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HomeMy WebLinkAbout01-5408 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage,Inc, f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, N.C. 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant{s) : NO. 01- Slf08 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013-3387 717-249-3166 or 8DO-990-9108 AY..ISO 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 escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin 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 DONnE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,P A 17013-3387 717-249-3166 or 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 ofit, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 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: Equity One, Incorporated Assignments of Record to: Wells Fargo Home Mortgage, Inc, f/k/a Norwest Mortgage, Inc. Recording Date: 6/17/98 Book: 579 Page: 694 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: 1550 Holly pike South MUNICIPALITY/TOWNSHIP/BOROUGH: South Middleton Township COUNTY: Cumberland DATE EXECUTED: 6/15/98 DATE RECORDED: 6/17/98 BOOK: 1461 PAGE: 146 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 Note 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 9/05/01 principal of debt due and unpaid Interest at 7.375% from 1/01/01 to 9/5/01 (the per diem interest accruing on this debt is $19.90 and that sum should be added each day after 9/05/01) $97,128.07 4,935.20 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $178.08 and that sum should be added on the first of each month after 9/05/01) 1407.14 Late Charges (monthly late charge of $34.71 should be added on the fifteenth of each month after 9/05/01) 222.68 PRO RATA MIP/PMI Other fees Suspense balance Attorneys Fees (anticipated and actual to 5% of principal) 78.46 98.75 (750.00) TOTAL 4..Jl5Ji...AD $108,506.70 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. N6N91 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has not been sent because the Mortgage is insured by the Federal Housing Administration ("FHA") and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant{s) herein in the sum of $108,506.70 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ..--:--' / ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN SOUTH MIDDLETON TOWNSHIP, Cm<<BERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN FOR WEIBLEY ESTATE CONSISTING OF TWO PAGES WHICH WAS PREPARED BY FISHER, MOWERY, ROSENDALE << ASSOCIATES, INC., DATED MAY 14, 1997, A COpy OF WHICH IS RECORDED IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN PLAN BOOK 75, PAGE 45, AS FOLLOWS: BEGINNING AT ,AN IRON PIN SET ON THE NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY 'ANN RHOADS AT THE DIVIDING LINE BETWEEN LOTS NOS. 4 AND 5 AND WHICH IRON PIN SET AT THE PLACE OF BEGINNING IS SOUTH 89 DEGREES 08 MINUTES 18 SECONDS WEST A DISTANCE OF 69,33 FEET FROM LOT NO, 1, MEASURED ALONG SAID NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, THENCE FROM SAID IRON PIN SET AT THE PLACE OF BEGINNING ALONG SAID NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, SOUTH 89 DEGREES 08 MINUTES 18 SECONDS WEST A DISTANCE OF 593.67 FEET TO AN IRON PIN AT A CORNER COMMON TO LOTS NOS. 4 AND 5 AND SAID LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, THENCE ALONG SAID DIVIDING LINE BETWEEN SAID LOTS NOS. 4 AND 5, THE FOLLOWING THREE (3) COURSES AND DISTANCES: (1) NORTH 00 DEGREES 45 MINUTES 20 SECONDS EAST A DISTANCE OF 142.73 FEET TO AN IRON PIN, (2) NORTH 67 DEGREES 55 MINUTES 36 SECONDS EAST A DISTANCE OF 332.91 FEET TO AN IRON PIN, AND (3) SOUTH 47 DEGREES 34 MINUTES 07 SECONDS EAST A DISTANCE OF 383.71 FEET TO AN IRON PIN SET AT THE PLACE OF BEGINNING, THE ABOVE-DESCRIBED LOT OF LAND IS ALL OF LOT NO. 4 AS SHOWN ON SAID SUBDIVISION PLAN FOR WEIBLEY ESTATE, RECORDED AS AFORESAID, ON WHICH THERE IS ERECTED A ONE- STORY FRAME DWELLING HOUSE AND OTHER IMPROVEMENTS, WHICH HAS THE MAILING ADDRESS OF 1550 HOLLY PIKE, CARLISLE, PENNSYLVANIA 17013. IT IS TO BE NOTED THAT THE PROPOSED 50 FEET WIDE PRIVATE RIGHT-OF-WAY SHOWN ON SAID SUBDIVISION PLAN IS HEREBY EXTINGUISHED AND SUBSTITUTED THEREFOR ARE THE RIGHTS PROVIDED IN AGREEMENT DATED FEBRUARY 22, 1996, AND RECORDED IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN MISCELLANEOUS RECORD BOOK 562, PAGE 936, AND THE ABOVE- DESCRIBED PROPERTY IS SPECIFICALLY CONVEYED TOGETHER WITH AND SUBJECT TO THE RIGHT- OF-WAY PROVIDED IN SAID AGREEMENT DATED FEBRUARY 22, 1996, WHICH EXTENDS FROM STATE ROAD 0034 KNOWN AS HOLLY PIKE TO THE ABOVE-DESCRIBED LOT NO, 4 KNOWN AS 1550 HOLLY PIKE. IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 IS CONVEYED TOGETHER WITH AND SUBJECT TO THE RIGHT-OF-WAY EXTENDING FROM TRAFFIC ROUTE NO. 34 KNOWN AS HOLLY PIKE TO LOT NO. 4 ON SAID ABOVE-DESCRIBED TRACT OF LAND AS SET FORTH IN THE RIGHT-OF-WAY AGREEMENT DATED APRIL 22, 1949, AND RECORDED APRIL 22, 1949, IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN MISCELLANEOUS RECORD BOOK 84, PAGE 463. IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 KNOWN AS 1550 HOLLY PIKE IS CONVEYED TOGETHER WITH AND SUBJECT TO A RIGHT-OF-WAY 60 FEET IN WIDTH EXTENDING FROM THE DIVIDING LINE BETWEEN LOTS NOS. 1 AND 5 WESTWARDLY TO SAID LOT NO, 4, THE SOUTHERN LINE OF SAID 60 FEET WIDE RIGHT-OF-WAY BEING SOUTHERN LINE OF THE RIGHT-OF-WAY SHOWN AS A PROPOSED 50 FEET WIDE PRIVATE RIGHT-OF-WAY ACROSS LOT NO. 5 ON SAID SUBDIVISION PLAN FOR WEIBLEY ESTATE, IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 IS CONVEYED TOGETHER WITH A RIGHT-OF-WAY OVER THE GRAVEL LANE EXTENDING ALONG THE EASTERN PORTION OF LOT NO, 5 AT A WIDTH OF 20 FEET FROM LAND NOW OR FORMERLY OF DANIEL W. JOHNSON AND WIFE SOUTHWARDLY TO LOT NO.4 ABOVE-DESCRIBED. ~.1l I FIe A T I_Q....N Mark J. Udren, Esquire, hereby states that he is the attorney for the plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. /LA~ Mark MARK 1. Udren, E T UDREN & FEDERAL EXPRESS FORM DATE:', 9;;3~/ YOUR NAME: .;f h <:..--<- . / pcJ~-e J MJU FILE NUMBER: 0 /)- 7 G (p ~ CU/Y1bei.c/t#U CODN~;( a { f1 0,/1/ r/7/l-1"'- t OFFICE FEDERAL EXPRESS FORM DATE: YOUR NAME: Mm FILE NUMBER: COUNTY OFFICE 0 C) C ~ "'- r:,l) ~ -vi::'I' r" ~ .r: rc C~ '--0 ~.".._, (~ -:;;,,'r a ~:' .-l vI ~ C' g ~ ~:~ \.:.~. 0..',,,,, "' ~ 2c' -- n ~ VI .l:l... ~".c. .,- , ) 00 '""'C) ):C. t': .. .,,---"1. ~ -4 :::J SL z :::> ":0 ,..., ::b ~ .0 :.<: Vv ~ <;;: ~ ...., '" ::l SHERIFF'S RETURN - REGULAR ~ASE'NO: 2001-05408 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS BECRAFT TIMOTHY A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BECRAFT TIMOTHY A the DEFENDANT , at 1455:00 HOURS, on the 20th day of September, 2001 at 1550 HOLLY PIKE SOUTH CARLISLE, PA 17013 by handing to PAMELA J BECRAFT, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.25 .00 10.00 .00 31. 25 r~....t:~~ R. Thomas Kline 09/21/2001 MARK UDREN Sworn and Subscribed to before me this S~ day of By: A.;~ JA~~ .