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06-2390
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 p1eadings@udren.com Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass-Through Certificates, Series 2004-0Pl 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a!k!a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. Ol.s, - ;2390 C1Ultr ~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escri ta sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 717 -249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within tbe 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address ofthe original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: EHome Credit Corp. Assignments of Record to: Option One Mortgage Corporation Recording Date: 11/22/04 Book: 713 Page: 1135 Assignments of Record to: Wells Fargo Bank, National Association as Trustee for SABR 2004-0Pl Mortgage Pass-Through Certificates, Series 2004-0Pl Recording Date: LODGED FOR RECORDING 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: 1910 Spring Road MUNICIPALITY/TOWNSHIP/BOROUGH: New Middleton Township) COUNTY: Cumberland DATE EXECUTED: 11/13/03 DATE RECORDED: 11/18/03 BOOK: 1845 PAGE: 2385 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 4/15/06: Principal of debt due Unpaid Interest at 11.5%* from 12/1/05 to 4/15/06 (the per diem interest accruing on this debt is $45.77 and that sum should be added each day after 4/15/06) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $30.98 and that sum should be added on the first of each month after 4/15/06) Late Charges (monthly late charge of $87.07 should be added in accordance with the terms of the note each month after 4/15/06) Suspense Balance NSF $145,275.30 6,209.68 325.00 280.00 7,269.83 Interest on Advance Attorneys Fees (anticipated and actual to 5% or principal) TOTAL 1,800.82 (1,087.78) 60.00 271.68 7.263.77 $167,668.30 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, In accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $167,668.30 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. '~)\lU Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 . . ALL. THOSE TWO CERTAIN TRACTS OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE IN NORTH MIDDLETOWN TOWNSHIP. CUMBERLAND COUNTY, PeNNSYLVANIA, BOUNDED AND DESCRIBED AS FOlLOWS: TRACT 1: BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 L.EADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD. WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STReET LOCATED HAS BEEN CHANGED AND IS NOW CAllED WAGNER STREET), AS INDICATeD ON THE PLAN OF LOTS ADOPTED BY GEORGE H, SCHLUSSER AND DESIGNATED AS PLAN NO.1 OF SCHLUSSER VILLAGE. SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERlAND COUNTY AT CARLISLE, PENNSYlVANIA. IN PLAN BOOK NO. 7. PAGE 5: THENCE ALONG THE NOR'ftiERN SIDE OF SAID CARLISLE AVENUE. NORTH 84 DEGREES 45 MINUTES WEST. A DISTANCe OF 152.8 FEET TO A POINT IN LINe Of LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER. NORTH 5 DEGREES, 15 MINUTES EAST. A DISTANCE OF 2M.S FEET TO A POINT IN LINE OF LOT NO.6 ON SAID PLAN OF LOTS: THENCE ALONG SAID LOT NO.6. SOUTH 84 DEGREES 'Ill MINUTES EAST, A DISTANCE OF 152.8 FEET TO A POINT IN THE CENTER OF THE AFORESAID PENNSYlVANIA STATe HIGHWAY ROUTE NO. 34; TliENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE 34. SOUTH 15 DEGREES 15 MINUTES WEST, A DISTANCE OF 259.5 fEET TO A POINT, TtfE PlACE OF BEGINNING. HAVING THEReON ERECTED A TWO-STORY FRAME. DWELLING HOUSE AND CONCRETE BLOCK GARAGE ~OWIl AS AND NUMBERED 1910 SPRING ROAD. TRACT 2: ON THE NORlH BY TRACT NO. 1 ABOVE DESCRIBED, ON THE EAST BY THE CARLISLE-NEW BLOOMFIELD ROAD (I<NOWN AS PENNSYLVANIA ROUTE NO. 34); ON THE SOUTH BY WAGNER STfEeT AS SHOWN ON TI1E REVISED P.l.AN OF FRY AVENUE LOTS ON PLAN NO.4 OF SCHWSSER VIU:AGE, WHICH- PLAN IS RECORDeD IN THE SAID RECOFlDER'S OFFICE IN PLAN BOOK NO.7 AT PAGE 47 AND ON THE WEST BY lOT NOS. 87 AND 68 AS SHOWN ON SAID REVIseD PLAN OF FRY AVENUE LOTS. . . BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLiSLE AVENUE (ERRONEOUSLY SAID IN PRIOR DEl!D TO BE PART OF lOT NO.5) AS SHOWN'ON PlAN NO.1 OF SCHLUSSER VIUAGE, WHICl-tPtAN IS RECOADED IN TliE SAID RECORDER'S OFFICE IN PLAN BOOK NO.7. PAGE 5. CONTAINING 50 FlEET. MORE OR LESS. IN FRONT ON SAID ROUTE NO. 34 AND exTENdiNG IN DEPTH AT AN INCREASING WIDTH OF 150 FEET. MORE OR LESS; AND HAVING A WIDTH IN THE REAR OF 55 FiIiT. MORE OR LESS. 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"'010 ",ZO Z "' ~~ ",H Z H01 "'0 >: H t< r< ~ '" o >-3 '" 01 " o 01 '" 01 Z en 01 '" o C "' 01 t< H 01 '" Ol '" o C ~ '" X " '" Ol >-3 o '" C n X " n >-3 H o Z * t<t<o HOW z", O1Zo If.lllln , , "00 O1oen ".... ,'" "0 "W Glen 01'" " .... Zo> o n 00 "" 0>-3 H01 >-3" HO 0"" Z' "'''' " en o d '" 01 " " " en 0> '" Ol '" " 0:;: "'" "" W "t' "' <>-3 01>-3 ,,"' "'" " >: 0" WH W>-3 01 >-3" H >-3" t'n 01>-3 " H ,,< . H ">-3 "'" "'''' o "" " :;: ZO OZ H>-3 0-"' 00 "'" ""0 .... '0, " 0 0'" '0 .... o '" o " :;: " n '" " " " " H Z >-3 01 " " " N W N "''' Ol" nGl COl " HW >-3w "'- " w "'en '" V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. \ 'u\\\0 Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. ~ -lCl.. C :D (J( {;) 0 t- ~ In. ~ U< ~ - Crt C> ~ --D -:::l --- -0 ~ "-> U{ ~ \) -- \lS >~ ~ - ~ ,r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) John Lucidon and Rosa Lucidon a/k/a Rose Maria Lucidon for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 4/16/06 to 6/6/06 Late charges per Complaint From 4/16/06 to 6/6/06 Escrow payment per Complaint From 4/16/06 to 6/6/06 TOTAL $167,668.30 2,380.04 87.07 61. 96 7.37 I hereby certify that (1) the Defendant are as shown above, and (2) accordance with Rule 237.1, co of DAMAGES ARE HEREBY ASSESSED AS DATE :...J/.t. """' I.... l J {Job Plaintiff and that not ce has been given in hereto. Mark J. Udren, ESQUIRE Attorney for Plaintiff INDICAT~ . ~ PRO PRf5TH~ '1 SBERIFF'S RETURN - REGULAR CASE NO: 2006-02390 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK VS LUCIDON JOHN ET AL SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, " says, the within COMPLAINT - MORT FORE was served upon LUCIDON JOHN the DEFENDANT , at 0853:00 HOURS, on the 3rd day of May , 2006 at 1910 SPRING ROAD CARLISLE, PA17013 by handing to JOHN LUCIDON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.40 .00 10.00 .00 32.40 So Answers: ~~'"""~'{:-l~~ R. Thomas Kline day of 05/04/2006 UDREN LAW OFFICE ~krJJ; Deputy riff By: Sworn and Subscribed to before me this A.D. o LotJ-! C3f'-l ~ /0 Prothonotary ,...1J..1.L:l.r\.....J...1'.r w !'i..,c,.l. U.t\.l\l - .K,..t;GU.l...rAl<. CASE NO: 2006-02390 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK VS LUCIDON JOHN ET AL SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LUCIDONROSA AKA ROSA MARIE LUCIDON the DEFENDANT , at 0082:00 HOURS, on the 3rd day of May , 2006 at 1910 SPRING ROAD CARLISLE, PA 17013 by handing to JOHN LUCIDON, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: . ~~.~//7 __.?'Y''/.C:. ,r.....r'" ,.,/.;:-~<_:.,.. .- f ~?"""'"'''''-''''''-''''1;/''''''~''-'."~ R. Thomas Kline me this day of 05/04/2006 UDREN LAW OFFICE ~.i?7 / . 7uty Sheriff By: Sworn and Subscribed to before A.D. Prothonotary UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 DATE of Notice: May 26, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFlCACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION, 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 NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED W BE USED FOR THAT PURPOSE. ar. , squ1.re Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCRBST CORPORATE CENTER 111 WOODCRBST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (6) NO. 06-2390 Civil Term John Lucidon 1910 Spring Road Carlisle, PA 17013 DATE of Notice: May 26, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA paR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, 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 BE USED FOR THAT PURPOSE. ar. , squ1re Woodcrest Corpor te Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 civil Term v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: John Lucidon Over 18 As captioned above Unknown MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. Rosa Lucidon Over 18 As captioned Unknown Sworn to -and subscribed before me~ this 6th day ~une, 2006:, ^.Q-)J~~ Notar:(,p~bl:c _J._,...,....,.,..t-"',,'..>I' "Nt".., ,<.", '" "',_ flll\oll,;;u,i ..JtPf)i J;:i:;_..;-.i, ~-""""~'-,'I"Llv-" '\l.~~Ur.u..~~ ':..\l,!'ln,"....., iV! ::.,1.':' 0~ c 1 ~~ ~ () - \'"_) ~ - )J -v ~' ~ N ?=- ~ ~ V\ \f ~ '1:::> - v t f:1 -L o c- r-.:> c::.:- (:'.:.'J G.;:~ t.- c:::: :.<~~: Q, :1~ fi'P 1)Q ~ ::~.~:::;? ~-L-M ^"~C) ""'","'rn 9 )~ :- ~ -0 ::r; '!? t.J1 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, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 Civil Term TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due $170.217.37 Interest From 6/7/06 8.375.91 to Date of Sale December 6. 2006 Ongoing Per Diem of $45.77 to actual date of sale including if sale is held at a later date (Costs to be added) $ ark J. Udren, ESQUIRE TTORNEY FOR PLAINTIFF rcJ C r- ~ ~ ~ r t: r. ':f- t (J "'\b. - ~ ~ ).> ~ }.) ~ ~ ) , - -'q. Vv ~ ~ ~ :CQ. \) ...0 - ~ i'- - ~ ~ tl\ '1 \) ~ \) C 1I1 0. J:: () Q. \) \) c- () ,...., () \J = 0 0 = I 0'" ....... I <- =! ,.. ~ -0 c:: l~-n f? ;.1::; 'F f - ... .. ?- I :p~ .... .... .... ::: .. en ,:.]........ , , .. '::l.- ~~~ ::b -0 :2: - .... v:.J +- ~ ... ':'? ~~7rn ~ ,.) ... :f ;;--t ~ 55 - .;;::- U1 -< WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-2390 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR SABR 2004-0Pl MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-0Pl, Plaintiff (s) From JOHN LUCIDON AND ROSA LUCIDON AfKJA ROSE MARIA LUCIDON (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) notlevied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $170,217.37 L.L. $.50 Interest FROM 6/7/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $45.77 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $8,375.91 Arty's Comm % Due Prothy $1.00 Arty Paid $130.40 Other Costs Plaintiff Paid Date: JUNE 6, 2006 ~TIS (Seal) Prothonotary 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 ill No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 NO. 06-2390 Civil Term Defendant(s) C E R T I FIe ATE 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 authori ies. ark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF "" = 0 =~ " c:;;...