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HomeMy WebLinkAbout06-1558 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 .com Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff v. Glenn E. Burdge Jane G. Burdge a/k/a Jana G Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. O t. - I S SQ 0 U. 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 o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las 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 o 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 o 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 O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address 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. /s/ 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: Bank United of Texas FSB Assignments of Record to: GE Capital Mortgage Services, Inc. Recording Date: 9/30/93 Book: 455 Page: 478 Assignments of Record to: Wells Fargo Bank, N.A. Recording Date: 4/25/05: Book: 716 Page: 4862 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: Lot 2 Hickory Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Shippensburg Township COUNTY: Cumberland DATE EXECUTED: 10/1/92 DATE RECORDED: 10/5/92 1092AGE: 667 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 1/24/06 Principal of debt due $64,166.22 Unpaid Interest at 7.87500 from 8/1/05 to 1/24/06 (the per diem interest accruing on this debt is $20.20 and that sum should be added each day after 1/24/06 3,575.40 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of 36.05 should be added in accordance with the terms of the note each month after 1/24/06 180.25 Attorne s Fees (anticipated and actual to 5°s oy principal) 4,708.31 TOTAL $103,235.18 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 $103,235.18 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. A Mark J. Udreh, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL that certain tract of Sound situate In Shlppensburg Township, Cumberland Pennsylvania, being improved with a single family dwelling house, and more particularly and described as follows: . BEOP44ING at a point oh the eastern edge orHlckory Lane at common corner ofLq No. 1, Section "N", and Lot No. 2, Section "N", as shown on Subdivision Plan for G dt C Associates dated August 20, 1991; thence along Lot No. 1 South 35 degrees 51 minutes 53 seconds Last 150.00 feet to a point; thence along other lands now or formerly of Galen S. AW North 54 degrees 08 minutes 07 seconds East 111.80 feet to a point; thence along a proposed . public street North 39 degrees 51 minutes 53 seconds West 115.00 feet to a polo0 thence by a- eurve to the left having a radius of 35.00 feet, a chord bearing of North 80 degrees 51 minulq seconds East, an are distance of 54.98 feet to a point on the eastern edge of Hickory Lane; along the eastern edge of HickoryLane South 34 degrees 08 minutes 07 seconds West 76,60 k/ to a point, the point and place of BEGINNING.,' BEING all of Lot No, 2, Section "N", on Subdivision Plan for G & C Associates dated August 20, 1991 end recorded in Cumberland County Plan Book 64, Page 60, CONTAINING 0.3790 acres, more or less. r Jells Fargo Home Mortgage P.O. Box 1225 Charlotte, NC 28201-1225 December 19, 2005 GLENN E BURDGE 204 HICKORY LN SHIPPENSBURG PA 17257 000142193EACt91 11111111111111111111111111111111111 7100 4047 5100 2145 9642 RE: Wells Fargo Home Mortgage Loan Number 0010457042 Mortgagor(s): Glenn E. Burdge Jana G. Burdge Mortgaged Premises: Lot 2 Hickory L Shippensbur, PA 17257 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice exulains how the oroeram works. MEET WITH A LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTfNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO 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 HIPOTECA. EXHIBIT This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer, HOMEOWNER'S NAME(S): Glenn E Burdee Lana G Burdee PROPERTY ADDRESS: Lot nShipp s ur, PA 17257 LOAN ACCT. NO.. 0010457042 ORIGINAL LENDER: CURRENT LENDER/SER VICER: WELLS FARGO BANK, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM Y BE IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. or toreciosure on your mortgage you must arrange and attend a agencies listed at the end of this days after your -- Under the Act, you are entitled to a temporary stay 0) days from the date of this Notice. During that time meeting with one of the consumer credit counseline If you meet with one of the consumer credit lender may NOT take action against you your intentions. to schedule one er i T A I T E - Your mortgage is in default for the reasons [ ort ater in t is Notice (see o owing pages or specific information about the nature of your fault.) If you have tried and are unable to resolve this problem with the lender, you have the ;ht to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance ogram. I o do so, you must fill out, sign and file a completed Homeowner's Emergency ;s[stance Program Application with one of the designated consumer credit counseling agencies ted at the end of this Notice. Only consumer credit counseling agencies have applications for program and they will assist you in submitting a complete application to the Pennsylvania )using Finance Agency. Your application MUST be filed or postmarked within thirty (30) days your face-to-face meeting. YOU MI IST 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. 000,43/636 AGENCY ACTION - Available funds for emergency mortggage assistance are very limited. They will be is urse y rte Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES O&LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). at: - - The MORTGAGE debt held by the above lender on your property A. YOU HAVE. NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: riff F P oni . n...Th,, ?nn S2.820.75 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: --If means that the entire o lose the chance to pay i due is not made within legal action to foreclos, IS .gins iegai were actu II have to Any att, the default within THIRTY (30) DAYS payment of the total amount past to instruct its attorneys to start UPON - - The mortgaged property will be sold by the Sheriff refers your case to its attorneys, but you cure the delinquency against ou you will still be required to pay the reasonable up to eso.bo. However, if legal proceedings are started finable attorney's fees actually incurred by the lender even if vill be added to the amount you owe the lender, which may OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance an a of er sums ue under the mortgage. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 OOD142/038 If You have not mortgage. Gurtng, your default it same position as it you had never your mortgage to EARLIEST POSSIRII SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (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 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. Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home Mortgage 3476 Stateview Boulevard Fort Mill, SC 29715 1-800-766-0987 803-396-6063 Clarice Townsend FFFE T OF SH RIFF'S $A LL - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or _ may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT. HOWEVER YOU DO NOT HAVE THIS RIGHT TO CtURE YOUR DEFAULT MORE THAN THREE' TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 'The Pennsylvania Housing Finance Agency can be reached'I'OLL FREE at 1 (800) 342.2397. Wells Fargo Home Mortgage P.O. Box 1225 Charlotte, NC 28201-1225 December 19, 2005 JANA G BUROGE 204 HICKORY LN SHIPPENSBURG PA 17257 000143/938AC191 INII?InIIIIIIA!191?II 7100 4047 5100 2145 9659 RE: Wells Fargo Home Mortgage Loan Number 0010457042 Mortgagor(s): Glenn E. Burdge Jana G. Burdge Mortgaged Premises: Lot 2 Hickory L Shippensbur, PA 17257 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the vrot ram works. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTTNUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CONTENDO 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 HIPOTECA. XH113 -, This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. HOMEOWNER'S NAME(S): Glenn E. Burdae Lana B rrdpe PROPERTY ADDRESS: Lnt 2 Hicknrv l Shippensbur PA 17257 LOAN ACCT. NO.: 0010457042 ORIGINAL LENDER: CURRENT LENDER/SERVICER: WELLS FARGO BANK, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1953 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. BARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay o orec osure on your mortgage or 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 counselor aggencies listed at the end of this Notice. THIS MEETINC MUST OCCUR WITHIN 77IE NET 30 DAYS. IF YOU DO NOT APPLY FOR EMERGEN Y M RTGAGE ASSISTANCE YOU MUSIUR "HOW TO C[IRE YO QXQ[TRh.40KIGACE till TA) -1 MORTGA .E D .FA II I EXPLAINS OW TO BRING YOUR MORTGAGE UP TO DATE. T CONSIZMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies iste at t e en o t is notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and tele hone numbers f designated consum r credit n li agencies for county the or Which the pro2erty is I is on y necessary to schedule one ace-to-face meeting. Advise your lender immediate y o your intentions. " T E A I A - Your mortgage is in default for the reasons MOR set ort ater in t is Notice (see following pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MI LST 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, FORECLO? MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 000143/9]6 Available funds for emergency mortgage assistance are very limited. They will e is arse y t e Agency under the eligiby criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES O&LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) I HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). RE OF THE DFFAI IIT-- The MORTGAGE debt held by the above lender on your property at: I of 2 I-iicknrv I A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the foilowin amounts are now past due: oaober 445 -December 2045 V A70.75 - - If you do not cure the default within THIRTY (30) DAYS means that the entire outstanding a lose the chance to pay the mort gag due is not made within THIRTY (3a0)ii legal action to foreclose upon Your m. icguis iegai proceeeings t were actually incurred, sill have to pay all reasoi D. Any attorney's fees w reasonable costs. if you Trent of the total-amount past instruct its attorneys to start - - The mortgaged property will be sold by the Sheriff (our case to its attorneys, but you cure the delinc{uency you you will still be required to pay the reasonable SO.00. However, if legal proceedings are started torney's_fecs actually incurred by the lender even if OTHER LENDER REMEDIES - - The lender may also sue you personally for the unpaid principal balance an a of cr sums ue under the mortgage. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: 11 , , 000 u3/936 -- If you have not mor a e. airing, your acra n: in same position as if you had never your mortgage to -- It is estimated that the earliest date that such a UM Ri E SHERIFF'S SALE ATE Sheri f's Sale of the mort gaged property could be held would be approximately six (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 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. Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home Mortgage 3476 Stateview Boulevard Fort Mill, SC 29715 1-800-766-0987 803-396-6063 Clarice Townsend ?4F?FF(T OF ?HERIFES LE - You should realize that a Sheriff's Sale will end your ownership of [ gage property an your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ may or - may not sell or transfer your home to a Buyer or transferee Who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX#(717)234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Adams County [-lousing Authority 139-143 Carlisle St. Getrysburg, PA 17325 (717)334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. Wells Fargo Home Mortgage P.O. Box 1225 Charlotte, NC 28201-1225 December 19, 2005 GLENN E BUROGE LOT 2 HICKORY L SHIPPENSBUR PA 17287 71D0 4047 5100 2145 9666 0001441906ee,91 RE: Wells Fargo Home Mortgage Loan Number 0010457042 Mortgagor(s): Glenn E. Butdge Jana G. Burdge Mortgaged Premises: I.ot 2 Flickoryy L Shippensbur, PA 17257 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIV1ENDO EN SU CASA. ST NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA f PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. HOMEOWNER'S NAME(S): Glenn E. Burdge Lana G. Buie PROPERTY ADDRESS: S ippens ur, PA 17257 LOAN ACCT. NO.: 0010457042 ORIGINAL LENDER: CURRENT LENDER/SERVICER: WELLS FARGO BANK, N.A. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. you HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM on your - Under the Act, you are entitled to a 0) days from the date of this Notice. ' meetme with one of the consumer cr - If you meet with lender may NOT meeting. your it is only necessary to your intentions. of the consumer credit action aeainst you one PPLI F MORTGAq?i - Your mortgage is in default for the reasons set ort ater in this Notice see o owing pages or 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 MortTage Assistance Program. o do so, you must fill out, sign and file a completed Homeowner's mergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MI JS 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. 000 14 41939 ? T Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES &LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). at: - - The MORTGAGE debt held by the above lender on your property A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: October 2005 - December 2005 $2.$20.25 Other charges (explainhtemize : Late Char es $134.45 Other Fees (if applicable( $43.34 Su ense Amount 40.00 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: - - If you do not cure the default within THIRTY (30) DAYS to exercise its riehts to accelerate the morteaee debt. This means that the entire lose the chance to pa; due is not made with Icgal action to fore[ payment of the total amount past to instruct its attorneys to start lE IS FORECLOSED UPON - - The mortgaged property will be sold by the Sheriff ige debt. teen er re ers your case to its attorneys, but you cure the delinquency ins legal proceedings againsty ou yyou will still be required to pay the reasonable -ere actually incurred, upp to y50.?10. However, if legal proceedings are started have to pay all reasonable attorney's fees actually incurred by the lender even if Any attorney's fees will be added-to-the amount you owe the lender, which may OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance an a of er sums uc under the mortgage. WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 . a 0001441.3• Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home Mortgage 3476 Stateview Boulevard Fort Mill, SC 29715 1-800-766-0987 803-396-6063 Clarice Townsend EFFECT OF 4HERIFF' SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the tender at any time. ASSUMPTION OF MORTGAGE - You _ may or `may not sell or transfer your home to a buyer or transferee w o will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO C=URE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. 6 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FARLI ST POSSIBLE SHERIFF'S SALE DATE. -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (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 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. PROGRAM CCCS of Western Pennsylvania, Inc. 2000 LinglestoNvn Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234.5925 FAX# (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717)334-8326 'rhe Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. , , } A Wells Fargo Flome Mortgage P.O. Box 1225 Charlotte, NC 28201-1225 December 19, 2005 JANA G BUROGE LOT 2 HICKORY L SHIPPENSSUR PA 17247 7100 4047 5100 2145 9673 0001451935Am91 RE: Wells Fargo Home Mortgage Loan Number 0010457042 Mortgagor(s): Glenn E. Burdge Jana G. Burdge Mortgaged Premises: Lot 2 Hickory L Shippensbur, PA 37257 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains ow t e program works. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. ST NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCTON INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRBA. 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 H?POTECA. °F 9ile.-)-r This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. HOMEOWNER'S NAME(S): Shippensbur,'PA 17257 LOAN ACCT. NO.: 0010457042 ORIGINAL LENDER: CURRENT LENDERISERVICER: WELLS PARGO BANK, N.A. PROPERTY ADDRESS: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. IEPRARY STAY OF FOREPLQ?URA - Under the Act, you are entitled to a temporary stay irec osure on your mortgage or thirty 0) days from the date of this Notice. During that time must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling ties listed at the end of this Notice. THIS MF.F.TING MUST OCCI iR wrrum THp wpV-r If you meet with one of the consumer credit lender may NOT take action against you your it is only necessary your intentions. " - Your mortgage is in default for the reasons set ort ater in t is Notice (see following pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU M.US_T 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. 9 . A f 00 0 14519 36 Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility -------- established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives pour application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES OkL.Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). - - The MORTGAGE debt held by the above lender on your property at: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: - „1 WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 THIRTY (30) DAYS of the TO THE LENDER. WHICH DAY You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: - If means that the entire lose the chance to pa; due is not made with legal action to foreclt IF THE MORTGAG at were acts will have to ]0. Any att wi the THIRTY (30) DAYS payment of the total amount past to instruct its attorneys to start UPON - - The mortgaged re ers your case to its att againsty ou You will still up to y50.by. However, nable attorney's fees actus ill be added to the amoun will be sold by the Sheriff .t you cure the delinquency d to pay the reasonable oceedings are started ed by the lender even if OTHER LENDER REMEDIES - - The lender may also sue you personally for the unpaid principal balance an a of er sums ue under the mortgage. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 0001/9/999 Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home Mortgage 3476 Stateview Boulevard Fort Mill, SC 29715 1-800-766-0987 803-396-6063 Clarice Townsend EFFECT OF SHE. You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You , may or _ may not sell or transfer your home to a uyer or trans erce who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE' TIMES IN ANY CALENDAR YEAR,) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. 0 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. LE SHERIFF'S SALF DATE -- It is estimated that the earliest date that such a Sheriffs Sale o the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be scat 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. ? tr r PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglcstovvn Road Harrisburg, PA 17102 (717) 541.1757 FAX# (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. V, . > V E R I F I C A T I O N 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. \ 1 ^ \ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. , n r? n ? I ?i UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) NO. 06-1558 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) Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge 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 $103,235.18 Interest Per Complaint 1,838.20 From 1/25/06 to 4/25/06 Late charges per Complaint 108.15 From 1/25/06 to 4/25/06 TOTAL 5105.181_,;x I hereby certify that (1) the addresses of?he Plaintiff and Defendant are as shown above, and (2) that notice as been given in accordance with Rule 237.1, a copy of which is attar ed hereto. CES, P DAMAGES ARE HEREBY ASSESSED AS DATE: torney for Plaintiff NDICATE PRO P O HY 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 06003 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, N.A. Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) TO: Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-1558 DATE of Notice: April 13, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI 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. War r.-t en, moire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, N.A. Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) TO: Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-1558 DATE of Notice: April 13, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O 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, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O 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. ?s?/,? . Mark 6 Uaren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: NARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers, Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Glenn E. Burdge Over 18 As captioned above Unknown Jane G. Burdge a/k/ Over 18 As captioned above Unknown Sworn to and subscribed before me this 25th day of April, 2006,. Title:' Company: G. Burdge ..rai..u . , ..Y . ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. wotad"*Aj'f Holm NJ= OF KEW J90 Cmnh tae fths4/16/200@ V 9.J V N w s r V r> G- n r Y^ry 4 w N r-) 'Il -i t _ry 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 099-999-ssnn Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From 4/26/06 to Date of Sale September 6. 2006 Ongoing Per Diem of 20.20 to actual date of sale including if sale is held at a later date (Costs to be added) OFFICES, P.C. $105,181.53 2.706.80 VlCk? ATTORNEY FOR PLAINTIFF S T- Q C C ? ? o r S` o o S A. Lei C cn Ci C C C C? t C f Y rJ ?Y_ C.> CD WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1558 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From GLENN E. BURDGE AND JANE G. BURDGE A/K/A JANA G. BURDGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $105,181.53 L.L. $.50 Interest FROM 4/26/06 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $20.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm % Atty Paid $143.60 Plaintiff Paid Date: APRIL 28, 2006 Due Prothy $1.00 Other Costs ZTIS L NG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 NO. 06-1558 Defendant(s) C E R T I F I C A T 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. P. C. J. Udren, ESQU?RE NEY FOR PLAINTIFF r ' ") ` =` ?Sl ' =,:? F?" ?,? .,,_i s.: ? r- ,; ,„_ , , ` ?; 4 ^- ' •? ?, P _ a UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge ' 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: Lot 2 Hickory Lane, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 204 Hickory Lane Shippensburg, PA 17257 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. Allfirst Bank See Caption above. 25 South Charles St Baltimore, MD 21201 GE Mortgage Services, LLC 3476 Stateview Blvd Fort Mills, SC 29715 C/o Phelan Hallinan & Schmieg 1617 JFK Blvd, Ste 1400 Philadelphia, PA 19103 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section 1 Courthouse Sq, Carlisle, PA 17013 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 Lot 2 Hickory Lane Shippensburg, PA 17257 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. / LAW OFFICES,/P.C. DATED: April 25, 2006 J -Udren, ESQ. nev for Plaintiff r C7 ^ = r- 4- T1 ?? X11 ?_ R? _; i ?- G? i ; ' t `a :? s? :•' .< ?r UDREN LAW OFFICES, P.C. y BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 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 $105,181.53, 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 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 SPHERE 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 _? ?: ? ,-; _? ?- ? 3?", .? 7 Ki ? o? ? ';' , c::' _. 4`. i i I? . t? c- z f' _? N '-%?. -. C? 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 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff v. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 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 $105,181.53, 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 izmediate 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.) J r 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 rJ ?? ?f may. t_...', ?l Ci1 ?? y11) ?? I J CIO l (a r )t co \ SHERIFF'S RETURN - REGULAR CASE NO: 2006-01558 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS BURDGE GLENN E ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BURDGE GLENN E the DEFENDANT at 1807:00 HOURS, on the 21st day of March 2006 at 204 HICKORY LANE SHIPPENSBURG, PA 17257 by handing to JANE BURDGE, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 17.60 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 45.60 03/22/2006 UDREN LAW OFFICE Sworn and Subscribed to before By: me this %Q day of A. D. Prothonotary s CASE NO: 2006-01558 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK VS BURDGE GLENN E ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BURDGE JANE G AKA JANA G BURDGE the DEFENDANT , at 1807:00 HOURS, on the 21st day of March 2006 at 204 HICKORY LANE PPENSBURG, PA 17257 JANE BURDGE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 nn Sworn and Subscribed to before me this 14'- day of N1.u.y_ ts-0 4 A. D. So Answers: ?,/ryr?-cam ??.? R. Thomas Kline 03/22/2006 UDREN LAW OFFICE By: y Prothonotary „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 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-1558 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 Praeci.pe 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 t fo t b/.Section le C.P. 3129. This Affidavit is made subject to the penal ies o 18 Pa C4904 relating to unsworn falsification to author tie . Dated: September 1, 2006 UDREA L* Okt CES, P.C. BY: Maw-J. ren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. :COURT OF COMMON PLEAS 3476 Stateview Blvd :CIVIL DIVISION Ft. Mill, SC 29715 €Cumberland County Plaintiff v. NO. 06-1558 Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) DATE: April 25, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge PROPERTY: Lot 2 Hickory Lane, Shippensburg, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 6, 2006, at 10:00 am, at the . Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A T ? tll C6 E 1 . dog £ c m v ' D ? r 0 3 or ti ? • !6 d e p '•? SC C Y go Ir LL , m G? ? C E E..E jq V ?. 4 ? o° D ? L•? at < .. w _ 3 _. N m W ?a ¢?- og ? 0 2 2V ve i l o Y ? ?q J t ? ? O ?Ll CY 0 13130 d w Qao p 8 w > b r " > n , Q co 0- p ' O z T 0 r- LL z ? to a o 2 ?- ? 2 ? T H = U a LL CL ? Ca D z , Fa z T O CL O LU W =? d m W V ?- a y? Q w to U x Q m c S2 ? 4 M w ¢ ~r m ?¢ N w ? to a o a ? w N.. OQmx V W W z c ZM c 0 cc g Otv ?^ ad U:C V J Hm U. L 89 L -i S' d. cu CL ? C7 +r, D co U .- N? U) U LL Co p J ?WGT Zu w i Q¢ Q nZ v? 8 Q? W Q m ¢r a VgIC z IC ? o CD SO M v v QW a2 m 'nc m roc w co) C7 W 'CI) O ' E Z w 8r $_ c z I o ?w -w 4 0 fL Za JJ c S E off' ?'; r V 7 O ou 1- O Q W r?D IL LS J w J ? W V c H C ) F- CD a c t3 » r E az w D m o OD ts or LU m D Z N -61 ?? vg = 9 E (D t ? a U) : E 8 zQ0 CD Q ' j O T N c? e L/) N OD IT T T T T T J C a a° m O .1C C d a O V to Li a _rn RS a LL r- co co U. ^V/ I.Y. EXHIBIT A Wells Fargo Bank, NA VS Glenn E. Burdge and Jane G. Burdge In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1558 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 26, 2006 at 3:20 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge, by making known unto Glenn E. Burdge, personally and husband of Jane G. Burdge, at 204 Hickory Lane, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2006 at 11:05 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge located at 204 Hickory Lane, Shippensburg, Pennsylvania 17257 according -to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge, by regular mail to their last known address of 204 Hickory Lane, Shippensburg, Pennsylvania 17257. These letters were mailed under the date of June 26, 2006 and never returned to the Sheriffs Office. So An s: R. Thomas Kline, Sheriff BY Real Estate Sdrgeant EXHIBIT B CD Wells Fargo Bank, NA VS Glenn E. Burdge and Jane G. Burdge In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1558 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 26, 2006 at 3:20 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge, by making known unto Glenn E. Burdge, personally and husband of Jane G. Burdge, at 204 Hickory Lane, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2006 at 11:05 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge located at 204 Hickory Lane, Shippensburg, Pennsylvania 17257 according -to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge, by regular mail to their last known address of 204 Hickory Lane, Shippensburg, Pennsylvania 17257. These letters were mailed under the date of June 26, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Mark Udren. Sheriff's Costs: Docketing $30.00 Poundage 80.00 Advertising 15.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Mileage 35.20 Levy 15.00 Surcharge 30.00 Law Journal Patriot News Postpone Sale Share of Bills 413.00 287.60 20.00 19.31 $ 961.61 ? /02,191 bL swe R. Thomas Kline, Sheriff BY U0 i,^ Real Estate ' ergeant C5v cx J 1, 6'? j, irc78AT ` .r . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. :COURT OF COMMON PLEAS 3476 Stateview Blvd :CIVIL DIVISION Ft. Mill, SC 29715 ?Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: Lot 2 Hickory Lane, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 204 Hickory Lane Shippensburg, PA 17257 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 J 4. Name and address of the last recorded holder of every mortgage of record: Name. Address Plaintiff herein. Allfirst Bank See Caption above. 