- Deputy S iff (]J~ ..2,,<> I A.D. ~f2~.~ rothonotary . ,~~ 'c:= SHERIFF'S RETURN - REGULAR ~ASE NO: 2001-05408 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS BECRAFT TIMOTHY A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BECRAFT PAMELA J the DEFENDANT , at 1455:00 HOURS, on the 20th day of September, 2001 at 1550 HOLLY PIKE SOUTH CARLISLE, PA 17013 by handing to PAMELA J BECRAFT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: r~..-t:~ R. Thomas Kline 09/21/2001 MARK UDREN Sworn and Subscribed to before me this -!fib day of By: ~1.Jt IA)~ Deputy S riff (})~ ..2o-v I A.D. ~(}~# r thonotary .... \ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. Plaintiff v. Timothy A. Becraft Pamela J. Becraft Defendant(s) ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . . NO. 01-5408 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: December 25, 2001 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorne for Plaintiff V F. RTF T CAT ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned, The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Nam~OSEPH Title: A~ST.SErRETARY Company: WELLS FARGO HOME MORlrQ;AGE i'-J (') 0 0 C N -" s: t- .., '"'Ow "'" f-~:;p rnrn :z: z:o I --"rn Z':P: ",:i>\y (f; .~ ."... '~~'::(?; ?B "'" / /,):.:u ~o :z: ~;-(") ~-rn :;:;2 '1? ~ ~ ~ ~ N ~ ... . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 . . NO. 01-5408 Defendant(s) 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) 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 9/6/01 to 12/25/01 Late charges per Complaint From 9/6/01 to 12/25/01 Escrow payment per Complaint From 9/6/01 to 12/25/01 $108,506.70 2,208.90 138.84 534 24 TOTAL $111.388 68 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of hich is attached hereto. ~ & ASSOCIATES DAMAGES ARE HEREBY ASSESSED DATE: . J~A '} ^1 ;).()O ~ . AS 7JCATED ~ AA~J . PRO PROTHY P , . MARK J. ODREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Timothy A. Becraft Pamela J. Becraft Defendant(s) NO. 01-5408 DATED: TO: December 13, 2001 Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER 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, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. - . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Horne Mortgage, Inc. f/k/a Norwest Mortgage, Inc. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Timothy A. Becraft Pamela J. Becraft Defendant(s) NO. 01-5408 DATED: TO: December 13, 2001 Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 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 DEB IDA 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 USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,- MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-5408 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NOR T H r. A ROLIN A COUNTY OF MECKLENBURG SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Timothy A. Becraft Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Pamela J. Becraft Over 18 As captioned Unknown Sworn to and subscribed before me this day of 2 abov~ Nanfe: LISA J8STI>H Title: ASST. SECRFTA RY Company: (8,- . NOTARYPUBUC !~~~. OFFICIAL SEAl :>1,. KELLY L. AlLSUP ~~ MEl'KLENBURG COUNTY, N.C. My CommissIon ExpIres 01-11-03 1:\'<" ;. t~ t r F&gr! ~ B g ~ Mi ~ n r--- (") 0 0 C N -11 s: C- -0 (1.:1 J:>o =q mm % 2::0 I -.'~ !....:~ Zt;: U\...i' (f) .._., .-J ~.J(~) 2L CI ;po ~:.~=8 '< ~o :x ~40 .,ern --0 \.0 9 )>c: ~ -;> r..n ~ ... .'. -...,-.,.;.(; ": >,~ :;, ' ";,' MARK J. UDREN << ASSOCIATES BY:~ark J. Udren, Esquire ATTY I.D. NO. 04302 1e40 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 : NO. 01-5408 Defendant(s) TO: Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 856-482-6900 MARK J. UDREN & ASSOCIATES BY: JMark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) . . NO. 01-5408 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) 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 9/6/01 to 12/25/01 Late charges per Complaint From 9/6/01 to 12/25/01 Escrow payment per Complaint From 9/6/01 to 12/25/01 $108,506.70 2,208.90 138.84 534 24 TOTAL $111.388.68 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy is attached hereto. ~ & ASSOCIATES DAMAGES ARE HEREBY ASSESSED DATE :. ).':J-< ) 7, :J ^Dd.... AS "Z!:TED . J 12 _ ~ P P~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) TO: Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE . NO. 01-5408 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings ATTORNEY IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: Mark J Udren. Esquire At this telephone number: 856-482-6900 MARK J. ~REN << ASSOCIATES BY: ~ark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s} . . NO. 01-5408 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) for failure to file an Answer to Plaintiff I 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 9/6/01 to 12/25/01 Late charges per Complaint From 9/6/01 to 12/25/01 Escrow payment per Complaint From 9/6/01 to 12/25/01 $108,506.70 2,208.90 138.84 534.24 TOTAL $111,388 68 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of ich is attached hereto. ~ & ASSOCIATES DAMAGES ARE HEREBY ASSESSED AS DATEJ~.J ~ :L~.;L I MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 - . NO. 01-5408 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $111. 388 68 Interest From December 26. 2001 to Date of Sale June 5. 2002 Per diem @$19.90 3.223.80 (Costs to be added) $ ( \_- ~~ - ~ b & ~ :'J.~ 8 g ~[;J ...(q, "- ..... "0 L '" , -tJ.o.~ ~ ~ 0'-<0 a ()o I I ~~ '-' ~ ( 8 ~--u ~ ~ ~ ~ r ~,~ - " . .., .. " .... ....., (") c: s: L. -oce .:,0"" mrn z Z-T": t ~i: -' ~c5 :> ~o 3: 5>~ ~ o C.J N " :}J ,i-on ~~ (~) ~-.=-.;..: :~;~ () -.-j ..,~ """ :D -< MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 . . NO. 01-5408 Defendant{s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: x An FHA insured mortgage Non-owner occupied Vacant 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. REN & ASSOCIATES (") 0 c' C N -n :s:: (- "OCU ;po. -" 929:1 z "",'"'- I h."j ~~~ .-/ ..~~~ ~t, '< -' :;1:>' ); -i4 ?fa 3: ':,,~:(~ 5>g \D Orfl ..-1 ~ ~ 53 .1='" -< MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carli~le, PA 17013 . . NO. 01-5408 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Timothy A. Becraft 1550 Holly Pike South, Carlisle, PA 17013 Pamela J. Becraft 1550 Holly Pike South, 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 Unemployment Compo Fund 16th Floor, L.I. Building, Harrisburg, PA 17121 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. The United States of America, Dept. Of Housing and Urban Developmen 490 L'Enfant Plaza East, Suite 3214 Washington, DC 20024 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. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 1550 Holly Pike South, South 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. i I ~ . UDREN & ASSOCIATES DATED: December 25, 2001 . (") 0 0 C N -n -- t.