~ <- ::t c:: n-tl1 ....'.'- r- I -om cuz 0'> (~ ':1 -0 -'\-~ -Yi --;:" '=s::r..: , ;;,C. -;:=-n'l f-.; w _..,J ,--I :<i .". .17 ::0 c..'1 -< ... . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 NO. 06-2390 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass-Through Certificates, Series 2004-0P1, 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: 1910 Spring Road (New Middleton Township), Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address John Lucidon 1910 Spring Road Carlisle, PA 17013 Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE .... . 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a Unemployment Compensation Fund 16th Fl., L&I Building Harrisburg, PA 17121 Helen V. Warrick 346 E. North Street Carlisle, PA 17013 A Marian M. Conrad Address to Follow 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address in the property and Name of every other person whose interest may be Address who has any record interest affected by the sale: Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1910 Spring Road (New Middleton Township) Carlisle, PA 17013 . ~ I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 6, 2006 N LAW OFFICES, .C. Mark J. Udr Q. Attorney for Plaintiff - 0 ....., c: = 0 coo cr" -n ,:;; L- --I c: :r: ~ rl1~ I -am 0"' ~1'10 (-,)(: _I .J -0 r .._\.. ~ -".. 2 ~1 ~,. 0 -'.; 'i? (5 en -'- :::;...1. ~'::'2 r ",' U1 .Q \ ..... UDREN LAW OFFICES. P.C. BY: Mark J. Udren. Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD. SUITE 200 CHERRY HILL. NJ 08003-3620 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0Pl 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road(New Middleton Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE TO prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) \ ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ,- , (") "'" ~ = ~ = <.f' (,- ..... '. ~ ::r::-n P'F ",;;;...,. -ani I :.uO 0' ;),,':J -<:) ~f{ > '? :r. !jJ en "< 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, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road(New Middleton Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. TO find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , -- YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 .' (") (: r--" 5 <.f" ,- ~ " \ <T' ~ :::I -,_-n cn'r: ~c;tn "J'-' ~:~) (\) ,_ )::-;J '...) (') ~;~{'n ~ )7 :.!1 "'""'0 -,-' --';" '-? .c- (J1 .".*"'" '. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02390 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK VS LUCIDON JOHN ET AL SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LUCIDON JOHN the DEFENDANT , at 0853:00 HOURS, on the 3rd day of May , 2006 at 1910 SPRING ROAD CARLISLE, PA 17013 by handing to JOHN LUCIDON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 61J.40~ C+-,. 18.00 4.40 .00 10.00 .00 32.40 So Answers: r'~~~f~ .f'~2..;J R. Thomas Kline day of 05/04/2006 UDREN LAW OFFICE ~1rJJ; Deputy riff By: Sworn and Subscribed to before me this A.D. Prothonotary SHERIFF'S RETURN - REGULAR 1-./ . .. CASE NO: 2006-02390 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK VS LUCIDON JOHN ET AL SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LUCIDON ROSA AKA ROSA MARIE LUCIDON the DEFENDANT , at 0082:00 HOURS, on the 3rd day of May , 2006 at 1910 SPRING ROAD CARLISLE, PA 17013 by handing to JOHN LUCIDON, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~ 6/2'l\ Q{, 6.00 .00 .00 10.00 .00 16.00 _t ,;1:- ....,,- ~~' -'',,' ,,::: ..-:;.' ,....;'O~:'.:,:>~~.:,c"'".:. ....../.. j...:;'~.",.~ ,&-"'. ". 'I .- R. Thomas Kline 05/04/2006 UDREN LAW OFFICE Sworn and Subscribed to before By: ~.~ ~. ty , Sheriff day of me this A.D. Prothonotary Wells Fargo Bank, National Association as Trustee for SABR 2004-0P 1 Mortgage Pass- Through Certificates, Series 2004-0Pl VS John Lucidon and Rosa Lucidon a1k/a Rose Maria Lucidon In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-2390 Civil Term 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. Sheriffs Costs: Docketing Surcharge Law Library Prothonotary Mileage Certified Mail Advertising Law Jounlal Patriot News Share of Bills Poundage Posting Handbill Levy 30.00 40.00 .50 1.00 8.80 2.35 30.00 611. 00 607.46 15.94 28.14 30.00 30.00 $1,435.19 "~/ iJ./Olf!O{, ~ So Answers: f /..# ~~-~ ~ R.1hom~s Kline, SherifF ~ By\.lo~~ Real Esta~ /.-. tr:~(j t- J (;'.0 l. oe oJ"" )"02- 'I 4~J i f (, / f 7 ,. '" UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 NO. 06-2390 civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Far90 Bank, National Association as Trustee for SABR 2004-0P1 Mortgage Pass-Through Certificates, Series 2004-0P1, 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: 1910 Spring Road (New Middleton Township), Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address John Lucidon 1910 Spring Road Carlisle, PA 17013 Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 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 lS a record lien on the real property to be sold: Name Address Unemployment Compensation Fund 16th Fl., L&I Building Harrisburg, PA 17121 Helen V. Warrick 346 E. North Street Carlisle, PA 17013 A Marian M. Conrad Address to Follow 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the propeJ:-ty: 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. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1910 Spring Road (New Middleton Township) Carlisle, PA 17013 . I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. , DATED: June 6, 2006 ~ UD~OFFICES~.C. ~rk J. Udr~Q. Attorney for Plaintiff . .UDREN IiAW, 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, National Association as Trustee for SABR 200'~-OP1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road(New Middleton Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, 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, lrou 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, National Association as Trustee for SABR 2004-0P1 Mortgage Pass- Through Certificates, Series 2004-0P1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2390 civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road(New Middleton Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PAl to enforce the court judgment of $170,217.37, 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 rn.ay 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 srrossly 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. THOSE TWO CERTAIN TRACTS OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE IN NORTH MIDDLETOWN TOWNSHIP, CUMBERLAND COUNTY, PENNSYl.VANIA, BOUNDED AND DESCRIBED AS FOLLOWS: TRACT 1: BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARlISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STREET LOCATED HAS BEEN CHANGED AND IS NOW CAllED WAGNER STREET), AS INDICATED ON THE PLAN OF lOTS ADOPTED BY GEORGE H. SCHLUSSER AND DESIGNATED AS PlAN NO.1 OF SCHlUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNiY AT CARLISLE, PENNSYlVANIA. IN PLAN BOOK.NO. 7. PAGE 5; THENCE ALONG THE.NORTHERN SIDE OF SAle CARUSLE AVENUE. NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES, 15 MINUTES EAST, A DISTANCE OF 259.5 FEET TO A POINT IN LINE OF LOT NO.6 ON SAID PLAN OF LOTS: THENCE Al.ONG SAID LOT NO.6, SOUTH 84 DEGREES 45 MINUTES EAST, A DISTANCE OF 152.8 FEET TO A POINT IN THE CENTER OF THE AFORESAID PENNSYlVANIA STATE HIGHWAY ROUTE NO. 34; THENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE 34. SOUTH 5 DEGREES 15 MINUTES WEST, A OISTANCE OF 259.5 FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THeREON ERECTED A 1WO-STORY FRAME DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AS AND NUMBERED 1910 SPRING ROAD. TRACT 2: ON THE NORTH BY TRACT NO. 1 ABOVE DESCRIBED, ON THE EAST BY THE CARLISLE-NEW BLOOMFIELD ROAD (KNOWN AS PENNSYLVANIA ROUTE NO. 34); ON THE SOUTH BY WAGNER STReET AS SHOWN ON THE REVISED PLAN OF FRY AVENUE lOTS ON PLAN NO.4 OF SCHLUSSER VILLAGE, WHICH-PLAN ' IS RECORDED IN THE SAJD RECORDER'S OFFICE IN PLAN BOOK NO.7 AT PAGE 47 AND ON THE WEST BY LOT NOS. 67 AND 6S AS SHOWN ON SAID REVISED PLAN OF FRY AVENUE LOTS. ' . BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLISLE AVENUE (ERRONEOUSLY SAID IN PRIOR DEED TO BE PART OF' LOT NO.5) AS SHOWN'ON PLAN NO.1 OF SCHLUSSER VILLAGE, WHICH-PLAN ISRECOflDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK NO.7. PAGE 5. CONTAINING 50 FEET. MORE OR LESS. IN FRONT ON SAID ROUTE NO. 34 AND EXTENQING IN OEFT'ri AT AN INCREASiNG WIDTH OF 150 F=,~ MORE OR LESS, AND HAVING A WIDTH IN THE REAR OF 55 FEET, MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUJLDING AND OTHER RESTRICTIONS AS SHOWN ON SAID PLANS OF LOTS RECORDED AS AFORESAID. " -;.. BEING KNOWN AS: 1910 SPRING ROAD (NEW MIDDLETON TOWNSHIP) CARLISLE, PA 17013 PROPERTY ID NO. : 29-16-1094-241 TITLE TO SAID PREMISES IS VESTED IN JOHN LUCIDON AND ROSE MARIA LUCIDON, HUSBAND AND WIFE BY DEED FROM LEON C. MORRISON AND JEANNETTE MORRISON, HUSBAND AND WIFE DATED 11/13/03 RECORDED 11/18/03 IN DEED BOOK 260 PAGE 2040. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2390 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TR.USTEE FOR SABR 2004-0Pl MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-0Pl, Plaintiff (s) From JOHN LUCIDON AND ROSA LUCIDON A/KJA ROSE MARIA LUCIDON (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. AmountDue $170,217.37 L.L. $.50 Interest FROM 6/7/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $45.77 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $8,375.91 Arty's Comm % Due Prothy $1.00 Atty Paid $130.40 Plaintiff Paid Date: JUNE 6, 2006 Other Costs (Seal) kJ~. ~!o)1 -(pUt^" I[ . URTIS R:r:ONG ! Prothonotary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 27 On September 5, 2006 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, P A Known and numbered as 1910 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2006 By: . JOClL( \vvuJt"\ Real Estate Sergeant 8E :01 V 0- NrW (iDOl ~ ,"" .:Uid3.. ..1.:3 ~ ~ ~ it THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of October and the 1st and 8th day(s) of November 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #27 Sworn to and su CUMBERLAND COUNTY SHERlFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 REAL ESTATE M.E f127 Writ No. 2111 In IChtlTerm Welle ,...