25 South Charles St Baltimore, MD 21201 GE Mortgage Services, LLC 3476 Stateview Blvd Fort Mills, SC 29715 C/o Phelan Hallinan & Schmieg 1617 JFK Blvd, Ste 1400 Philadelphia, PA 19103 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section 1 Courthouse Sq, Carlisle, PA 17013 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 Lot 2 Hickory Lane Shippensburg, PA 17257 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. / UDRE,N LAW OFFICES,/P.C. DATED: April 25, 2006 M J -Udren, ESQ . A ornev for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY'I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. :COURT OF COMMON PLEAS 3476 Stateview Blvd ;CIVIL DIVISION Ft. Mill, SC 29715 :Cumberland Countv Plaintiff V. :MORTGAGE FORECLOSURE Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 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 $105,181.53, 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 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 UDREN LAW OFFICES, P.C. BY: ,Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, N.A. 3476 Stateview Blvd Ft. Mill, SC 29715 Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 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 $105,181.53, 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 THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL that cumin tract of Sound situate in Shippetuburg Township, Cumberland Cm 4i Peonaytvan* being improved. with a single family dwelling louse, and more particuladybomkl and described as follows: P BBOWNWO at a point on the autmn edge ofHlckory Lane at common comer ofLd,. No. 1, Sectlost "N", and Lot No. 2, Section "N", as shown an Subdivision Pint for G dt C Associates dated August 20, 1991; thence along Lot No. 1 South 35 degrees 51 minutes 53 seconds Beat 150.00 feet to a point; thence along other lands now or formerly of Gwen S. ASW North 54 degrees 08 minutes 07 seconds But 111.80 feet to a point;, thence along it pmpow . public street North 35 dt+pm 51 minutes 53 seconds West 11 S.Oo fi st to a polar theme by s- curve to the Left having a radius of 35.00 fart, a chard bearing ofNorth 80 degrees 51 Mande seconds Beat, an arc distance of 54.98 feet to a point on the tastem edge of FGclmry Lana; along the gatern edgrofHftdwry.Luse South 54 degrees 08 minuses 07 secands West 76.10 .. to a point, the point and piano ofBEGINMNG., BEING all of Lot No, 2. Section "N", on Subdivision Plan fbr G & C Associates Used August 20, 1991 and recorded in Cumberland County Pion Book; 64, Page 60. CONTAII1IING 0.3790 acres, more or hiss. t r BEING KNOWN AS: LOT 2 HICKORY LANE SHIPPENSBURG, PA 17257 PROPERTY ID NO.: 36-35-2385-116 TITLE TO SAID PREMISES IS VESTED IN GLEN E. BURDGE AND JANE G. BURDGE, HUSBAND AND WIFE BY DEED FROM GALEN S. ASPER AND JEANNETTE A. ASPER, HIS WIFE BY THEIR ATTORNEY-IN-FACT, JOHN MCCREA III, BY VIRUTE OF POWER OF ATTORNEY RECORDED AUGUST 28, 1985 IN CUMBERLAND COUNTY MISCELLANEOUS BOOK 308, PAGE 669 AND MARTIN HURST AND MABEL M. HURST, HUSBAND AND WIFE DATED 10/1/1992 RECORDED 10/5/1992 IN DEED BOOK X-35 PAGE 612. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-1558 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From GLENN E. BURDGE AND JANE G. BURDGE A/K/A JANA G. BURDGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $105,181.53 L.L. $.50 Interest FROM 4/26/06 TO DATE OF SALE 9/6/06 - ONGOING PER DIEM OF $20.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm % Atty Paid $143.60 Plaintiff Paid Date: APRIL 28, 2006 Due Prothy $1.00 Other Costs URTI . L NG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 40 1? VL- kA- Cz, On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Township, Cumberland County, PA Known and numbered as 204 Hickory Lane, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22, 2006 By: ISWOAn Real Estat Sergeant OE :b V S- X V W 9001 V43 1?83HS 3P-i JO 331JAO THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of 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 Sworn to and s sc 'bed b ore me this 16th c?bA&6? ANNSYLVAP S A L E #40 NotarW Seal Te L. Russell, Notary Public City Ha ; aup* County My 'res June 6,2010 e er, P ttnia Association Nota NOT PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE i CARLISLE, PA. 17013 we (elk 76afaxma}girt the NMI r PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. 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. sa Marie Cote, Editor SWORN TO AND SUBSCRIBED before me this 4 day of August, 2006 LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 40 Writ No. 2006-1558 Civil Wells Fargo Bank, NA vs. Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge Atty.: Mark Udren ALL that certain tract of ground situate in Shippensburg Township, Cumberland County, Pennsylvania, being improved with a single family dwelling house, and more particu- larly bounded and described as fol- lows: BEGINNING at a point on the eastern edge of Hickory Lane at common corner of Lot No, 1, Sec- tion "N", and Lot No. 2, Section "N", as shown on Subdivision Plan for G & C Associates dated August 20, 1991; thence along Lot No. 1 South 35 degrees 51 minutes 53 seconds East 150.00 feet to a point; thence along other lands now or formerly of Galen S. Asper North 54 degrees 08 minutes 07 seconds East 111.80 feet to a point; thence along a pro- posed public street North 35 de- grees 51 minutes 53 seconds West 115.00 feet to a point; thence by a curve to the left having a radius of 35.00 feet, a chord bearing of North 80 degrees 51 minutes 53 seconds East, an are distance of 54.98 feet to a point on the eastern edge of Hickory Lane; thence along the east- ern edge of Hickory Lane South 54 degrees 08 minutes 07 seconds West 76.80 feet to a point, the point and place of BEGINNING. BEING all of Lot No. 2, Section "N", on Subdivision Plan for G & C Associates dated August 20, 1991 and recorded in Cumberland County Plan Book 64, Page 60. CONTAINING 0.3790 acres, more or less. BEING KNOWN AS: Lot 2 Hickory Lane, Shippensburg, PA 17257. PROPERTY ID NO.: 36-35-2385- 116. TITLE TO SAID PREMISES IS VESTED IN Glen E. Burdge and Jane G. Burdge, husband and wife by deed from Galen S. Asper and Jeannette A. Asper, his wife by their attorney-in-fact, John McCrea III, by virtue of power of attorney re- corded August 28, 1985 in Cumberland County Miscellaneous Book 308, Page 669 and Martin Hurst and Mabel M. Hurst, husband and wife dated 10/ 1/ 1992 recorded 10/5/1992 in Deed Book X-35 page 612. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA Plaintiff V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $105,181.53 Interest From 4/26/06 10,059.60 to Date of Sale 9/5/07 Ongoing Per Diem of 20.20 to actual date of sale including if sale is held at a later date (Costs to be added) UDREN LAW OFFICES, P.C. a±4e J. Udren, ESQUIRE .TTORNEY FOR PLAINTIFF V T v c? r-a 0 'Jo w ? ? ? ' y ? -r ? j V 1 l? r ~ F t t w 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 .com Wells Fargo Bank, NA Plaintiff v. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN OFFICES, P.C. ar J. Udr en, SQUIRE ORNEY FOR PLAINTIFF %- - rT" t P'' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION :Cumberland County AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, NA, 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: Lot 2 Hickory Lane, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address V. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge MORTGAGE FORECLOSURE NO. 06-1558 204 Hickory Lane Shippensburg, PA 17257 204 Hickory Lane Shippensburg, PA 17257 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 ,ol` of record: Name Address Wells Fargo Bank, NA 3476 Stateview Blvd. Fort Mill, SC 29715 1 Home Campus, Des Moines, IA 50328 Allfirst Bank 25 South Charles Street Baltimore, MD 21201 GE Mortgage Services LLC 3476 Sateview Blvd. Fort Mill, SC 29715 c/o Francis S. Hallinan, Esquire Address to Follow 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 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 Lot 2 Hickory Lane Shippensburg, PA 17257 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.¢. DATED: March 16, 2007 ark\_6/. Udren, ESQ. ttorney for Plaintiff i C2 0 t ? 1 _ tSl ' J c l., V a ?T' ? ,?iT2 •. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. .MORTGAGE FORECLOSURE Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,181.53, 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.) r 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 TARE 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 ?? ? C3 t w ? -ri t 1110 Cri Wells Fargo Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings®udren.com V. MORTGAGE FORECLOSURE Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,181.53, 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 canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 TARE 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 C7 0 -F1 t? 4 ", it WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1558 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NA, Plaintiff (s) From GLENN E. BURDGE, JANE G. BURDGE A/K/A JANA G. BURDGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION, (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $105,181.53 L.L. Interest FROM 4/26/06 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $20.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $10,059.60 Atty's Comm % Atty Paid $1126.71 Plaintiff Paid Due Prothy $2.00 Other Costs Date: MARCH 29, 2007 (Seal) Cu is R. Long, o ota By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Wells Fargo Bank, NA VS Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1558 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2007 at 1758 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge, by making known unto Glenn E. Burdge personally, and husband of Jane G. Burdge a/k/a Jana G. Burdge, at 204 Hickory Lane, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2007 at 1901 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge located at Lot 2 Hickory Lane (a/k/a 204 Hickory Lane), Shippensburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Glenn E. Burdge and Jane G. Burdge a/k/a Jana Burdge, by regular mail to their last known address of 204 Hickory Lane, Shippensburg, PA 17257. These letters were mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriff s Costs: Docketing 30.00 Poundage 120.00 Advertising 15.00 Posting Bills 15.00 Prothonotary 2.00 Mileage 38.40 Levy 15.00 Surcharge 30.00 Law Journal 407.00 Patriot News 408.86 Share of Bills 15.69 ? y,d 9 9 9?i $1096.95 - So An er • - R. Thomas Kline, Sheriff BY? _ Real Estate rgeant o? 2 ` U Co dq9 et'r,/ qP 70 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA Plaintiff v. ATTORNEY FOR PLAINTIFF ;COURT OF COMMON PLEAS ;CIVIL DIVISION :Cumberland County ;MORTGAGE FORECLOSURE Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, NA, 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: Lot 2 Hickory Lane, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 Jane G. Burdge 2.04 Hickory Lane a/k/a Jana G. Burdge Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none I ..4. Name-and address of the of record: Name Wells Fargo Bank, NA last recorded holder of every mortgage Address 3476 Stateview Blvd. Fort Mill, SC 29715 1 Home Campus, Des Moines, IA 50328 Allfirst Bank 25 South Charles Street Baltimore, MD 21201 GE Mortgage Services LLC 3476 Sateview Blvd. Fort Mill, SC 29715 c/o Francis S. Hallinan, Esquire Address to Follow 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 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 Lot 2 Hickory Lane Shippensburg, PA 17257 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.¢. DATED: March 16, 2007 rkN,J/. Udren, ESQ. torney for Plaintiff r ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. MORTGAGE FORECLOSURE Glenn E. Burdge NO. 06-1558 Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Glenn E. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,181.53, 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 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 TARE 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 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 .com Wells Fargo Bank, NA Plaintiff v. Glenn E. Burdge Jane G. Burdge a/k/a Jana G. Burdge Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-1558 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jane G. Burdge a/k/a Jana G. Burdge 204 Hickory Lane Shippensburg, PA 17257 Your house (real estate) at Lot 2 Hickory Lane, Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $105,181.53, 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 canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 TARS THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL that oertain tract of Sound situate In SWppmsburg-TownsWp. CumberW I ,,l peantpty ds, being improwd.wlth A single firmly dwelling house, and more p"culady ba?mlril and deserted ai Ibliows: ?.. BBGR4G Wat a pohrt.eh tbo awiatetn edge of HickoryLate at common Corner oflA Nc.1, SeWoa W., sad Lot NQ: ;t,•Swdon W, as shown on SubdMAca Ptaa for O k C Assodma dated August 20.1991; thence along hot No. I 9oath 35 degrees St roil53 satsatt b E0.150.00 feet to a point; them along other leads now or krmer? of Wm S. kp t? North 54 depsa 01 minutes 07 seconds But l 11.10 Act * a point; thence tong a pmpcw 17 pubib sttWNorth 33 degrdbr 31 minutes 53 seconds Wen 115.00 het to a point; themes 6ys-? am* to the k ft baving a radhts of 35.00 lbet, a chord badog of North 80 degrees 51 a3 iot seconds be, an an durance of 54.98 feet to a point on the astern edge oflBdcay LanK Ibral sioag the sawn edpof Hdchory l ane South S4,dapA 08 minutes 07. seconds Nest 76.10 to a point, the pots and place of 13ROD& G., BEING aq of Lot No. 2. Section "N", on Subdivision Plan 1br 0 at C Associates hM Auva 20, and recorded iK.Cumbetllard Count' Plan Book 64, Page 60. CONTAOM10.3790-nom, more or less. BEING KNOWN AS: LOT 2 HICKORY LANE, SHIPPENSBURG, PA 17257 PROPERTY ID NO.: 36-35-2385-116 TITLE TO SAID PREMISES IS VESTED IN GLENN E. BURDGE AND JANE G. BURDGE, HUSBAND AND WIFE BY DEED FROM GALEN S. ASPER AND JEANNETTE A. ASPER, HIS WIFE, BY THEIR ATTORNEY-IN-FACT, JOHN MCCREA III, BY VIRTUE OF POWER OF ATTORNEY RECORDED AUGUST 28, 1985 IN CUMBERLAND COUNTY MISCELLANEOUS BOOK 308, PAGE 669, AND MARTIN HURST AND MABEL M. HURST, HUSBAND AND WIFE DATED 10/01/92 RECORDED 10/05/92 IN DEED BOOK X-35 PAGE 612. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-1558 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NA, Plaintiff (s) { From GLENN E. BURDGE, JANE G. BURDGE A/K/A JANA G. BURDGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $105,181.53 L.L. Interest FROM 4/26/06 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $20.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $10,059.60 Atty's Comm % Due Prothy $2.00 Atty Paid $1126.71 Other Costs Plaintiff Paid Date: MARCH 29, 2007 (Seal) 64?? Curti R. Long, o By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 oea Real Estate Sale # 01' On April 13, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Township, Cumberland County, PA Known and numbered as Lot 2 Hickory Lane, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: April 13, 2007 By: Real Estate Sergeant O£' tool IR 4 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 Shannon D. Bilthime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. 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 _ SALE #8 Sworn to and subscribed beforPgQNWjM2& ` Nomri al Seal Terry L. kussak;, Notaiy Public City Of Haais;burg; Dauphin County My mission Expires June 6,20'10 Memt+ r, nnsVty in!a A-;orslglt 4m Nnfd? NOT AY P LIC r CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ?1 - PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 20, July 27, and August 3, 2007 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 Astenma as to timc, place and chwacter of publication are true. Marie Coyne, SWOKN TO AND SUBSCRIBED before me this 3 day of August, 2007 Notary NO7MM SEAL DEBORAH A COLL*d Notary PubNC CARLKE BORO. CUMERIAND COMM My C mn*dcn Expint Ap 26.2010 Mgi.-on*" 0" M a Writ No. 2006-1558 Civil Wells Fargo Bank, NA vs. Glenn E. Burdge and Jane G. Burdge a/k/a Jana G. Burdge Atty.: Mark Udren DECRIPTION ALL that certain tract of ground situate in Shippensburg Township, Cumberland County, Pennsylva- nia, being improved with a single family dwelling house, and more particularly bounded and described as follows: BEGINNING at a point on the east- ern edge of Hickory Lane at common k CoMtr of Lot No. 1, Section "N", and Lot No. 2, Section "N", as shown on Subdivision Plan for G & C Associates dated August 20, 1991; thence along Lot ft 1 South 35 ' 51 =in- vow 53 seconds East 50.00 het to apshtt thence along other laada now or** rlyl? of Gaie+n 8 Ilaetlz 54 is OE esinutee O'iti aaoosd? 140 11.00 hot to a paint; dwmw dung a proposed public street North 35 degrees 51 minutes 53 seconds West 115.00 feet to a point; thence by a curve to the left having a radius of 35.00 feet, a chord bearing of North 80 degrees 51 minutes 53 seconds East, an arc distance of 54.98 feet to a point on the eastern edge of Hickory Lane; thence along the eastern edge of Hickory Lane South 54 degrees 08 minutes 07 seconds West 76.80 feet to a point, the point and place of Beginning. BEING all of Lot No. 2, Section "N", on Subdivision Plan for G & C Associates dated August 20, 1991 and recorded in Cumberland County Plan Book 64, Page 60. CONTAINING 0.3790 acres, more or less. BEING KNOWN AS: LOT 2 HICK- ORY LANE, SHIPPENSBURG, PA 17257. PROPERTY ID NO.: 36-35-2385- 116. TITLE TO SAID PREMISES IS VEMI) IN Glenn E. Burdge and Jane G. Burdge, husband and wife by deed from Galen S. Asper and Jeannette A. Asper, his wife, by their attorney-in-fact, John McCrea III; by virtue of power of attorney recorded August 28, 1985 in Cumberland County Miscellaneous Book 308, Page 669, and Martin Hurst and Mabel M. Hurst, husband and wife dated 10/01/92 recorded 10/05/92 In Deed Book X-35 Page 612. YTV4VOO (3KA1Si3SMU UDREN LAW OFFICES,' P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, NA =COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION :Cumberland County V. Glenn E. Burdge Jane G. Burdge NO. 06-1558 a/k/a Jana G. Burdge Defendant PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: February 1, 2008 UDREN LAW OFFICE P, P.C. BY : Attorneys for Plaintiff\ MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE A V1 t71 OO 8 g d? (I c rt T Ci`S r 6 -11