- --4 ~,.... -ocr) :r... '.," rl1rn :z ~ii:~ Z:J_~ '- Zs_ , }jt~J ~Z~ -..l ;)L "-1 e) '-0 :'> '.".'1 ~ __+'::--n -,. ""!C5 ZO - ~rf1 -0 1.0 '-) Pc --., -7 .:..n ;;r;- ~ :0 s::- -< MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 . . NO. 01-5408 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $111,388.68, 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 charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 mortgagee the back payment, late To find out how much you must pay, 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 856-482-6900. 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 856-482-6900. 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. rF YOU DO NOT HAVE A LAWYER OR CANNOT APPORD ONE, GO TO OR TELEPHONE THE OFFrCE LrSTED BELOW TO FrND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVrCE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 8 s.: -Om !:p [1.' z( (J)~. ~6 :< ~8 Pc: z =< ., o N t.- :po. ;;;e I -.J ".. :x If? :..n .c- () .'-n "'1 r "71TJl "v -,,;. 1_ l_~C) .-....'~!I (5 :'J --.0 ""~'.rn o --,-1 ;;r;- :0 -< ~RK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 . . NO. 01-5408 Defendant(s) NOTICE OF SHERIFF'S SALE OF ~F.AT. PROPERTY TO: Timothy A. Becraft 1550 Holly pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly pike South, South Middleton Township (Carlisle), PA 17013 is scheduled to be sold at the Sheriff's Sale on June 5, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $111,388.68, 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 RI~HTS YOU MAY BE ABLE TO PREVF.NT THIS SHERIFF'S S;ll.LE 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: (8<;6)-482-6900 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.) ~: ~ :::L~ ~R~ ~LE TO SA: Y~: P=~:TY AND YOU HAVF. EVEN IF THE SHERIFF'S SALE D S E . OTHER RIGHTS 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 856-482-6900. 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 856-482-6900. 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 THrS PAPER TO YOUR LAWYER AT ONCE. rF YOU DO NOT HAVE A LAWYER OR CANNoT AFFORD ONE, GO TO OR TELEPHONE THE OFFrCE LrSTED BELOW TO FrND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERYrCE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 r- ~. 0 0 0 c: N ., s: t.- -~ "C) ClJ :Po :r;: -n rnrr -,... i"11i'::::: .... Z::e, , -nrn WI;": -.J ""'[ I') ~:-.:'._' ;;)u 2""- ,<C' :Po ']":=+1 >0 :x C)-~ z - ~2: f~ --0 1.0 0 PC: "':~ Z .:..n jJ ~ -'='" '-< MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . . NO. 01-5408 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) DATE: December 25, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Timothy A. Becraft and Pamela J. Becraft PROPERTY: 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 5. 2002, at 10:00 A.M., 'at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlise, 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. (") <::> 0 c: N -Tl $: t.- -OW ::0- ;g J"T1r"-1 Z Z:u I 1~11'T1 Z~~ )0 (J)~C,_ -.l f -} L ~6 -=rSd :'> -~-~ ,~ ~O :x: ~~B -0 \D On. PC: .. -I Z ':..n ~ =< .c- -< 'iY ----/ /"--y -------- / ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN SOUTH MIDDLETON TOWNSHIP, cmmERLAND COON'l'Y, PENNSYLVANIA, BOUNDED AND DESCRIBED rN ACCORDANCE wrTH . SUBDIYrSION PLAN FOR WEIBLEY ESTATE CONSrSTrNG OF TWO PAGES WHrCH WAS PREPARED BY FISHER, MOWERY, ROSENDALE & ASSOCrATES, rNC., DATED MAY 14, 1997, A COPY OF WHrCH. rs RECORDED rN THE HERErNAFTER NAMED RECORDER.'S OFFrCE rN PLAN BOOK 75, PAGE 45, AS FOLLOWS: BEGINNING AT' AN IRON PIN SET ON THE NORTHERN LrNE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS AT THE DIVIDrNG LINE BETWEEN LOTS NOS. 4 AND 5 AND WHICH rRON PIN SET AT THE PLACE OF BEGrNNING rs SOUTH 89 DEGREES 08 MINuTEs 18 SECONDS WEST A DISTANCE OF 69.33 FEET FROM LOT NO.1, MEASURED ALONG SArD NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS; THENCE FROM SArD rRON prN SET AT THE PLACE OF BEGINNING ALONG SArD NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, SOUTH 89 DEGREE.S 08 MINO'TES 18 SECONDS WEST A DISTANCE OF 593.67 FEET TO AN IRON prN AT A CORNER COMMON TO LOTS NOS. 4 AND 5 AND SAID LAND NOW OR FORMERLY OF .CHARLEY ANN RHOADS; THENCE ALONG SArD DIVIDrNG LINE BETWEEN SAID LOTS NOS. 4 AND 5, THE FOLLOWING THREE (3) COURSES AND DISTANCES. (1) NORTH 00 DEGREES 45 MrNUTES 20 SECONDSEASTADISTANCE OF14i:7j- FEET--TO-:AN nON PIN;---m NORTH-67DEGREES 55-- MINUTES 36 SECONDS EAST A DISTANCE OF 332.91 FEET TO AN rRON prN; AND (3) SOUTH 47 DEGREES 34 MrNUTES 07 SECONDS EAST A DISTANCE OF 383.71 FEET TO AN rRON prN SET AT THE PLACE OF BEGrNNrNG. THE ABOVE-DESCRIBED LOT OF LAND rs ALL OF LOT NO. 4 AS SHOWN ON SAID SUBDrvrsroN PLAN FOR WEIBLEY ESTATE, RECORDED AS. AFORESArD, ON WHICH THERE rs ERECTED A ONE- STORY FRAME DWELLING HOUSE AND OTHER rMPRQVEMENTS, WHrcu HAS THE MAILrNG ADDRESS OF 1550 HOLLY PIKE, CARLrSLE, PENNSYLVANIA 17013. rT rs TO BE NOTED THAT THE PROPOSED 50 FEET wrDE PRIVATE RIGHT-OF-WAY SHOWN ON SArD SUBDIVISION PLAN IS HEREBY EXTINGUISHED AND SUBSTU'UTED THEREFOR ARE THE RrGHTS PROVIDED IN AGREEMENT DATED FEBRUARY 22, 1996, AND RECORDED rN THE HEREINAFTER NAMED RECORDER'S OFFICE rN MrSCELLANEOUS RECORD BOOK 562, PAGE 936, AND THE ABOVE- DESCRIBED PROPERTY rs SPECIFICALLY CONVEYED TOGETHER wrTH AND SUBJECT TO THE RIGHT- OF-WAY PROYrDED IN SArD AGREEMENT DATED FEBRUARY 22, 1996, WHrcu EXTDlDS FROM STATE ROAD 0034 KNOWN AS HOLLY prKE TO THE ABOVE-DESCRrBED LOT NO. 4 KNOWN AS 1550 HOLLY pro. rN ADIirTrON, THE ABOVE-DESCRIBED LOT NO.4- rs CONVEYED TOGETHER wrTH AND SUBJECT TO THE RrGHT-OF-WAY EXTENDrNG FROM TRAFFrC ROUTE NO. 34 KNOWN AS HOLLY PIKE TO LOT NO. 4 ON SAID ABOVE-DESCRIBED TRACT OF ~AND AS SET FORTH rN THE RrGHT-OF-WAY AGREEMENT DATED APRrL 22, 1949, AND RECORDED APRrL 22, 1949, rN THE HERErNAFTER NAMED RECORDER'S OFFrCE rN MISCELLANEOUS RECORD BOOK 84, PA~E 463. rN ADDrTION, THE ABOVE-DESCRrBED LOT NO. 4 KNOWN AS lS50 HOLLY PIKE rs CONVEYED TOGETHER WITH AND SUBJECT TO A RIGHT-OF-WAY 60 FEET rN wrDTH EXTENDrNG FROM THE DIYrDING LINE BETWEEN LOTS NOS. 1 AND 5 WESTWARDLY TO SArD LOT NO.4, THE SOUTHERN LrNE OF SAID 60 FEET wrDE RIGHT-OF-WAY BEING SOUTHERN LINE OF THE RrGHT-OF-WAY SHOWN AS A PROPOSED 50 FEET wrDE PRrVATE RrGHT-OF-WAY ACROSS LOT NO. 5 ON SArD SUBDIYrSION PLAN FOR WErBLEY ESTATE. rN ADDrTION, THE ABOVE-DESCRrBED LOT NO. 4 rs CONVEYED TOGETHER wrTH A RrGHT-OF-WAY OVER THE GRAVEL LANE EXTDlDrNG ALONG THE EASTERN PORTION OF LOT NO. 5 AT A wrDTH OF 20 FEET FROM LAND NOW OR FORMERLY OF DANrEL W. JOHNSON AND wrFE SOUTHWARDLY TO LOT NO. 4 ABOVE-DESCRrBED. BEING KNOWN AS 1550 HOLLY PIKE SOUTH, SOUTH MIDDLETON TOWNSHIP (CARLISLE), PA 17013. PROPERTY TAX PARCEL NO. 40-10-0632-038 TITLE TO SAID PREMISES IS VESTED IN TIMOTHY A. BECRAFT AND PAMELA J. BECRAFT, HUSBAND AND WIFE, BY DEED FROM PAUL E. WEIBLEY, EXECUTOR OF THE LAST WILL AND TESTAMENT OF DORIS R. WEIBLEY, DECEASED, DATED 6/15/98, RECORDED 6/17/98, IN DEED BOOK 179, PAGE 380. MARK J. UDREN & ASSOCrATES , BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 1040 N. KrNGS HrGHWAY, SUrTE 500 CHERRY HILL, NJ 08034 856-4B2-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLArNTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-5408 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) SUGGESTrON OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Timothy A. Becraft & Pamela J. Becraft have filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on December 26, 2001. Bankruptcy Case No. 01-06785. ~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ,..