~...a." AssoclMtJft......,fDrSABR 2~.. J..ll........... CertHlc:atls""2OO4-OP1 Va. John Luc:Idott IIftd . Rosa Lucldoh ............... ........., Ally: ..... J.Udren DESCRP110N ALL THOSE TWO CEIITAIN tracts of land with the impJ:oveJUt8ts ~ emctedsituafe in North Middletown 'l'~ ~ County, Pennsxlwaia, ,~1IDd described as foJkM; n.t"l~ ......".. . Jiewy_ ....., M leadUaJ,,'" '. ..'. .....".....,....,. ." ... ~ of New B ... '." .".",',"hich point isp the ~ lifteof~ AYeftue <_ street ',Jtated bas - ~. and is .. caIW~ Street);. as iIIdic:IfLod on the tA of lots adopted by GageR. SdJIusser aDd designated as ,.N/t, 10l~ Vi)lage, said plan ~~II'the Oftiee of the Recorder of Deeds in IllId for CumberlaI1d County at Carli.' sIe,. ~...' '.,.V8IIl. '.. . a, in Plan," .BQok No.7, page 5; tbe8ce " . me JlOJ1JJem side of said Carlisle A1'ellUe, ,Notl!1. 84 degrees 45 minutes West, a ~ of 152.8 feet to a point in line of land DQW or f~y of George H. SChlll~ser, North 5 degrees, '15 minutes East. a distance of 259.5 feet to a point in line of Lot No.6 on said Plan of Lots; tbeare alqog sai4Lot No.6, South 84 degrees 45 minutes East, a distance of 152.8 fe<< to a .paint in the renter of the aforementioned PewylVlllia State Highway Route No. 34; 1hence. aloIg tIle center of tllid Pennsylvania State ~ Roote 34, ~ 6 degrees 15 minutes, West, a disIaw:e of 259.5 feet to a point, the place of beginning. Having thereon erected a two-BtoI'y frame dwelling house and cona:ete block ~ known as and numbered 1910 Spring Road. Tract #2: On the North by Tract No. I above described , on the East by the Carlisle-New Bloomfield Road ~..Pennsy~RQUte No. 34); on the South 'by Wagner StR:et as shown on the revised pip of Fry Avenue Lots on Plan No.4 of SchIusscr Village, which plan is recorded in the said t!tonIer's Office in Plan Book No.7 at page 47 and on the West by Lot Nos. 67 and6S as shewBon said n:NisCplaof Fry Avenue Lots. Being a portion of Lot No. 4 and part of the former Carlisle Aveaue (erroneously said in prior deed to be part of lot No.5) as shown on Plan No.1 of ~,~"., ..is recorded in tbe s8t ~s Book No.7, page 5. Con1aining 50 feet, more or Jess, in front of said Route No. 34 and extending in deplh at 3D increaPg~ of lSOfret,JIlore or less. and baviDg a .-._ teilf1'lf SS..feet, more or less. ............ " '.1Xl The above....tw,....o.1ots .01......"'-'... ..... ......................'......'......,.. ...... ...~... subject to 1lIc' . ,,~..,. . .,.".,i "i"'. as shown 011' JQIIl '. . ", .". . as aforesaid. Being knowJ1 Middleton 11 Property ID. #: 2~.16-. . . tle to said[R1l1ISe8 IS . John ~don . a Luci4on. husba1lll .... wife by ~. Morrison and ~ .' . e dated 11/13103 ,Jllge :m4O. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, 'was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: October 20, October 27 and November 3, 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. ~ SWORN TO AND SUBSCRIBED before me this 3 day of November. 2006 NO A SEAL lOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 27 Writ No. 2006-2390 Civil Wells Fargo Bank, National Association as Trustee [or SABR 2004-0Pl Mortgage Pass-Through Certificates, Series 2004-0P 1 vs. John Lucidon and Rosa Lucidon a/k/a Rose Marte Lucidon Atty.: Mark ,J. Udren ALL THOSE TWO CERTAIN tracts ofland with the improvements thereon erected situate in North Middletown Township, Cumberland County, Pennsylvania. bounded and described as follows: TRACT 1: BEGINNING at a point in the cen- ter of Pennsylvania State Highway Route No. 34 leading from the Bor- ough of Carlisle to the Borough of New Bloomfield, which point is in the northern line of Carlisle Avenue (which street located has been changed and is now called Wagner Street). as indicated on the plan of lots adopted by George H. Schlusser and designated as Plan No. 1 of Schlusser Village. said plan being recorded in the Office of the Recorder' of Deeds in and for Cum- berland County at Carlisle, Penn- sylvania, in Plan Book No.7. Page 5; THENCE along the northem side of said Carlisle Avenue, North 84 degrees 45 minutes West. a distance of 152.8 feet to a point in line of land now or formerly of George H. Schlusser, North 5 degrees, 15 min- utes east, a distance of 259.5 feet to a point in line of Lot No. 6 on said plan oflots; THENCE along said lot No.6, South 84 degrees 45 min- utes East, a distance of 152.8 feel to a point in the center of the afore- said Pennsylvania State Highway Route No. 34; THENCE along the center of said Pennsylvania State Highway Route 34, South 5 degrees 15 minutes West, a distance of 259.5 feet to a point, the place of beginning. HAVING thereon erected a two- story frame dwelling house and con- crete block garage known as and numbered 1910 Spring Road. TRACT 2: ON THE NORTH by Tract No. 1 above described, on the east by the Carlisle-New Bloomfield Road (known as Pennsylvania Route No. 34); on the south by Wagner Street as shown on the revised plan of Fry Avenue lots on Plan No. 4 of Schlusser Village, which plan is re- corded in the said Recorder's Of- fice in Plan Book No. 7 at Page 47 and on the west by Lot Nos. 67 and 68 as shown on said revised plan of Fry Avenue lots. BEING a portion of Lot No.4 and part of the former Carlisle Avenue (erroneously said in prior deed to be par-t of Lot No.5) as shown on Plan No. 1 of Schlusser Village. \vhich plarl is recorded in the said Recorder's Office in Plan Book No. 7, Page 5. CONTAlN1NG 50 feet, more or less, in front on said Route No. 34 and extemping in depth at an increasing width of 150 feet, more or less; and having a width in U1e rear of 55 feet, more or less. THE ABOVE two lots of ground are conveyed subject to the build- ing and other restrictions as shown on said plans of lots recorded as aforesaid. BEING KNOWN AS: 1910 SPRING ROAD, (NEW MIDDLETON TOWNSHIP) CARLISLE, PA 17013. PROPERTI lD NO.: 29-16-1094- 241. TITLE TO SAID PREMISES IS VESTED IN John Lucidon and Rose Maria Lucidon, husband and wife by Deed from Leon C. Morrison and Jt'annette Morrison, husband and wife dated 11/13/03 recorded 11/ 18/03 in Deed Book 260 Page 2040. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 C _~ ;,_, LORRAINE DOYLE, ESQUIRE - ID #34576 '~ ~r- ° ~ ALAN M. MINATO, ESQUIRE - ID #75860 ~','T?' ~_~ -~~ cr? CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ~' ~" '`~ WOODCREST CORPORATE CENTER r=~ ~ ~ "' `_' 111 WOODCREST ROAD, SUITE 20 0 ~:~~. ~. __ CHERRY HILL, NJ 08003-3620 ``~' ~a 856-669-5400 „~: .. pleadings@udren.com ~ w ~ Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for ECIVIL DIVISION SABR 2004-OP1 Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 :MORTGAGE FORECLOSURE Plaintiff v. John Lucidon €NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $170,217.37 ,~al.(,ov 7~f~ Interest From 06/07/2006 71,172.35 ~1t, n to Date of Sale September 8, 2010 3a. ~tU ` C-b~ Ongoing Per Diem of 45.77 (a . (~(~ --. r r ~ r /~35 l4 - ~r rr sS.tU - ~r rl /$. GU - rr ~l rt +~ v ~~ ~l $~$?: aq - ~r ~~ . ~ ~(> , to actual date of sale including if sale is held at a later date (Costs to be added) UDRENr LA~pt,.~ CES , P . C . BY: Attorne for Plaintiff UDREN, ESQUIRE STUART WINNEG ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE eK~ ~s3o41~ ~2~ 07~/3.3Q~ IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: ROSAMARIA LUCIDON a/k/a ROSAMARIA OLBES LUCIDON a/k/a ROSAMARIA GUERRERO Chapter: 13 Case Number: 1:06-bk-02465-MDF Debtor(s) CHARLES J. DEHART, III (TRUSTEE) Movant(s) vs. ROSAMARIA LUCIDON Respondent(s) ORDER DISMISSING CASE Upon consideration of the Trustee's Certificate of Default of Stipulation in settlement of the Trustee's prior Motion to Dismiss case for material default and it having been determined that this case should be dismissed, it is ORDERED that the above-named case of the debtor(s) be and it hereby is dismissed. BT the C'oiu~t B P ,Y dodge (arc) This dncr~~raen# as elec#roncally sagned and faled on #/ae sarrae dat¢. Dated: November 10, 2009 MDPA-Dismiss Case.W PT -REV 03/09 Case 1:06-bk-02465-MDF Doc 66 Filed 11/10/09 Entered 11/10/09 11:02:04 Desc Main Document Page 1 of 1 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 C WOODCREST CORPORATE CENTER ~~ - .. 111 WOODCREST ROAD, SUITE 200 ~` CHERRY HILL, NJ 08003-3620 r.; ,': 856-669-5400 ~' a pleadings@udren. com =''z~:: .r; c:: Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for 'CIVIL DIVISION SABR 2004-OPl Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 :MORTGAGE FORECLOSURE Plaintiff v. John Lucidon =NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (s) C E R T I F I C A T E .~; c 1.~ c... --t ~.~~ ~! C , u:; - :~• ~ - ~~: a' . , .. =t c. t..- I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OF .C. B . Attorneys for Plaintiff PIARR-'J:._.UD'R~I~.__ ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 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, National '-COURT OF COMMON PLEAS Association as Trustee for SABR CIVIL DIVISION 2004-OP1 Mortgage Pass-Through Cumberland County Certificates, Series 2004-OP1 Plaintiff =MORTGAGE FORECLOSURE v. John Lucidon €NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, National Association as Trustee for SABR 2004- OPl Mortgage Pass-Through Certificates, Series 2004-OP1, 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: 1910 Spring Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 1910 Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address a record lien on the Name n c z~ r;„ ~~+ ~~ Y~ _' ~~. x.:: ,. :~.:~ t-- ~. 0 a L W a~. ~:~_: c.~. ~.. '~'~ :~-e :i i -r; i`i Y+n 1 i -~~ F -.: Y~, ~~~ ..~ of every judgment creditor whose judgment is real property to be sold: Address Bureau of Compliance Unemployment Compensation Fund Helen V. Warrick Address to follow 16th Floor, L&I Building Harrisburg, PA 17121 346 East North Street Carlisle, PA 17013 ,. ~ A Marian M. Conrad Jerry Danyluk 4. Name and address of of record: Name Address to follow 834 Acri Road Mechanicsburg, PA 17055 the last recorded holder of every mortgage Address Wells Fargo Bank, National 1270 Northland Drive Association as Trustee for Suite 200 SABR 2004-OP1 Mortgage Mendota Heights, MN 55120 Pass-Through Certificates, Series 2004-OP1 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 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants every other person of whom the plaintiff any interest in the property which may be Address 1910 Spring Road Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 7, 2010 UDREN LAW FILES, P.C. BY: .xzeys. _for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank, National Association as Trustee for SABR 2004-OPl Mortgage Pass- Through Certificates, Series 2004-OPl Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS ~ ~ NOTICE OF SHERIFF' S SALE ~~ ~y,~ .'a ~, ~ ~; _; O ~-- ~ t ~~ OF REAL PROPERTY .