWVILLE, PA J. 724J. PROPERTY ID NO. : 43-11-3069-016 TITLE TO SAID PREMISES IS VESTED LAWRENCE A. TAYLOR AND CAR IN TOM L. RAUDABAUGH BY DEED FROM RECORDED 5/2/03 IN DEED BOg;~56LpA~~Y~~~'3 .HIS WIFE DATED 4/30/03 WRIT OF EXECUTION and/or ATTACHMENT . ~ COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-937 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From TOM L. RAUDABAUGH (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $106,300.53 L.L. $.50 Interest FROM 4/12/06 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $20.33 - TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,008.84 Arty's Comm % Due Prothy $1.00 Arty Paid $119.68 Other Costs Plaintiff Paid Date: APRIL 11, 2006 CURTIS R. LONG (Seal) prothon~ ~ -- JJ.-e ~. 7'lza-kJ...r-- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY IDLL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ill No. 04302 Real Estate Sale # 25 On May 17, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, P A Known and numbered as 720 Bloserville Rd., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 17, 2006 By: ~6Jw~ Real i&4te Sergeant bO :( d Z I UdV qOal Vd 'A1NnOJ UN~1(J38Wn:J .:l.:lIH3HS 3Hl .:10 3:)1J.:10 , , y 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 ofthe 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 Pliltriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily an4l0r Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #25 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ... ~ _. r .....1. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA 55. 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. TO AND SUBSCRIBED before me this day of August. 2006 NOT ARIA SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 200!l REAL ESTATE SALE NO. 25 Writ No. 2006-937 Civil Mortgage Electronic Registration Systems, Inc. vs. Tom L. Raudabaugh Atty.: Mark J. Udren LEGAL DESCRIPTION ALL TIiAT CERTAIN tract or par- cel of land situate in Upper Frankford Township, Cumberland County, Pennsylvania. bounded and described according to a survey by Statler and Lahr dated July 24, 1984 as follows, to wit: BEGINNING at a point in the BloseIVille Road. a/k/a PA A-5749. at line of lands now or formerly of A Scott Clark and Judith A. Clark; thence along said line South 85 de- grees 30 minutes West a distance of 195.00 feet to a point on the east- erly side of a 10 foot wide alley; thence along said alley North 4 de- grees 30 minutes West a distance of 49.5 feet to a point on the south- erly line of lands now or formerly of Wayne C. Anderson and Sondra L. Anderson; thence along said lands North 85 degrees 31 minutes East a distance of 117.20 feet to a point; thence North 4 degrees 30 minutes West a distance of 2.20 feet to a point; thence North 85 degrees 30 minutes East a distance of 15.84 feet to a point; thence South 4 de- grees 30 minutes East a distance of 2.20 feet to a point; thence North 85 degrees 31 minutes East a dis- tance of 61.96 feet to a point in the Bloserv1lle Road; thence along the BloseIVille Road South 4 degrees 30 minutes East a distance of 49.5 feet to a point, the place of beginning. BEING KNOWN AS lot #15 in the Village ofBloseIVille and a small por- tion of the lot immediately to the north of this lot. Being known and numbered as 720 BloseIVille Road, Newville, PA 17241, formerly known and numbered as R.D. #3, Box 354 (formerly designated as R.D. #3, Box 68A). BEING KNOWN AS: 720 BloseIVille Road, (Upper Frankford Township), Newville, PA 17241. PROPERlY ID NO.: 43-11-3069- 016. TITLE TO SAID PREMISES is vested in Tom L. Raudabaugh by deed from Lawrence A. Taylor and Carolyn L. Taylor, his wife dated 4/ 30/03 recorded 5/2/03 in Deed Book 256 page 4383.