~ (") Cl 0 c: N -n s: '- ----I '"'(0) ;po ;.~:~~ f:~\ ~S3 ..:: m5; N .,~~~O "" ',-C- , ~O \.2.(":) ._.r- '< ~ ::r::: -r, ?Zg Qo 'P. om ;l>-c: -'---l ~ N ~ Cl "< MARK J. UDREN << ASSOCrATES BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 1040 N. KrNGS HrGHWAY, SUrTE 500 CHERRY HILL, NJ OB034 856-482-6900 ATTORNEY FOR PLArNTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 01-5408 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) PRAECrPE TO WITHDRAW JUDGMENT TO THE PROTHONOTARY: Kindly withdraw the Judgment entered on January 7, 2002 upon Timothy A. Becraft & Pamela J. Becraft in the amount of $111,38B.68. Defendant(s), Timothy A. Becraft Pamela J. Becraft filed a CHAPTER 13 BANKRUPTCY ON December 26, 2001 - #01-06785. MARK J. UDREN & ASSOCIATES .~ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF DATED: January 21, 2002 ... n 0 0.. C N " g '- --j ~OJ :>>0 ~~:TI . .g:j :z: 1".- N "j (Il ~r,; \D ':)9 "'7 ':JO ~e "'" -'.r.:=8 ?fg ::l:: ;,)0 '? dlTl 5c 5' ~ ~ ::0 '< . LAWOFFICES MARK J. UDREN & ASSOCIATES 1040 NORTH KINGS HIGHWAY SUITE 500 CHERRY HlIL, NEW JERSEY 08034 856 . 482 . 6900 FAX: 856.482.1199 MARK J. UDREN* STUART WlNNEG** GAYL SPIVAK ORLOFF*** HEIDI R. SPWAK*** CHRISTOPHER J. FOX.** CORINA CANIZ*** *AlJM1'1TlID NJ, PA. FL ..ADMITl'BD PA ".ADMl7TBD NJ, PA. TINA MARIE RICH OFRCEADMlN1STllAroR FREDDIE MAC PENNSYLVANIA DESIGN A TED COUNSEL PENNSnVANlA OFFICE 14 ~.tJJ(n.l JrfElfitJ,YA':E,.'UE SUITE 240 BRYN MAWR, PA 19010 215-568-9500 215-568-1141 FAX PLEASE RESPOND TO NEW JERSEY OFFICE January 21, 2002 Sheriff of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Re: Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. vs. Timothy A. Becraft & Pamela J. Becraft Cumberland County C.C.P. #01-5408 Dear Sir or Madame: Enclosed please find Praecipe to Return Writ of Execution. Thank you for your attention to this matter. Sincerely yours, ~ Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES /cas Enclosure cc: Cumberland County Prothonotary Kindly file the praecipe to Withdraw JUdgment which you are currently holding with regard to this matter upon receipt of the Writ. Thank you very much. ~< : . - . MARK J. UDREN & ASSOCIATES . BY: Mark J. Udren, Esquire ATTY I.D. NO. '04302 1040 N. KrNGS HrGHWAY, SUrTE 500 CHERRY HrLL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 01-5408 TO THE SHERIFF: PRAECIPE TO RETURN WRIT OF EXECUTION Kindly return the Writ of Execution to the Prothonotary with regard to the referenced matter. DATED: January 21, 2002 MARK J. UDREN & ASSOCIATES '~ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ~ g ~. ~ -'Ow' ~p Z.,.._ m~t" ~e V- %'3 ~~ )7"3. q, ~ ~ ::\~ .-" t~~S3 b.b ..-I-f' (~ -,'\ ~;,:; () .,,- fl1 S "" "& ,,) '- ~ r-> .0 \ 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 Home Mortgage. Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO. 01-5408 Defendant(s) PRAEcrPE 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) Timothy A. Becraft and Pamela J. Becraft 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 9/6/01 to 5/11/04 Late charges per Complaint From 9/6/01 to 5/11/04 Escrow payment per Complaint From 9/6/01 to 5/11/04 $108,506.70 19,482.10 1,110.72 5,698.56 TOTAL $134,798.08 I hereby certify that (1) the addresses of the Defendant are as shown above, and (2) that notice has accordance with Rule 237.1, a copy of which is attached Plaintiff and been given in ereto. DAMAGES ARE HEREBY ASSESSED DATE: (f2d.'( IF, ~(\Q't AS IND~ATED. '-- /J PRO Ka!t,f j J<.';\~ MARK J. UDREN ~ ASSOCIATES BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 R<;6-4R2-6'lOO Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgagei Inc. P aintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Timothy A. Becraft Pamela J. Becraft Defendant(s) NO. 01-5408 DATED: December 13 2001 TO: Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 IMPORTANT NOTrCE 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 MAr LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REOUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DE~TRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FArR DEBT COLLECTrON PRACTICES ACT, THrS LAW FrRM rs DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY rNFORMATrON OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFrCES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HrLL, NJ 08003-3620 856-482-6900 Wells Fargo Home Mortgage. Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte. NC 28217 Plaintiff ATTORNEY FOR PLAINTrFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 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 Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Pamela J. Becraft Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Timothy A. Becraft Over 18 As captioned above Unknown Sworn to and subscribed before me this 11th day of May, 2004. ~Q;2i~{vL) CAAA SfEARS HCIAInU8ucOFNEW JERS!Y Commr.Ion Exp/Jes 4/16!'K'M. Name: Title: Company: ) MARK . UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C_ t~ ~ -10. ...0 _ #- 1t- 0 r -- C5 0 ~ ~ j ""- ..0 VI ~ IU ~ U"t J .- ~ - . ,~..~--"~ "-> g () -n ::;:J ~ ..-... i..~~f:~ ;IC:J :-=J(~, -r-'"' (~r-~ ::,Y"P c..j -> ",.., "'~~ c.'.) .-""" u:) ", C-l . USBC PAM - LIVE - V2.3 - Docket Report Page 1 of6 CREDS, CLAIMS, 341Held, PlnCnfrmd, DISMISSED U.s. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:1)1-bk-06785-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 12/26/2001 Date Terminated: 04/19/2004 Date Dismissed: 04/19/2004 Timothy A Becraft 1550 HOLLY PIKE SOUTH CARLISLE, PA 17013-9103 SSN: xxx-xx-0424 Debtor represented by Robert L. O'Brien O'Brien Baric & Scherer 19 WEST SOUTH STREET CARLISLE,PA 17013 717249-6873 Charles J. DeHart, III (Trustee) PO Box 410 Hummelstown, P A 17036 717 566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 717-221-4515 Asst. U.S. Trustee Filing Date # Docket Text 12/26/2001 1 VOLUNTARY PETITION under chapter 13 , [DD], ORIGINAL NIBS DOCKET ENTRY #1 (Entered: 12/26/2001) 12/26/2001 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 01110/02 Re: Item # 1 [Complied], [DD], ORIGINAL NIBS DOCKET ENTRY #2 (Entered: 12/26/2001) 01/16/2002 ~ CORRESPONDENCE to Attorney allowing until January 23, 2002 to file missing documents. Re: Item # 2, [CA], ORIGINAL NIBS DOCKET ENTRY #3 (Entered: 01116/2002) 01118/2002 "I Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2, [DP], ORIGINAL