- !.. `~ ~=- ` ~~ OWNER (S) : John Lucidon °-~ w Rosa Lucidon a/k/a ~~ -N'~- . - , ' -- Rose Maria Lucidon ` . __ ~ ~_=: --~ .~ ~''` ~ . (p'r PROPERTY: 1910 Spring Road tw: ~=~ Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 8, 2010, at 10:00 A.M., at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or 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. - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-2390 Civil Term ~' UDREN LAW OFF'.~CES, P.C. ATTORNEY 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 W 11 FOR PLAINTIFF e s Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for 'CIVIL DIVISION SABR 2004-OPl Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 'MORTGAGE FORECLOSURE Plaintiff v. John Lucidon =NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 C'~ C na ° ^ ~.. c `' - . . _ rri ?? try _~ t -r, r~~ Yr. _ .ai __.:. ~ { f 6 _ • __ . ~ r> c:~~ .r: - --, -_ .. c._: -c Your house (real estate) at 1910 Spring Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, 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 Sheriffs 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 TH8 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. 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 v~•'- s ~r~. CHERRY HILL, NJ 08003-3620 --* <=~= v _%~; 856-669-5400 •, ~r . ; t -' ' pleadingsCudren. com ~,. °:- Wells Fargo Bank, National :COURT OF COMMON PLEAS ~ ~„ =~ Association as Trustee for =CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- Cumberland County Through Certificates, Series 2004-OP1 MORTGAGE FORECLOSURE Plaintiff v. John Lucidon =NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floar, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWN$R'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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAYS 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2390 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR SABR 2004-OPl MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OPl, Plaintiff (s) From JOHN LUCIDON AND ROSA LUCIDON A/K/A ROSE MARIA LUCIDON (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 $170,217.37 L.L. Interest FROM 6/7/2006 TO DATE OF SALE 9/8/2010 -ONGOING PER DIEM OF $45.77 TO ACTUAL DATE OF SALE INCLUDING IF SALE I5 HELD AT A LATER DATE - $71,172.35 Atty's Comm Atty Paid $1,587.09 Plaintiff Paid Due Prothy $2.00 Other Costs Date: Jti~N ~' 9, 2010 (deal) . Buell, Prothonotary 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. ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings ,udren.com Wells Fargo Bank, National Association as Trustee for SABR 2004-OP 1 Mortgage Pass- Through Certificates, Series 2004-OP 1 Plaintiff V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-2390 Civil Term - :Z -n _? - c? -0 v-n =c? N) ?m r0' CD MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by the undersigned counsel, moves this Honorable Court for an Order directing Service of the Notice of Sheriff's Sale by publication in accordance with Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 430(b)(1); and service of all subsequent pleadings that require personal service upon the Defendants known as John Lucidon, deceased mortgagor and real owner, and upon "the Unknown Heirs of John Lucidon, deceased mortgagor and real owner" by posting only, of the subject premises located at 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013 in accordance with Pa.R.C.P. 430; and in support thereof avers the following: Plaintiff filed a Complaint in Mortgage Foreclosure against the above captioned Defendants. 2. It has come to the Plaintiff's attention that the Defendant, John Lucidon, mortgagor and real owner of the mortgaged premises is deceased. A true and correct copy of Proof of Death is attached hereto and marked Exhibit "A". 3. Judgment was previously entered against the defendants in June, 2006. 4. There are no "known" surviving heirs other than those that may have been previously identified herein. 5. There maybe other "unknown" surviving heirs. 6. Plaintiff must now effect service of the Notice of Sale upon the defendants. WHEREFORE, so as to properly satisfy the Pennsylvania Rules of Court, particularly Pa.R.C.P. 1144(a)(2), (a)(3), where the Plaintiff is required to name as party defendants in an action in mortgage foreclosure the heirs of a deceased mortgagor, if known, and those of a deceased real owner, the Plaintiff moves this Honorable Court, and hereby requests an Order, pursuant to Pa.R.C.P. 430 et seq., directing service of the Notice of Sheriff's Sale by publication upon the Defendant John Lucidon, deceased mortgagor and real owner, and upon the Defendants known as "the Unknown Heirs" of John Lucidon mortgagor and real owner"; and service of any and all subsequent pleadings that require personal service upon the Defendant known as John Lucidon, deceased mortgagor and real owner, and Defendant known as the "Unknown Heirs" of John Lucidon, deceased mortgagor and real owner by posting only, of the subject premises located at 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013. UDREN LAW OFFICES, P.C. Attorneys ALAN M. MINATO, ESQUIRE Ancestry.com - Social Security Death Index Page 1 of 1 Social Security Death Index Name: John M. Lucidon SSN:2847 Last Residence: 19003 Ardmore, Delaware, Pennsylvania Bo 1-11: 22 Aug 1957 Died: 21 Jan 2009 State (Fear) SSh Pennsylvania (1971-1972) issued: 19?T 19na Source Citation: Nurnbet-:168-48-28.4,-- slue State: Pennsdtlvuaic.:Isstie Date: Soturce Information: Ancestr".Coln. Social Sccuritu Death Index [database on-line]. Provo l7-t', USA: Ancestrv.com Opcrttion inc, aotu. Original data: Social Security Administration. Socia(Securitu Death Index. Master Fit<. Social, Seeuritt Adnvinistration. Description: The Social Security Administration Death Buster File contains information on millions of deceased indiviedaus with United States social security tnunbers whose deaths were reported. to the Social, Security Administration- Birth y"e.jr? £o-? the iudividnals lasted an,ge from 187_5 to lastyear. Information in these records includes name. birth date, death d stet, and last known residence. © 2olo, The Generations Network, Inc. EWd* A http://search. ancestry.com/cgi-binlsse.dll?rank=0&gsfn=John&gsln=Lucidon& sx=&f9=&f8=&f l 0... 7/20/2010 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings a(&,udren.com Wells Fargo Bank, National Association as COURT OF COMMON PLEAS Trustee for SABR 2004-OP 1 Mortgage Pass- = CIVIL DIVISION Through Certificates, Series 2004-OP1 € Cumberland County Plaintiff NO. 06-2390 Civil Term V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, Wells Fargo Bank, National Association as Trustee for SABR 2004-OP 1 Mortgage Pass-Through Certificates, Series 2004-OP I, having filed its Motion ror Service Pursuant to Special Order of Court, submits this Memorandum of Law in support hereof. Pennsylvania Rule of Civil Procedure 430(a) specifically provides, in part, that "(a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service." The purpose of the Motion is to seek special service of the Notice of Sheriff's Sale on John Lucidon, deceased mortgagor and real owner, and on the unknown heirs of John Lucidon, deceased mortgagor and real owner. It is believed that there may be heirs of the deceased Defendant not named herein yet, they are unknown to the Plaintiff. Therefore, because the heirs are "unknown", and thus unidentifiable and unable to be located, service cannot be made under the applicable rule. Pennsylvania Rule of Civil Procedure I I44(a) (2) requires the Plaintiff to name as party Defendant in an action in mortgage foreclosure the heirs of a deceased mortgagor, if known. As stated in the attached Motion, the mortgagor and real owner John Lucidon is deceased. Pa.R.C.P. I I44(a)(3) is silent with regard to the heirs of a deceased real owner who, may also be the deceased mortgagor. Known heirs may have been identified herein. However, so as to properly serve John Lucidon, deceased mortgagor and real owner, and any surviving heirs who are unknown to the Plaintiff, but who may have an interest in the mortgaged premises, the Plaintiff seeks service by publication with regard to the Notice of Sheriff's Sale and posting only, of the mortgaged premises with regard to all subsequent pleadings, including, inter alia, the Notice of Sheriffs Sale, that require personal service. Pa.R.C.P. 430(b)(1) provides for service by publication. Further, Pa.R.C.P. 430(b)(2) provides for service by publication on unknown heirs: When service is made by publication upon the heirs and assigns of a named former owner(s) or party in interest, the court may permit publication against the heirs or assigns generally if it is set forth in the complaint or an affidavit that they are unknown. In conformity with Pa.R.C.P. 430(b)(2), the Plaintiff sets forth, as verified, in the within Motion, that there may be unknown heirs. In order to complete service on the Defendants deceased mortgagor and real owner by and through their surviving "unknown heirs", so as to move this foreclosure action forward to ultimate disposition, the Plaintiff respectfully requests that this Honorable Court, pursuant to Pa.R.C.P. 430 et seq., and for all the reasons hereinbefore stated, and in the attached Motion, grant a Special Order directing service of the Notice of Sheriffs Sale by publication on, deceased mortgagor and real owner, and the "Unknown Heirs"; and service of all subsequent pleadings on John Lucidon, deceased mortgagor and real owner, and on the "Unknown Heirs" that require personal service, by posting only, of the subject premises located at 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: A?torne ALAN M. MINA O, ESQUIRE VERIFICATION The undersigned, hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: SeptemberJD , 2010 UDREN LAW OFFICES, P.C. BY: ALAN M. MINATO;?-SQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings*udren.com Wells Fargo Bank, National Association as € COURT OF COMMON PLEAS Trustee for SABR 2004-OP 1 Mortgage Pass- CIVIL DIVISION Through Certificates, Series 2004-OP I Cumberland County Plaintiff NO. 06-2390 Civil Term V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendants CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that I have served or caused to be served true and correct copies of the Motion For Service Pursuant to Special Order of Court upon the following person named herein at their last known address or their attorney of record by: Regular First Class Mail Date Served: September Jb , 2010 TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 Rosa Lucidon a/k/a Rosa Maria Lucidon 1910 Spring Road Carlisle, PA 17013 UDREN LAW OFFICES, P.C. for Plaintiff ALAN M. MINATO, ESQUIRE f SFp z z zoo 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank, National Association as Trustee for SABR 2004-OP 1 Mortgage Pass- Through Certificates, Series 2004-OP 1 Plaintiff v. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendants NO. 06-2390 Civil Term ORDER C'? r-3 ~9m ~,.i ~,-:kA C~...7 ~~~ ...... f. r.. Y'; .+ ~ A ~ 1 __. , r~ t .._~; . -- , c--, _, AND NOW, this a ~ day of , 20 , u on o~ ~0 p consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Notice of Sheriff's Sale on deceased mortgagor and real owner John Lucidon, and upon any and all "Unknown Heirs" of John Lucidon, deceased mortgagor and real owner, shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P. 430(b)(1) the Notice of Sheriff's Sale once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service all subsequent pleadings upon the deceased mortgagor and real owner and the "Unknown Heirs" that require personal service on each Defendant shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of the said subsequent pleadings on the most public part of the property located at: 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013, which is the subject matter of this action in mortgage foreclosure. ih~.l l£.ck~ ~y ~ ~. ~,;~~ 9~~~,~~y~~~~ _ -/ BY THE COUR~: ~.~v - :.~ ,.-~ :- J. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ,SARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKENA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Cl) 856-669-5400 C Wells Fargo Bank, National Association as ? cz; COURT OF COMMON PLEgM Trustee for SABR 2004-OP1 Mortgage Pass- € CIVIL DIVISION Through Certificates, Series 2004-OP1 ` Cumberland County -<A Plaintiff r' V. A ? John Lucidon -? Rosa Lucidon a/k/a NO. 06-2390 Civil Terttg Rose Maria Lucidon Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: to a -? Cd ?.n ern NJ I" 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of mailing. 2. A Notice of Sheriffs 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 "8". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 1? , 2010 UDREN oL9F-i-EE3 Y: -4 Atts?rzieys.-f.cr- MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LQRP,AINE DOYLE, ESQUIRE LAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE'. MARGUERITE L. THOMAS, ESQUIRE J 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 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- -:Cumberland County Through Certificates, Series 2004-OP1 :MORTGAGE FORECLOSURE Plaintiff V. John Lucidon :NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 1910 Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE i* . 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address L/Unemployment Compensation 16th F1., L&I Building Fund Harrisburg, PA 17121 ?Helen V. Warrick 346 E. North Street Carlisle, PA 17013 ,/A Marian M. Conrad 1050 Peters Mountain Road Dauphin, PA 17108 c/o Neil J. Rovner, Esquire 4503 North Front Street Harrisburg, PA 17110 (Jerry Danyluk 834 Acri Road, Mechanicsburg, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank, National 1270 Northland Drive, Suite 200 Association as Trustee for Mendota Heights, MN 55120 SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1 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 Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PQ 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 1910 Spring Road (New Middleton Township) Carlisle, PA 17013 Any and All Unknown Heirs of 1910 Spring Road John Lucidon, deceased (New Middleton Township) mortgagor and real owner Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn'falsification to authorities. UDREN LAW OFFICES,,P.C. DATED: November (V , 2010 Mark J. Udren, ESQM'-.;--- Attorney for Plaintiff MARK J. UDREN, ESQ IRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ES UIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. 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 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1 Plaintiff V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County PLEAS NO. 06-2390 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): John Lucidon and Rosa Lucidon a/k/a Rose Maria Lucidon PROPERTY: 1910 Spring Road, (New Middleton Township) Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on September 8. 2010, at 10:00 A.M., in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 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 C- O C (A C7 Q, 0 O 3 :3 w co Q C y ;U n cD O a Q r c -? 0 ? O A SD O N CD r c 0 CL O O O O O W n C a' CD w Q r -I in o m W A W N -? O fD co -I O (n A co N r- m Z CL W 0 O 3 -4 CD D ( O N c 3 f1 CD O a O D M f N W ?+ fD ? n O N ? cnv nn z ?4 3 p? dog ?? m =m ?0 Z(DM 0M0 -fo 0c 3 m Da C. Z%. -o 0 ¢n ?+3 oy C7m? m m C m c D pm W v u ? v (a M D = .M Z m3 ; F d - o ? °? 9m ? ?3 _ a Z C N DC? C? ° Moz (1 ° a n Zi ad o O W ?,' W G ?°'p m Or I1 O n?po? ;a ?m ch v m ( ems ( a moo. ?c W rn c0 3 0 xn C ' m Ch c D N? C) Wo o fD =y ?? 4 m a n -I 0 _ m m c r ? c a)- 50 n9 . C s o Dx D Z ?o-1 r? n Orn cr m a o ? Wa ma N Z -i C ? O O - -cn . m - ;a n m Z 0 >- 3 Grn n m y' v D a y - ' ? 7 o n m a 3 o o cap) (A D cr c D (7 co a (7 ' nD - w0 ?m y y s D v O z ch fA om M o a' D ' D -4 o w D = m _0 y rn , w m D v m N ° „ No j ? C: -i z D o o N IiZO x D PI a v °?° D Q' ? O 0 w y `° o m w m ? El ?? m 0 ' r n w a am Co N d m 1 d a 1 •r ? 0161126619216 ' CD ? C] CD r- El t11y d, b ? \ 20 04 m3Rz x a cb Q . v 1 (D ( D H m c3 _ 0 06129/12010 fto , i Mailed From 08003 • o o M c I US POSTAGE o g . m 1 _ o 0 ca 2 n = m 3 o w t ?ao ca ox w & m y 0 0) ° 0 a 3.c 9 I F a Sm 01 7 D ??N? ? . T ° m(a?M_= ? n CCCN < G?' m NV 6, = - 0 m R c o m m = m mg $fo w <D ?d y a S y v OON me -m (D ? c n m.?w? c d o :3 > x v???wo. ? g Ol N ? 0 m° g m a m ? = m m a?i n m CD N ? °? m 3a maw 3 w .m av nC CLOD y aaa.?3 x Zm °mm a m a••0 6 O Cl) v (D r; O Om rma 0T -O N 0 0 . v 0 c0) ?m3m' pl X 1 ,0 O O n v3= m g= m m m T;u N O ym 0 ?n 3 :0 - 7O C L aml6g° m c m ac nto N• W coo Q n w3 m 3 CD N mniS?m3 ? (D2 m pc ?? wG .. _ mo?mb? ( N ( D _ y m omm o X 181 A M MARS J. UDREN* STUART WINNEG** LORRAINE DOYLE** ALANM. MINATO*** C11,M.RA MAMMA LOUISA. SIMONI*** ADAM L. AA YES" MARGUERITE L. THOMAS*** * ADAII77BD NJ, PA, FL "• ADM"M PA ADMITTED NJ, PA TINA MARIE RICH OFFICE ADMINISTRATOR UDREN LAW OFFICES, AC. WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856-669-5400 FAX. 856-669-5399 FREDDIE MAC PENNSYLVANL4 DESIGNATED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE November 9, 2010 Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 P NSYLVANL4 OFFICE Re: Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1 VS. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Cumberland County C.C.P. No. 06-2390 Civil Term Dear Prothonotary: In connection with the above file, enclosed please find Praecipe to File Proof of Service for filing. Also enclosed is an extra copy of the Praecipe to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for youriassistance with this matter. /dbs Enclosure CC: Sheriff of Cumberland County 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. ARKENA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank, National ':.COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 1270 Northland Drive :NO. 06-2390 Civil Term Suite 200 Mendota Heights, MN 55120 Plaintiff V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November `li , 2010 UDREN T " iF1 F-S- P. C . BY: Attorneys-fir tiff MARK J. UDREN,.-. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE LAN M. MINATO,,ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, $SQUIRE MARGUERITE L. THOMAS, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank, National Association as Trustee for SABR 2004-OP I Mortgage Pass- Through Certificates, Series 2004-OP 1 Plaintiff V. NO. John Lucidon Rosa Lucidon a4da Rose Maria Lucidon Defendants ORDER 06-2390 Civil Term SFP 2 2 2010 AND NOW, this ?,? day of upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Notice of Sheriff's Sale on deceased mortgagor and real owner John Lucidon, and upon any and all "Unknown Heirs" of John Lucidon, deceased mortgagor and real owner, shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P, 430(b)(1) the Notice of Sheriff's Sale once in the local legal publication and once in a newspaper of general circulation within the County, and, pursuant to Pa.R.C.P. 430, service all subsequent pleadings upon the deceased mortgagor and real owner and the "Unknown Heirs" that require personal service on each Defendant shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of the said subsequent pleadings on the most public part of the property located at: 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013, which is the subject matter of this action in mortgage foreclosure;. BY THE COUR J. EXHIBIT B Wells Fargo clank, National Association, as Trustee, et. al., Plaintiff(s) VS. John Lucidon, et. al„ Defendant(s) UDR£N LAW OFFICES Ms. Henni Crommarty I I I Wooderest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 _ Service of Process by APS International, Ltd. 1-800-328-7171 An tKt%%NAT10-%L ++ APS International Plaza 1??_ 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: IVA33-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --John Lucidon, by posting Court Case No. 06-2390- Civil Term State oL• County of: Name of Server. undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was n'ott/ aparty to this action: Dateffime of Service: that on the Lsk day of , 20 ILL?- at Z.