NIBS DOCKET ENTRY #4 (Entered: 01/22/2002) https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl 7948779644130025- L _ 82 _ 0-1 4/29/04 USBC PAM - LIVE - V2.3 - Docket Report . Page 2 of6 02/08/2002 ~ MOTION to compel filing ofIncome Tax Returns by the IRS [Disposed], [SP], ORIGINAL NIBS DOCKET ENTRY #5 (Entered: 02/11/2002) 02/11/2002 Q CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. Certificate of Service of Plan on correct creditors served by BNC., [CA], ORIGINAL NIBS DOCKET ENTRY #6 (Entered: 02/11/2002) 02/11/2002 1 ORDER granting allowing forty-five [45] days to file Returns. Re: Item # 5, [SP], ORIGINAL NIBS DOCKET ENTRY #7 (Entered: 02/1112002) 03/07/2002 Jl 341 meeting held. , [CA], ORIGINAL NIBS DOCKET ENTRY #8 (Entered: 03/07/2002) 03/12/2002 .2 OBJECTION to Plan by Trustee. Re: Item # 4 [Disposed], [SP], ORIGINAL NIBS DOCKET ENTRY #9 (Entered: 03/12/2002) 03/18/2002 lJl NOTICE to parties in interest of Objection to Plan by Trustee. Hearing on 04/11/02 at 02:30 P.M_ at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 9, [SP], ORIGINAL NIBS DOCKET ENTRY #10 (Entered: 03/18/2002) 03/28/2002 11 MOTION for relief from stay filed by WELLS FARGO HOME MORTGAGE, INC. [fee paid rec#580624 $75.00] [Disposed] [Entered: 03/28/02], [DS] CERTIFICATE OF NON-CONCURRENCE [Entered: 03/28/02], [DS] REQUEST for admission, [DS], ORIGINAL NIBS DOCKET ENTRY #11 (Entered: 03/28/2002) 03/28/2002 12 ORDER that answers are due on 04/18/02 Re: Item # 11, [DS], ORIGINAL NIBS DOCKET ENTRY #12 (Entered: 03/28/2002) 04/02/2002 13 CERTIFICATE of service Re: Item # 12, [SP], ORIGINAL NIBS DOCKET ENTRY #13 (Entered: 04/03/2002) 04/18/2002 .1.4 PROCEEDING MEMO re hearing Continued to May 9, 2002 at 2:30 PM Re: Item # 10, [SP], ORIGINAL NIBS DOCKET ENTRY #14 (Entered: 04/18/2002) 04/18/2002 12 ANSWER by DEBTOR Re: Item # 11, [SP], ORIGINAL NIBS DOCKET ENTRY #15 (Entered: 04/18/2002) 04/19/2002 l6. CORRESPONDENCE SETTING Preliminary Phone Conference on https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?948779644130025-L 82 0-1 4/29/04 YSBC PAM - LIVE - V2.3 - Docket Report Page 3 of6 05/08/02 at 11 :00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 15, [SP], ORIGINAL NIBS DOCKET ENTRY #16 (Entered: 04/19/2002) 04/25/2002 11 PRAECIPE/WITHDRAWAL by TRUSTEE Re: Item # 9, [DR], ORIGINAL NIBS DOCKET ENTRY #17 (Entered: 04/25/2002) 04/25/2002 II BUSINESS Examination Report filed by Chapter 13 Trustee. , [DR], ORIGINAL NIBS DOCKET ENTRY #18 (Entered: 04/25/2002) 04/29/2002 12 MOTION for relief from stay filed by W ASHOVIA BANK, N.A [fee paid rec# 581758 $75.00] [Entered: 04/29/02], [DS] CERTIFICATE OF NON-CONCURRENCE, [DS], ORIGINAL NIBS DOCKET ENTRY #19 (Entered: 04/29/2002) 04/29/2002 20 ORDER that answers are due on OS/20/02 Re: Item # 19, [DS], ORIGINAL NIBS DOCKET ENTRY #20 (Entered: 04/29/2002) 05/03/2002 21 CERTIFICATE of service Re: Item # 20, [SP], ORIGINAL NIBS DOCKET ENTRY #21 (Entered: 05/03/2002) 05/08/2002 22 PROCEEDING MEMO: phone conference not held_ Settlement stipulation [w/Trustee concurrence] to be filed within 30 days. Re: Item # 11, [JG], ORIGINAL NIBS DOCKET ENTRY #22 (Entered: 05/08/2002) 05/08/2002 23 ORDER ConfIrming Plan, [SP], ORIGINAL NIBS DOCKET ENTRY #23 (Entered: 05/08/2002) OS/22/2002 24 ANSWER by DEBTOR Re: Item # 19, [SP], ORIGINAL NIBS DOCKET ENTRY #24 (Entered: OS/22/2002) OS/24/2002 2.5 CORRESPONDENCE SETTING Preliminary Phone Conference on 06/20/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 24, [SP], ORIGINAL NIBS DOCKET ENTRY #25 (Entered: OS/24/2002) 06/10/2002 26 CORRESPONDENCE from MOVANT requesting relisted Hearing Re: Item # 11, [SP], ORIGINAL NIBS DOCKET ENTRY #26 (Entered: 06/11/2002) 06/13/2002 27 CORRESPONDENCE SETTING Preliminary Phone Conference on 07/23/02 at 11 :30 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 26, [SP], ORIGINAL NIBS DOCKET ENTRY #27 (Entered: https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?948779644130025-L _ 82 _ 0-1 4/29/04 USBC PAM - LIVE - V2.3 - Docket Report Page 4 of 6 06113/2002) 06/20/2002 28 PROCEEDING MEMO: phone conference not held - matter to be set for hearing before Judge Bentz in September. Re: Item # 19, [CL), ORIGINAL NIBS DOCKET ENTRY #28 (Entered: 06120/2002) 07/12/2002 29 OBJECTION to Claim #6 as Amended of WELLS FARGO HOME MORTGAGE, INC. filed by DEBTOR. [Disposed), [SP), ORIGINAL NIBS DOCKET ENTRY #29 (Entered: 07/12/2002) 07/12/2002 30 ORDER fixing hearing date on 08/12/02 at 03:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 29, [SP), ORIGINAL NIBS DOCKET ENTRY #30 (Entered: 07/12/2002) 07/1812002 .~l CERTIFICATE of service Re: Item # 30, [SP], ORIGINAL NIBS DOCKET ENTRY #31 (Entered: 07/18/2002) 07/18/2002 32 MOTION to dismiss Case for failure to comply with order to file tax returns; filed by USA on behalf of IRS Re: Item # 1 [Disposed], [BW], ORIGINAL NIBS DOCKET ENTRY #32 (Entered: 07/19/2002) 07/22/2002 3.;3. ANSWER by WELLS FARGO HOME MORTGAGE INC. Re: Item # 29, [SP], ORIGINAL NIBS DOCKET ENTRY #33 (Entered: 07/22/2002) 07/23/2002 34 PROCEEDING MEMO: phone conference not held - stipulation with trustee concurrence to be filed within 30 days - 6 months to cure arrears. Re: Item # 11, [eLl, ORIGINAL NIBS DOCKET ENTRY #34 (Entered: 07/23/2002) 07/24/2002 35 STIPULATION by Parties in Settlement. [Requested Trustee concurrence) Re: Item # 11 (Entered: 07/24/02), [SP] APPROVED by the court. Re: Item # 11, [SP], ORIGINAL NIBS DOCKET ENTRY #35 (Entered: 08/05/2002) 07/29/2002 36 NOTICE to creditors of hearing on 09/09/02 at 10:00 A,M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 32 [Rescheduled) [Entered: 07/29/02), [SP] NOTICE to creditors that answers/objections are due on 08/16/02 Re: Item # 32, [SP), ORIGINAL NIBS DOCKET ENTRY #36 (Entered: 07/29/2002) 08/12/2002 .3..7 PROCEEDING MEMO: phone conference held, Parties to exchange information regarding costs involved in Sheriffs sale, then matter to https://ecf.pamb_uscourts.gov/cgi-binIDktRpt.pl?948779644130025-L _ 82.0-1 4/29/04 1JSBC PAM - LIVE - V2.3 - Docket Report Page 5 of6 be scheduled for hearing with Judge Bentz if matter cannot be settled. Re: Item # 29, [JG], ORIGINAL NIBS DOCKET ENTRY #37 (Entered: 08/13/2002) 08/28/2002 38 PRAECIPE/WITHDRAWAL Re: Item # 32 [Entered: 08/29/02], [SP] This entry cancels the previous due date. Re: Item # 36, [SP], ORIGINAL NIBS DOCKET ENTRY #38 (Entered: 08/29/2002) 09/06/2002 39 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on 10110/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101, [SP], ORIGINAL NIBS DOCKET ENTRY #39 (Entered: 09/06/2002) 09/24/2002 40 CORRESPONDENCE from Wells Fargo. Re: Request to reschedule hearing Re: Item # 37, [SP], ORIGINAL NIBS DOCKET ENTRY #40 (Entered: 09/24/2002) 09/27/2002 41 CORRESPONDENCE SETTING Status Conference, Judge Warren W. Bentz, Presiding on 12/04/02 at 10:30 A.M, at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 33 [Rescheduled], [SP], ORIGINAL NIBS DOCKET ENTRY #41 (Entered: 09/27/2002) 10/15/2002 42 Praecipe/Withdraw Re: Item # 39, [SP], ORIGINAL NIBS DOCKET ENTRY #42 (Entered: 10/15/2002) 12/02/2002 43 MOTION to withdraw Objection Re: Item # 29 [Disposed], [SP], ORIGINAL NIBS DOCKET ENTRY #43 (Entered: 12/02/2002) 12/02/2002 44 ORDER granting Re: Item # 43 [Entered: 12/02/02], [SP] This entry disposes of motion_ Re: Item # 29 [Entered: 12/02/02], [SP] This entry cancels the previous due date. Re: Item # 41, [SP], ORIGINAL NIBS DOCKET ENTRY #44 (Entered: 12/02/2002) 02/06/2004 45 Motion to Dismiss Case for material default and hearing notice to parties. Filed by Charles J DeHart, III (RE: related document(s)l). Hearing scheduled for 3/1112004 at 02:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (JR) (Entered: 02/06/2004) 02/23/2004 46 Certificate of Default Filed by Heidi R Spivak ofUdren Law Offices PC on behalf of Wells Fargo Horne Mortgage Inc (RE: related document(s)[35] ). (SP) (Entered: 02/23/2004) https://ecf.parnb.uscourts.gov/cgi-binlDktRpt.pl?94877964413002S-L 82.0-1 4/29/04 YSBC PAM - LIVE - V2.3 - Docket Report Page 6 of6 02/27/2004 47 Order Granting Relief from Stay per Certificate of Default (RE: related document(s)[46]). (SP) (Entered: 02/27/2004) 03/10/2004 48 Stipulation by debtor and Ch. 13 trustee Filed by Trustee (RE: related document(s)[45] ). (Attachments: # 1 Proposed Order)(dehart, III(ds), Charles) (Entered: 03/10/2004) 03/12/2004 12 Order approving Stipulation (RE: related document(sH8 ). (SP) (Entered: 03/12/2004) 03/23/2004 50 Motion to Dismiss Case upon the basis that the plan lacks feasibility with proposed order. Notice sent to all Creditors_ Filed by Trustee. Objections due by 4/15/2004. (dehart, III(asm), Charles) (Entered: 03/23/2004) 03/26/2004 5.1 BNC Certificate of Mailing. Service Date 03/26/2004. (Related Doc # 50) (Admin.) (Entered: 03/27/2004) 04/19/2004 52 Order Dismissing Case (RE: related document(s)50)_ (SP) (Entered: 04/19/2004 ) 04/21/2004 53 BNC Certificate of Mailing. Service Date 04/21/2004. (Related Doc # 52) (Admin.) (Entered: 04/22/2004) I PACER Service Center I Transaction Receipt I 04/29/200413:23:22 Ip ACER Login: IlmuOO] I IIClient Code: I IDescription: IIDocket Report IICase Number: 111:0 I-bk-06785-MDF I IBilIable Pages: 113 IICost: 110.21 1 https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?948779644130025-L 82_0-1 4/29/04 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Home Mortgage, Inc. fjkja Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-5408 TO THE SHERIFF: PRAEcrPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due Interest From 5/12/04 to Date of Sale September 8, 2004 Per diem @$19_90 $134,798.08 2,388.00 (Costs to be added) $ UDREN LAW OFF'CE', P.C. ~ Mark J. Udren, 8SQU!RE ATTORNEY FOR PLAINTIFF 1Y ~ ;AJR ~ \I:- il - a-. - C> VI ..0 r> .... .... (I) tI'\(f' S ~ e. -r ~ ~ .lQ. :.co..:-- V) 0 () 0 )--~ r- r 4- - ~ -t -- .f::-w"'- l,.J ).,..0 tI) ..0 '" 6'" :- !rt .,.., i1)'oc D ~O)JD t/lCCcC cC Cr?D I p.,) :: ... _ ~ ::: :: :: .... D- .... .. .. 1- 1 _ ' . ~ ~ - -:.. O::;._~ - ~ ~ "=tt- C) ~--; 0 ~ -n ---1 .-'- :1j,' ":':711 -- C:) c:" C?, -~, ,'--, .--t' ...0 '" 01 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY, To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC. FIKIA NORWEST MORTGAGE, INC., Plaintiff (s) From TIMOTHY A.BECRAFT AND PAMELAJ. BECRAFT NO 01-5408 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendan' (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 heen 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. Amount Due $134,798.08 LL $.50 Interest FROM 5/12/04 TO DATE OF SALE 9/8/04 PER DIEM @$19.90 - $2,388.00 Atty's Comm % Due Prothy $1.00 Atty Paid $143.25 Other Costs Plaintiff Paid Date, MAY 18, 2004 (Seal) CURTIS R. LONG Prothonot!!l)' . ~: .4kb~~_ P. /1(.-J1ALI'. r- Deputy REQUESTING PARTY: Name MARK J. UDREN. ESQUIRE Addres", UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY IDLL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO_ 01-5408 Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: X An FHA insured mortgage Non-owner occupied Vacant 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 L~~. ) Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF , c F"_.) C,) C~) ~- o -n ...... ~- ;'i,::!J ,- ;',"! ::7 f"',) \D i'.J U'l UDREN LAW OFFICES, P.C. - BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 NO. 01-5408 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Pamela J. Becraft 1550 Holly pike South 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 Unemployment Compo Fund 16th Floor, L.I. Building Harrisburg, PA 17121 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. The United States of America, Department of Housing and Urban Development 490 L'Enfant Plaza East, Suite 3214 Washington, DC 20024 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 1550 Holly pike South South Middleton Township (Carlisle), PA 17013 1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 11, 2004 UDREN LAW OFFICES, P.C~ Mark J. ~ Attorney for Plaintiff , '" c:;> 0 C:...;:l OIl .c- ?:: ---! .....~ ffi =-' ,. -r:r rrl co ::-:) c;) (-) ~) :;i y, -< -;~ '. j...., lr) " , , N Ul ~ UDREN LAW OFFrCES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO. 01-5408 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $134,798.08, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call: (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 STrLL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERrFF'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 856-482-6900. 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. amount due 6900. The sale will go through only if the buyer pays the Sheriff the full in the sale. To find out if this has happened, you may call 856-482- 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 I 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ,- ", '__:.:l ';:..:' ...- C -n OJ :::1 r;~ -.-, ,-- rfl 'J , ~:> ?t~ ,--:" \..0 -I .-.-.~ , . , " V'l UDREN LAW OFFICES, P.C. o BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HrLL, NiT 08003-3620 856-669-5400 ATTORNEY FOR PLA.L~'J:.L~'~' Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Piaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO. 01-5408 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $134,798.08, 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 attorneyls 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 856-482- 6900. 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 856-482-6900_ 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 \.c') r....., C', "'-' '.:;." <.'.;';' J_- C) -n :~--J , <'re: tn ,.,:' (~; :.,.... c~ ! UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) : NO. 01-5408 AMENDED AFFrDAVIT OF SERVrCE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a I:rue and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto" then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said" Order is attached hereto as Exhibit "B". All Notices were served within the tim 3129. This Affidavit is made subject to the relating to unsworn falsification to a orth by Pa Rule C.P. ies of tie~ . Dated: August 9, 2004 UDl.EN tion 4904 P.C. BY: ar Udren, Esqu1re ttorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HrLL, NJ OB003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff ~ COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO. 01~5408 Defendant(s) AMENDED AFFrDAVrT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Pamela J. Becraft 1550 Holly Pike South 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 Compo Fund 16th Floor, L.r. Building Harrisburg, P,A, 17121 Agway Energy Products 530 E. North Street Carlisle PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. The United States of America, Department of Housing and Urban Development 490 L'Enfant Plaza East, Suite 3214 Washington, DC 20024 5. Name and address of every other person 'who has any record lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, J?A 17128-0946 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 1550 Holly Pike South South Middleton Township (Carlisle), PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal kn ledg or information and belief. I understand that false sta ens h re'n are made subject to the penalties of 18 Pa.C.S. s C 4 04 r lating to unsworn falsification to authorities. .C. DATED: August 9, 2004 rk J. Udren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTrFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-5.l08 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) DATE: July 16, 2004 TO: ALL PARTIES rN INTEREST AND CLArMANTS NOTICE OF SHERIFF' S Sl~LE OF REAL PROPERTY OWNER(S): Timothy A. Becraft & Pamela J. Becraft PROPERTY: 1550 Holly Pike South South Middleton Township (Carlisle), PA 17013 rmprovements: REsrDENTIAL DWELLrNG The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on SeDtemb,ar 8. 2004, at 10: 00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. 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Becraft In The Court of Cornmon Pleas of Cumberland County, Pennsylvania Writ No. 2001-5408 Civil Term Richard Smith, Deputy Sheriff, who being duly swom according to law, states that on June 14, 2004 at 9:55 o'clock AM, he served a true c:opy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above ,entitled action, upon the within named defendants, to wit: Timothy A. Becraft and Pamela J. Becraft, by making knovm unto Pamela Becraft, personally and wife of Timothy A Becraft, at 1550 Holly Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 13,2004 at 3:50 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled a.ction, upon the property of Timothy ABecraft and Pamela J. Becraft located at 1550 Holly Pike, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn ac,;ording to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Timothy A Becraft and Pamela J. Becraft, by regular mail to their last known address of 1550 Holly Pike, Carlisle, PA 17013. These letters were mailed under the date of July 13, 2004 and never returned to the Sheriffs Office. This _ day of ?~~~ R. Thomas Kline, Sheriff BY , !&A }J,~ Rea~eputy Sworn and subscribed to before me 2004, A.D. Prothonotary C"..~."~r~. - .'...,:1,....., TB -'....lot !..l!.oit.:,..~ . -.., r1~':' ;z. "' (7~ ~.< ~:'- fL "'"'.- ::<l '" C? c.";'.::' .C" o ,-, :71 ~ i'~'.~ (.=.:; 0', :? -~ (,J o ()'"~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF wells Fargo Horne Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-5408 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Timothy A. Becraft has filed Chapter 13 Bankruptcy in the Eastern District of Pennsylvania on September 3, 2004, Bankruptcy Case No l . Mark J. ~" 04-bk-05351. squire UDREN LAW OFF'IC S, P.C. Attorney for Pl intiff 0127662 r-" 0 c::::." c.~., "n ~ ::;1 c:) ; : , f'"' I -, ~ - .- r.) (~'I -.J -.. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $134,798.08 Interest From 05/12/04 to Date of Sale September 7, 2005 Per diem @$19.90 9,631.60 (Costs to be added) $ ;zJ ~ ( \L ~ L ~ ~ r ~ G Y ? +- \f l 0 4<l. ii - \) \) W "'Q ~ ~ I) ~ -. -k,L - tJ...; -- ~ . ~ \) ~ \) \) en C/ \ I -~~ ~ "l :t) ~~~':: -+--+=. _'_::.::.::'v:J+- "- ~ '-. #--Z "< _ -l;g: "- V( .'l U't -c V\ -:D. C) 60 \) \) ~ w C \) eel \ \ \ \ \ - - , ~ ------ T-~ C') ("") ~:; -'\\ \:.- '::~~ ~-,~ --~o'.. -1: . . ~-; 1 :;.::; \ .<;'" --." 0' ...t? - w ~ WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5408 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff (s) From TIMOTHY A. BECRAFT AND PAMELA J. BECRAFT (1) You are directed to levy upon the property of the defendan' (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $134,798.08 L.L. Interest FROM 5/12/04 TO DATE OF SALE 9/7/05 - PER DIEM @$19.90-$9,631.60 Atty's Comm % Due Prothy $1.00 Atty Paid $1693.78 Other Costs Plaintiff Paid Date: APRIL 4, 2005 CURTIS R. LONG (Seal) prothonz Ex: tV>. . / Q. 7fC?Ad< / Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCRESTCORPORATECENTER 11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 USBC PAM - LIVE - V2.6 - Docket Report Page j or 'I . 2002, CREDS, CLAIMS, DISMISSED u.s. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:04-bk-05351-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 09/03/2004 Date Tenninated: 02/09/2005 Date Dismissed: 02/09/2005 Timothy A Becraft 1550 Holly Pike Carlisle, PA 17013-9103 SSN: xxx-xx-0424 Debtor represented by James H Turner Turner and O'Connell 4415 North Front Street Harrisburg, P A 1711 0 717 232-4551 Fax: 717 232-2115 Emai1: pat@turnerandoconne1Lcom Charles J. DeHart, III (Trustee) PO Box 410 Hummelstown, P A 17036 717 566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 (717) 221-4515 Asst. U.S. Trustee Filing Date # Docket Text 09/03/2004 1 Chapter 13 Voluntary Petition. Filing fee due in the amount of $ 194.00 Filed by James H Turner of Turner and O'Connell on behalf of Timothy A Becraft. (BR) (Entered: 09/03/2004) 09/0312004 2 Matrix filed/Creditor List Uploaded Filed by James H Turner of Turner and O'Connell on behalf of Timothy A Becraft (RE: related document(sll), (BR) (Entered: 09/03/2004) 09/0312004 .3. Chapter 13 Plan Filed by James H Turner of Turner and O'Connell on behalf of Timothy A Becraft (RE: related document(s)l ). (BR) (Entered: 09/0312004) 09/03/2004 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO https:/ /ecf.pamb.uscourts.gov/cgi-binlDktRpt.p1 7434285238862617 - L_82_ 0-1 2/2312005 USBC PAM - LIVE - V2.6 - Docket Report t'age 1. UJ "t . . CHANGE. 11/4/2004 at 09:00 AM. (BR) (Entered: 09/03/2004) 09/03/2004 Receipt of Voluntary Petition Filing Fee, Chapter 13 - $194.00 Receipt Number: 00612841. (By CReg by BR) (RE: related document I) (Entered: 09/08/2004) 09/10/2004 '\ Request for Notices Filed by Dolores Geesman of P A Department of Labor and Industry (BETO) (RCP) Additional attachment(s) added on . . . 