-o'clock AM Place of Service: at 1910 sprin= Road (New Middleton Twp) J n Carlisle, PA 1,7013 Documents Served: the undersigned served the documents described as: Notice of sheriffs sale of Resl Property w/ Order Service of Process on: A true and correct copy of the aforesaid document(s) was served on: John Lueldon, by posting Person Served, and Method of Service: By personally delivering them into the hands of the person to be served. delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with John Lucidon, by posting at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex : Skin Color : Hair Color : Facial Hair A r. Age Approx. Height Approx. Weight To t est of y knowledge an belief said person was not engaged in the US Military at the a of se cc. Signature of Serv j n rsi ed dec es under of perjury Subscribed and sworn to before me this h t foregoi is t. day of 20 Signet Server N Publi (Commi on :xpires) APS International, td. 0U ,s of AEriNSYLV?wIA C . Nc?'sr; Seal srrlmie L. Peters. r4olm PubM? ? 91 E ? YM? ?on of Notariss EXHIBIT B MARK J. UDREN* STUART WINNEG** LORRAINE DOYLE** ALANM. MINATO*** CIIANDRA M. ARKEMA*** ADAML %AYES** MARGUERML THOMAS*** * ADM ZD NJ, PA, FL •• ADMIT6D PA •" ADAMM) NJ, PA TINA MARIE RICH OFFICE ADMMISMTOR UDREN LA W OFFICES, A C. WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856-669-5400 FAX. 856-669-5399 FREDDIE MAC PENNSYLVANL4 DESIGNATED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 OFFICE VANIA M65%. 5%. Re: Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1 VS. John Lucidon & Rosa Lucidon a/k/a Rose Maria Lucidon Cumberland County C.C.P. No. 06-2390 Civil Term Gentlemen: In connection with the above file, enclosed please find Praecipe to File Proof of Publication. I have enclosed an extra copy of the Praecipe to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. /hac Enclosure UDREN LAW OFFICES, P.C. 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 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 Plaintiff ::NO. 06-2390 Civil Term V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (s) PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proof of Publication with regard to the captioned matter. DATE: November 111, 2010 UDREV---1:0,W-OFFICES , . C. =Rff. ys for Plai UDREN- -- RE STUART WINNEG, ESQUIRE L RRAINE DOYLE, ESQUIRE vALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE SFP 2 2 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank, National Association as Trustee for SABR 2004-OP 1 Mortgage Pass- Through Certificates, Series 2004-O.P1 Plaintiff V. € NO. 06-2390 Civil Term John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendants ORDER AND NOW, this d day of 126 upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Notice of Sheriff's Sale on deceased mortgagor and real owner John Lucidon, and upon; any and all "Unknown Heirs" of John Lucidon, deceased mortgagor and real owner, shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P. 430(b)(1) the Notice of Sheriff's Sale once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service all subsequent pleadings upon the deceased mortgagor and real owner and the "Unknown Heirs" that require personal service on each Defendant shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of the said subsequent pleadings on the most public part of the property located at: 1910 Spring Road, (New Middleton Township), Carlisle, PA 17013, which is the subject matter of this action in mortgage foreclosure, BY -THE COUR°I': J. EXHIBIT B 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 publicationattached 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 October 8, 2010 sa Marie Coyne, for SWORN TO AND SUBSCRIBED before me this 8 day of October, 2010 Q"40 Notary NOTARIAL SEAL DEBORAH A COWN8 NO" Pubk BOROUGH. CWNBERLAN? COUIM Y;IffAft" ENOM Apr K.204 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. EXHIBIT B CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 06-2390 CIVIL TERM Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass-Through Certificates, Series 2004-OP1 1270 Northland Drive, Suite 200, Mendota Heights, MN 55120, Plaintiff John Lucidon and Rosa Lucidon a/k/a Rose Maria Lucidon, 1910 Spring Road, Carlisle, PA 17013 Defendants NOTICE OF SALE OF REAL PROPERTY To: John Lucidon (deceased mort- gagor and real owner) and Any and All Unknown Heirs of John Lucidon (deceased mortgagor and real owner), 1910 Spring Road Carlisle, PA 17013, Defendants Your house (real estate) at 1910 Spring Road, (New Middleton Town- ship) Carlisle, PA 17013 was sched- uled to be sold at the Sheriff's Sale on September 8, 2010 at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. SEPTEMBER 8, 2010 SALE POSTPONED TO NOVEMBER 3, 2010 PROPERTY DESCRIPTION: ALL THOSE TWO CERTAIN tracts of land, together with improvements thereon, erected situate in North Middleton Township, Cumberland County, Pennsylvania, more par- ticulary bounded and described as follows; TRACT NO. 1 BEGINNING at a point in the center of Pennsylvania State Highway Route No. 34 leading from the Borough of Carlisle to the Borough of New Bloomfield, which point is in the northern line of Car- lisle Avenue (which street located has been changed and is now called Wagner Street), as indicated on the Plan of Lots adopted by George H. Schlusser and designated as Plan No. 1 of Schlusser Village, said Plan being recorded in the Office of the Recorder of Deeds in and for Cum- berland County, Pennsylvania, in Plan Book 7, Page 5; thence along the northern side of said Carlisle Avenue, North 84 degrees 45 minutes West, a distance of 152.8 feet to a point in line of land now or formerly of George H. Schlusser; thence along said lands now or formerly of George H. Schlusser, North 5 degrees 15 minutes East, a distance of 259.5 feet to a point in line of Lot No. 6 on the said Plan of Lots; thence along said Lot No. 6, South 84 degrees 45 min- utes East, a distance of 152.8 feet to a point in the center of the aforesaid Pennsylvania State Highway Route 34; thence along the center of said Pennsylvannia State Highway Route No. 34, South 5 degrees 15 minutes West, a distance of 259.5 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a two-story frame dwelling house and concrete block garage known and numbered as 1910 Spring Road, Carlisle, Pennsylvania. TRACT NO. 2 ON THE NORTH by Tract No. 1 above described; on the east by the Carlisle-New Bloomfield Road (known as Pennsylvania Route No. 34); on the south by Wagner IEXHOT B CUMBERLAND LAW JOURNAL Street as shown on the Revised Plan Oct. 8 of Fry Avenue Lots on Plan No. 4 of Schlusser Village, which plan is recorded in the said Recorder's Of- fice in Plan Book 7, page 47; and on the west by Lot Nos. 67 and 68 as shown on said revised plan of Fry Avenue lots. BEING a portion of Lot No. 4 and part of the former Carlisle Avenue (er- roneously said in prior deed be part of Lot No.5) as shown on Plan No. 1 of Schlueser Village, which plan is recorded in the said Recorder's Office in Plan Book 7, Page 5. Containing 50 feet more or less, in front on said Route No. 34 and extending in depth at an increasing width of 150 feet, more or less, and having a width in the rear of 55 feet, more or less. THE ABOVE two lots of ground are conveyed subject to the building and other restrictions as shown on said plan of lots recorded as aforesaid. BEING KNOWN AS: 1910 Spring Road, Carlisle, PA 17013. PROPERTY ID NO.: 29-16-1094- 241. TITLE TO SAID PREMISES IS VESTED IN John Lucidon and Rose Maria Lucison, husband and wife by deed from Leon C. Morrison and Jeannette Morrison, husband and wife dated 11/13/2003 recorded 11 / 18/2003 in Deed Book 260 Page 2040. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. Attorneys for Plaintiff 111 Woodcrest Rd. Ste. 200 Cherry Hill, NJ 08003 (856) 482-6900 EXHIBIT B PROOF OF PUBLICATION State of Pennsylvania, County ames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County news State aforesaid, being duly sworn, deposes of Carlin eSCounty and State aforesaid, was 1 of general circulation in the Borough established December 13th, 1881, since which date THE Na INEL has been retouii issued in said County, and that the printed no publicion attached exactly the same as was printed and published in the regular editions and issues o THE SENTINEL on the following day(s): October 6, 2010 COPY OF NOTICE OF PUBLICATION NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTQN - LAW NO. 06-2390 CIVIL TERM Wells Fargo Bank, National Association as Trustee for SABR 200443P1 Mortgage Pass - Through Certificates, Series 2004-OP1 1270 Northland Drive Suite 200 Mendota Heights, MN 55120, Plaintiff v. John Lucidon and Rose Lucidon a/k/a Rose Maria Lucidon, Defendants 1910 Spring Road Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY To: John Lucidon (deceased mortgager and real owner) and Any and All Unknown Heirs of John Lucidon (deceased mortgagor and real owner), Defendants, 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road, (North Middleton Township) Carlisle, PA 17013 was scheduled to be sold at the Sheriffs Sale on September 8, 2010 at 10"00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plnint?f above (the mortgagee) against you. H the sale is postponed, the property will be rellsted for the Next Available Sale. SEPTEMBER 8, 2010 SALE POSTPONED TO NOVEMBER 3, 2010 ON Y D RI f N: E TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TRACT fO. 1 BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STREET LOCATED HAS BEEN CHANGED AND IS NOW CALLED WAGNER STREET), AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H. SCHLUSSER AND DESIGNATED AS PLAN NO.1 OF SCHLUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 7, PAGE 5; THENCE ALONG THE NORTHERN SIDE OF SAID CARLISLE AVENUE, NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER; THENCE ALONG SAID LANDS NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES 15 MINUTES EAST, A DISTANCE OF 259.5 FEET TO A POINT IN LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS; THENCE ALONG SAID LOT NO. 6. SOUTH 84 DEGREES 45 MINUTES EAST, A DISTANCE OF 152.8 FEET TO A POINT IN THE CENTER OF THE AFORESAID PENNSYLVANIA STATE HIGHWAY ROUTE 34; THENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34, SOUTH 5 DEGREES 15 MINUTES WEST, A DISTANCE OF 259.5 FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY FRAME DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AND NUMBERED AS 1910 SPRING ROAD, CARLISLE, PENNSYLVANIA. TRACT BLOOMFIE D ROAD (KNOWS AS PENNSYLVANIA ROUTE NO. 34); ON THE SOUTH Y WAGNER STREET S SHOWN ON THE REVISED PLAN OF FRY AVENUE LOTS ON PLAN NO.4 OF SCHLUSSER VILLAGE, WHICH PLAN IS'RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 47; AND ON THE WEST BY LOT NOS. 67 AND 68 AS SHOWN ON SAID REVISED PLAN Of FRY AVENUE LOTS. BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLISLE AVENUE (ERRONEOUSLY SAID IN ?- PRIOR QE*O BE PART OF LOT NO: S6) AS SHOWN ON PLAN NO. 1 OF SCHLUSSER VILLAGE, WHICH PLAN IN RECORDED IN THE'SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 5. CONTAINING 50 FEET MORE OR LESS, IN FRONT ON SAID ROUTE NO. 34 AND EXTENDING IN DEPTH AT AN INCREASING WIDTH OF 150 FEET, MORE OR LESS, AND HAVING A WIDTH IN THE REAR OF 55 FEET, MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUILDING AND OTHER RESTRICTIONS AS SHOWN ON SAID PLAN OF LOTS RECORDED AS AFORESAID. BEING KNOWN AS: 1910 Spring Road Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-241 TITLE TO SAID PREMISES IS VESTED INJOHN LUCIDON AND ROSE MARIA LUeCON,14USBAND AND WIFE BY DEED FROM LEON C. MORRISONANDJEANNETTE MORRISON, HUSBAND AND WIFE DATED 11/1312003 RECORDED 11/18/2003 IN DEED BOOK 260 PAGE 2040. Mark J. Udren, Stuart Winneg, Lorraine Doyle, Alan M. Minato, Chandra M. Arkema, Louis A. Simoni, Adam L. Kayes and Marguerite L. Thomas, Attorneys for Plaintiff Urden Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Affiant further deposes that he/she i; interested in the subject matter of the aforesaid notice or advertisement, an all allegations in the foregoing staten to time, place and character of public are true. Sworn to and subscribed before me t llf? Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY Irv Comm"I;an Expires Jan 27, 2014 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13t',, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following, day(s): October 6, 2010 COPY OF NOTICE OF PUBLICATION .. ?.., --•b ., ...-k, -- m nal idle at harbrs. .b g said- Swift Supply, he Said !E claims a huge chunk of reve ancies, because customers c r to be celed plans to build do e same Al home improvements complete constructio divert- new houses with the ur ;kepti- tainty that followed th( to add- plosion and oil gusher. tws the after he applied for c, pensation, he initially id has told "we weren't in the Ilion to graphic area of the spill:' nants. Just last week, how( Ad not Silvers got a check fox e total erything he asked fox uested would not say how muc I Fein- received. Feinberg has .aid the tided that proximity t( ;' given fected areas will no lox 17013 Was scheduled to be is filed play a role in compenss dZ". aRoom 22nd nlo?ogagee) approval. 1.1.. sal.. Vallable e num- "I'm very happy," S']3, 2010 s actu- said, "but there's still a 1 118, as businesses that haven't I S THEREON, ERECTED SYLVANIA, MORE wg4c a 1i aptnqw -uses s;eq} liq Arnie WV * u su 2mgsuasH o} pus S1 axV111MRl a}P}s astA aquiouc s,iaquisgo -pe oum siaAmul sq pageis x o; saapeal asnoH sr neaanq aoua.xaJaa aq j, lnoa 11 `T11q jeg4 do AspuM asnpa a}anaS ag13I asuodsw s so; nsamq aqua apuaS Qg4T4 pW -aa;ar au} palsy r}sulms I }ouuso pus asnoH slsrotDo pa}oap }suPuo }snuff saxu} ARmi io; s}uaumj1nbea sons ut }utI} fiq u °uo}}n} -msui asuaaout o} so}uues T 1 a}s}s ai}} zapufl Aqua'WLAA,4pt 'ollxgEO; •presuo} }uauxpuauiu uu SIB "4 uop > `Wgpasssd-asnoH -OES4x9-sv.2 au} pagag4v 2x81 o} sap'coap a}s asnoH a iaW a Affiant further deposes that he/she is not interested in. the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this I A111, Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Comm-s?ian Expires Jan 27, 2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson GVv Sheriff b.°a et cKul yr? Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF Wells Fargo Bank, N.A., vs. John Lucidon (et al.) Case Number 2006-2390 SHERIFF'S RETURN OF SERVICE 06126/2010 Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on 6-26-2010 at 1030 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John & Rosa Lucidon, located at, 1910 Spring Road, Carlisle, Cumberiand County, Pennsylvania according to law. 06/30/2010 03:22 PM - Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John Lucidon, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, John Lucidon is deceased. 06/30/2010 03:22 PM - Shawn Harrison, Deputy Sheriff, who being duly swom according to law, states that on 6/30/1C at 1520 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Rosa Lucidon, by making known unto, Jaime Guerrero, Adult Son, at, 1910 Spring Road, Carlisle, Cumberland County, Pennsylvania its contents and a the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $1,263.42 July 02, 2010 SO ANSWERS, s RON R ANDERSON, SHERIFF (c) CoamtySuite Sheriff. TeleosoR, Inc. r 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank, National Association as Trustee for SABR 2004-OP1 Mortgage Pass- Through Certificates, Series NO 2004-OP1 Plaintiff V. John Lucidon Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) 06-2390 Civil Term eo O R D E R 7 r) Cn L-j - o C 0 c-? co 'i ? AND NOW, this D day of December, 2010, after -< `-D consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 1910 Spring Road, Carlisle, PA 17013, it is hereby ORDERED that the said Sale currently scheduled for December 8, 2010, is extended 1 (one) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for January 5, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the December 8, 2010 Sheriff's Sale. ' BY OURT: J. TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 ,-Trosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 wren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff Cumberland County courthouse One Courthouse Square Carlisle, PA 17013-3387 C3 -n --4 s ni -n r rn M ? O , -+ca =r--n C :)-n z c-) o? D SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor w00V Qt Cirira6,rrl44# t +ILC.? j '' Il.? Zlla i .' N 27 CUMBERLAND COUN iY RENWSYLVAfflA Wells Fargo Bank, N.A. vs. John Lucidon (et al.) Case Number 2006-2390 SHERIFF'S RETURN OF SERVICE 06/26/2010 Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1030 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John & Rosa Lucidon, located at, 1910 Spring Road, Carlisle, Cumberland County, Pennsylvania according to law. 06/3012010 03:22 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John Lucidon, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, John Lucidon is deceased. 06/30/2010 03:22 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 6/30/1C at 1520 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Rosa Lucidon, by making known unto, Jaime Guerrero, Adult Son, at, 1910 Spring Road, Carlisle, Cumberland County, Pennsylvania its contents and a the same time handing to him personally the said true and correct copy of the same. 09/02/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/3/2010 10/19/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/8/2010 12/08/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, PA on Januart 5, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Mark Udren, on behalf of Wells Fargo Bank, N.A. of 4600 Regent Blvd, Ste 200, Irving, TX 75603 being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,522.80 January 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF tlg. 06 Fd , okelk a-0o Pd. Lie. a's 113 b?o Sy3©3 ;c ,"'our,ySui[8 Shev:ff. Te en-a11. Inc. % 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, National :COURT OF COMMON PLEAS Association as Trustee for SABR E CIVIL DIVISION 2004-OP1 Mortgage Pass-Through :Cumberland County Certificates, Series 2004-OP1 Plaintiff :MORTGAGE FORECLOSURE V. John Lucidon NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, National Association as Trustee for SABR 2004- 0P1 Mortgage Pass-Through Certificates, Series 2004-OP1, 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: 1910 Spring Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address John Lucidon 1910 Spring Road Carlisle, PA 17013 Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 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 Bureau of Compliance Unemployment Compensation Fund Address to follow 16th Floor, L&I Building Harrisburg, PA 17121 Helen V. Warrick 346 East North Street Carlisle, PA 17013 A Marian M. Conrad Address to follow Jerry Danyluk 834 Acri Road Mechanicsburg, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank, National 1270 Northland Drive Association as Trustee for Suite 200 SABR 2004-OP1 Mortgage Mendota Heights, MN 55120 Pass-Through Certificates, Series 2004-OP1 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 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 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 1910 Spring Road Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 7, 2010 UDREN LAW ICES, P.C. BY. 'c -----Atto.rneys__ for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE TJDREN 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, National =COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 :MORTGAGE FORECLOSURE Plaintiff V. John Lucidon :NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosa Lucidon a/k/a Rose Maria Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, 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 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 THOSE TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARY BOUNDED AND DESCRIBED AS FOLLOWS; TRACT NO.1 BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STREET LOCATED HAS BEEN CHANGED AND IS NOW CALLED WAGNER STREET), AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H. SCHLUSSER AND DESIGNATED AS PLAN NO. 1 OF SCHLUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 7, PAGE 5; THENCE ALONG THE NORTHERN SIDE OF SAID CARLISLE AVENUE, NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER; THENCE ALONG SAID LANDS NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES 15 MINUTES EAST, A DISTANCE OF 259.5 FEET TO A POINT IN LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS; THENCE ALONG SAID LOT NO. 6, SOUTH 84 DEGREES 45 MINUTES EAST, A DISTANCE OF 152.8 FEET TO A POINT IN THE CENTER OF THE AFORESAID PENNSYLVANIA STATE HIGHWAY ROUTE 34; THENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34, SOUTH 5 DEGREES 15 MINUTES WEST, A DISTANCE OF 259.5 FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY FRAM DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AND NUMBERED AS 1910 SPRING ROAD, CARLISLE, PENNSYLVANIA. TRACT NO.2 ON THE NORTH BY TRACT NO.1 ABOVE DESCRIBED; ON THE EAST BY THE CARLISLE-NEW BLOOMFIELD ROAD (KNOWN AS PENNSYLVANIA ROUTE NO. 34); ON THE SOUTH BY WAGNER STREET AS SHOWN ON THE REVISED PLAN OF FRY AVENUE LOTS ON PLAN NO.4 OF SCHLUSSER VILLAGE, WHICH PLAN IS RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 47; AND ON THE WEST BY LOT NOS. 67 AND 68 AS SHOWN ON SAID REVISED PLAN OF FRY AVENUE LOTS. BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLISLE AVENUE (ERRONEOUSLY SAID IN PRIOR DEED BE PART OF LOT NO. 5) AS SHOWN ON PLAN NO. 1 OF SCHLUSSER VILLAGE, WHICH PLAN IS RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 5. CONTAINING 50 FEET MORE OR LESS, IN FRONT ON SAID ROUTE NO. 34 AND EXTENDING IN DEPTH AT AN INCREASING WIDTH OF 150 FEET, MORE OR LESS, AND HAVING A WIDTH IN THE REAR OF 55 FEET, MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUILDING AND OTHER RESTRICTIONS AS SHOWN ON SAID PLAN OF LOTS RECORDED AS AFORESAID. BEING KNOWN AS: 1910 Spring Road Carlisle, PA 17013 PROPERTY IV Nd.: 29-16-1094-241 TITLE TO SAID PREMISES IS VESTED IN JOHN LUCIDON AND ROSE MARIA LUCISON, HUSBAND AND WIFE BY DEED FROM LEON C. MORRISON AND JEANNETTE MORRISON, HUSBAND AND WIFE DATED 11/13/2003 RECORDED 11/18/2003 IN DEED BOOK 260 PAGE 2040. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF r 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, National :COURT OF COMMON PLEAS Association as Trustee for :CIVIL DIVISION SABR 2004-OP1 Mortgage Pass- :Cumberland County Through Certificates, Series 2004-OP1 :MORTGAGE FORECLOSURE Plaintiff V. John Lucidon :NO. 06-2390 Civil Term Rosa Lucidon a/k/a Rose Maria Lucidon Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: John Lucidon 1910 Spring Road Carlisle, PA 17013 Your house (real estate) at 1910 Spring Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,217.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) i YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. .1. If the Sheriffs 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 THOSE TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARY BOUNDED AND DESCRIBED AS FOLLOWS; TRACT NO.1 BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STREET LOCATED HAS BEEN CHANGED AND IS NOW CALLED WAGNER STREET), AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H. SCHLUSSER AND DESIGNATED AS PLAN NO. 1 OF SCHLUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 7, PAGE 5; THENCE ALONG THE NORTHERN SIDE OF SAID CARLISLE AVENUE, NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER; THENCE ALONG SAID LANDS NOW OR FORMERLY OF GEORGE. H. SCHLUSSER, NORTH 5 DEGREES 15 MINUTES EAST, A DISTANCE OF 259.5 FEET TO A POINT IN LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS; THENCE ALONG SAID LOT NO. 6, SOUTH 84 DEGREES 45 MINUTES EAST, A DISTANCE OF 152.8 FEET TO A POINT IN THE CENTER OF THE AFORESAID PENNSYLVANIA STATE HIGHWAY ROUTE 34; THENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34, SOUTH 5 DEGREES 15 MINUTES WEST, A DISTANCE OF 259.5 FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY FRAM DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AND NUMBERED AS 1910 SPRING ROAD, CARLISLE, PENNSYLVANIA. TRACT NO.2 ON THE NORTH BY TRACT NO.1 ABOVE DESCRIBED; ON THE EAST BY THE CARLISLE-NEW BLOOMFIELD ROAD (KNOWN AS PENNSYLVANIA ROUTE NO. 34); ON THE SOUTH BY WAGNER STREET AS SHOWN ON THE REVISED PLAN OF FRY AVENUE LOTS ON PLAN NO.4 OF SCHLUSSER VILLAGE, WHICH PLAN IS RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 47; AND ON THE WEST BY LOT NOS. 67 AND 68 AS SHOWN ON SAID REVISED PLAN OF FRY AVENUE LOTS. BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLISLE AVENUE (ERRONEOUSLY SAID IN PRIOR DEED BE PART OF LOT NO. 5) AS SHOWN ON PLAN NO. 1 OF SCHLUSSER VILLAGE, WHICH PLAN IS RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 5. CONTAINING 50 FEET MORE OR LESS, IN FRONT ON SAID ROUTE NO. 34 AND EXTENDING IN DEPTH AT AN INCREASING WIDTH OF 150 FEET, MORE OR LESS, AND HAVING A WIDTH IN THE REAR OF 55 FEET, MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUILDING AND OTHER RESTRICTIONS AS SHOWN ON SAID PLAN OF LOTS RECORDED AS AFORESAID. BEING KNOWN AS: 1910 Spring Road 1 Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-241 TITLE TO SAID PREMISES IS VESTED IN JOHN LUCIDON AND ROSE MARIA LUCISON, HUSBAND AND WIFE BY DEED FROM LEON C. MORRISON AND JEANNETTE MORRISON, HUSBAND AND WIFE DATED 11/13/2003 RECORDED 11/18/2003 IN DEED BOOK 260 PAGE 2040. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2390 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR SABR 2004-OP1 MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OPI, Plaintiff (s) From JOHN LUCIDON AND ROSA LUCIDON A/K/A ROSE MARIA LUCIDON (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 $170,217.37 L.L. Interest FROM 6/7/2006 TO DATE OF SALE 9/8/2010 - ONGOING PER DIEM OF $45.77 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $71,172.35 Atty's Comm % Due Prothy $2.00 Atty Paid $1,587.09 Other Costs Plaintiff Paid Date: JUNE 9, 2010 David D. Buell, 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 TRUE COPY FROM RECORD In T"wno" wlw? 1 Ma w0D Mt 1nW hwd and the .w??fattll or "M at This x=!: ?d 3D.b aolloutpooo 01731sg pa-d :Xg OIOZ `t,i aunj :all6,Q vioniq palwodioaui aqua.iajax siuj Aq puu jum sigl gjIm pat3 «V„ llglgxg uo paquasap Aiinj azouz `alsilwo `pRog SuudS 0161 `st, pa.zaguznu pue umou}I `Vd `AjunoD puLIjoqumo `gOnozog aisiliuD ui palunlts Aliadoid pa.z auj ui Isanjui s,juepuajap auj uodn paznai jjuauS aqj O I OZ `t, I aunt up '11914 Yll !A 1?trt ?j>.??uct??sl!u?? €:?€?My! 1?;t?t+ay5; u? .°r..ri,?; ; fl I PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a-legal periodical published in the Borough of Carlisle in the County and.State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 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. ('!ea Marie Coyne, 7A/ SWORN TO AND SUBSCRIBED before me this 30 da of Jul 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public [CARLISLE BOROUGH, CUMBERLAND COtNM My Couunft" Expires Apr 28. 2014 doll 9 j ?•, O41 a spry °t °?04,. ens cep e 5°? ?? a°? tig e4'eot?ra Ge ?a° tt• ?. 4,¢? t°y ? do t' c fi 1? ,?04? to yt0' by a .?1 s?tiy ???e c o g"? o $,?4 c o 0 oe ticti°?4c? tit` •tiaa 4w9,'y^o° O. L.tiet`yve¢Ggsc?a ?° o°at tieae of m? Sl oc ° GG'???e ¢¢1poUt??tee?°? pfi e?. 0 q, e??eop 6enp ea 'tit` ,off tiea yep p`? ycc? 40 Ij o a Q`eefi 5tit s e a a 4 e o \y OS' e;,? e eg 41y??g o et ?? ?s ?ygafia9 l Nil zc? -e c' ?o s? ?1 gg 9° ae ee 4 5+ s? 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SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the atr +1 o twNew s Now you know 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 Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 on the date(s) indicated below. That neither she 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 she 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 This ad ran on the date(s) shown below: 07/09/10 07/16/10 07/23/10 a........... Sworn to and s'd sFribed before me his'05Jd of August, 2010 A.D. Notary Public COMMONWEALTH C)F PENNSY?VAN!& _, Notarial 5eea1 5herrlF L. Kisner, Notary Publ c Lower Paxton TwP•, Dauphln County My Comm'issio? n ExPires Nov. zal r Member. PenrisV!°;anla Asscciatior of t -"'es Writ No. 2006-2390 Civil Term Wells Fargo Bank, N.A., as Trustee for SABR 2004-Op1 Mortgage Pass Through Certificates, Series 2004-OP1 Vs John Lucidon Rosa Lucidon, aWa Rose Maria Lucidon Atty: Mark J. Udren ALL THOSE TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARY BOUNDED AND DESCRIBED AS FOLLOWS; TRACT NO. 1 BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHICH STREET LOCATED HAS BEEN CHANGED AND IS NOW CALLED WAGNER STREET). AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H. SCHLUSSER AND DESIGNATED AS PLAN NO. 1 OF SCHLUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLANBOOK 7, PAGE 5; THENCEALONG THE NORTHERN SIDE OF SAID CARLISLE AVENUE, NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF GEORGE H. SCHLUSSER; THENCE ALONG SAID LANDS NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES 15 MINUTES EAST, A DISTANCE OF 259.5 FEET TO A POINT IN LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS; THENCE ALONG SAID LOT NO, 6, SOUTH 84 DE ES 45 MINUrM EAST, A DISTANCE OF 132.8 FEET TO A POINT #N THE CENTER OF THE AFORESAID Vs ow"M 101. lam.' ShOM L. Deitch Atty: David A Banc ,LL that certain. tract of land situate in West 'ennsboro Township, Cumberland County, 'ennsylvania, bounded and described as allows: tEGINNWG at an iron pin in the center line of -R. # 21034 leading from Plainfield to Greason, Which pin is North 4 degrees 48 minutes East to feet from the center line of Township Road T-446; thence by other.land of Lester Gerald humma and wife, North 85 degrees 12 minutes, Vest 210 feet to a stake; thence by the same, forth 4 degrees 48 minutes East, 195 feet to a take; thence by the same, South 85 degrees 12 ainutes Fast, 210 feet to a pin in the center line ?f L.R. # 21034; thence by the center line of said oad, south 4 degrees 48 minutes West, 195 feet o the Place Of Beginning; Containing 40,950 quare feet and being described according to survey thereof by Noel B. Smith, R.S., dated eptember 8, t972, a copy of which is attached ereto as part of this deed. BEING subject to a building set back line which 40 feet West of the proposed right of way he f L.R. # 21034, which latter line is 25 feet West f the existing center line of said road. EING the same premises which Lester Gerald humma and Gayle RuthThumma, husband and ife, by their Deed dated September 26, 1972, t the Cumberland County Recorder of Deeds iffice in Deed Book "V", Volume 24, Page 253, ranted and conveyed unto Dennis G. Deitch and haron L. Deitch, husband and wife, Grantors erein. ARCEL NO. 46-07-0475-028A Writ No.. 2010-2236 Civil Term JPMC Specialty Mortgage LLC Vs George L. Diehl Reshendalene L. Diehl Atty: Mkael. J Clark ALL THAT CERTAIN tact of land with a frame 'welling house and other improvements thereon rected. 1TUATE on the South side of Molly Pitcher fighway in Lees Cross Roads in Southampton 'owhship, Cumberland County, PA, bounded nd described as follows: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said county and State do hereby certify that the Sheriff's Deed in which SABR Trust 2004-OP 1, Trustee is the grantee the same having been sold to said grantee on the 5th day of Janu A.D., 2011, under and by virtue of a writ Execution issued on the 9th day of June, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 06 Number 2390, at the suit of SABR Trust 2004-OP 1, Trustee against John & Rosa aka Rose Maria Lucidon is duly recorded as Instrument Number 201103314. IN TESTIMONY WHEREOF, I have here to set my hand and s of said office this day of Iglecorder i=. f Deeds ?o?ady, PA W cm* First 2014