11116/2004 (DR). (Entered: 09/16/2004) 09/16/2004 5 Request for Notice under 2002 Filed by Brice Vander Linden and Wernick PC on behalf of Wells Fargo Bank. (Brice Vander Linden and Wernick PC, ) (Entered: 09/16/2004) 09/23/2004 6 Request to BNC - Meeting of Creditors. 34)(a) meeting to be held on 11/4/2004 at 10:00 AM Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th Fl, 228 Walnut St, Harrisburg, P A Proofs of Claims due by 2/2/2005 Last day to Object to Plan Confirmation 3/4/2005 (DP) (Entered: 09/23/2004) 09/25/2004 7 BNC Certificate of Mailing. (RE: related document(s)6 ). Service Date 09/25/2004. (Admin.) (Entered: 09/26/2004) 09/25/2004 8 BNC Certificate of Mailing, (RE: related document(s)6 ), Service Date 09/25/2004. (Admin.) (Entered: 09/26/2004) 11109/2004 9 Certification that 341 Meeting of Creditors (Ch, 13) Not Held on 11/4/04. To be Rescheduled for Debtor. (There is no image or paper document associated with this entry.). (dehart, Ill(ds), Charles) (Entered: 11/09/2004) 11/10/2004 lQ Certification that 341 Meeting of Creditors (Ch. 13) Rescheduled. 341(a) meeting to be held on 1/6/2005 at 12:00 PM at Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th FI, 228 Walnut St, Harrisburg, PA. (DP) (Entered: 11110/2004) 11/12/2004 U BNC Certificate of Mailing. (RE: related document(s)lO). Service Date 11/12/2004. (Admin.) (Entered: 11/13/2004) 12/08/2004 12 Motion to Dismiss Case for material default and hearing notice to parties. Filed by Trustee. Hearing scheduled for 1/13/2005 at 02:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA (dehart, Ill(ds), Charles) (Entered: 12/08/2004) 01/13/2005 13 Certification that 341 Meeting of Creditors Not Held for Debtor on 1/6/05. (There is no image or paper document associated with this https://ecLpamb.uscourts.gov/cgi-binJDktRpt.pl 7434285238862617 -L_82 _ 0-1 2/23/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 3 of 4 . report.) Notice sent to all Creditors regarding possible dismissal of case. (Notice attached). Objections due by 2/5/2005. (dehart, III(ds), Charles) (Entered: 01/1312005) 01/16/2005 14 BNC Certificate of Mailing_ (RE: related document(s)13 ), Service Date 01/1612005. (Admin.) (Entered: 01/17/2005) 01/21/2005 15 Correspondence from Trustee re hearing. No appearance for debtor. Case to be dismissed Filed by Trustee. (dehart, III(ds), Charles) (Entered: 01/21/2005) 01/26/2005 16 Motion to Compel Filing of Tax Returns Filed by Nathanael J Byerly of United States Attorney's Office on behalf of IRS. (Attachments: # 1 Proposed Order #::; Exhibit A) (Byerly, Nathanael) (Entered: 01/26/2005) 01/26/2005 17 Brief in Support of Motion to Compel Filing of Tax Returns Filed by Nathanael J Byerly of United States Attorney's Office on behalf of IRS (RE: related document(s)L6). (Byerly, Nathanael) (Entered: 01/26/2005) 01/26/2005 18 Objection to Confirmation of Plan Filed by Nathanael J Byerly of United States Attorney's Office on behalf of IRS (RE: related document(s)3 ). (Attachments: # J Proposed Order)(Byerly, Nathanael) (Entered: 01/26/2005) 01/27/2005 19 Notice to Parties: (RE: related document(s)18 ). Hearing scheduled for 3/812005 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Attachments: # ] Certificate of Service) (KZ) (Entered: 01/2712005) 01/27/2005 20 Notice to Filing Party: **The Proposed Order was NOT e-mailed to the Court in accordance with the Administrative Procedures. Please e- mail the order so it can be presented to the Judge. (Re: Motion to Compel Filing of Tax Returns) ** (RE: related document(s)L6 ). (DP) (Entered: 01/2712005) 01/27/2005 21 Notice to Filing Party: **The Proposed Order was NOT e-mailed to the Court in accordance with the Administrative Procedures. Please e- mail the order so it can be presented to the Judge. (Re: Objection to Confirmation of Plan) **, (RE: related document(s)]8 ). (DP) (Entered, 01/27/2005) 02/09/2005 TJ Order Dismissing Case for failure to appear at 2nd scheduled 341 Meeting of Creditors(RE: related document( s) 13). (DP) (Entered: 02/09/2005) https://ecf.pamb.uscourts,gov/cgi -bin/DktRpt.pl ?434285238862617 - L_82_ 0-1 2/23/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 4 ot 4 02/1 0/2005 23 Final Report Filed by Trustee. (dehart, Ill( ck), Charles) (Entered: 02/1012005) 02/11/2005 24 BNC Certificate of Mailing. (RE: related document(s)22 ). Service Date 02/1112005. (Admin.) (Entered: 02/12/2005) I I I IPACER Login: PACER Service Center Transaction Receipt Docket Description: Report 02/23/2005 10:00:51 I~ Client I ~ Code: uclren 1 :04-bk-05351-MDF Fil or Ent: Search Fil Doc From: 0 Doc To: Criteria: 99999999 Term: y Links: n Format: HTMLfmt Billable Pages: D81016 https:llecf.pamb.uscourts.gov/cgi-binlDktRpt. pI ?434285238862617 -L_ 82_ 0-1 2/23/2005 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 OB003-3620 856-669-5400 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-5408 C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties 9f 18 Pa. C.S. Sec. 4904 relating to unsworn fa sification to authoritie ----- r~? c~ t::-? cP '"fl.'" o;...~ '; -'" /"~ \ :::- ,p -- (.;) --- - .. ,- 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 Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1550 Holly Pike South, Carlisle (South Middleton Township), PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Timothy A. Becraft 1550 Holly pike South Carlisle, PA 17013 Pamela J. Becraft 1550 Holly Pike South 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 Unemployment Compo Fund L.1. Building, 16th Floor Harrisburg, PA 17121 Agway Energy Products 530 E. North St. Carlisle, PA 17013 ,,' . 4. Name and address of the last recorded holder of every mortgage of record: Name Address plaintiff herein. See Caption above. The United States of America Dept. Of Housing and Urban Development 490 L'Enfant Plaza East, Ste 3214 Washington, DC 20024 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. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N.. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 1550 Holly Pike South Carlisle, (South Middleton Township), 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 u worn fa ification to a?thorities. DATED: March 23, 2005 Mark J. Udren, ESQ. "Attorney for Plaintiff "', c:::::. r.l ~ ':-(j :r-_ -7) ::-~;J , _i>. \,0 c..J UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Timothy A. Becraft 1550 Holly pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, Carlisle (South Middleton Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $9,631.60, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffls 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 1 5 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. more chance you will have of stopping the sale. to obtain an attorney,) The sooner you contact one, the (See notice on page two on how 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 0 r"'",) C) ,= C~ =) -." (::J'l :;:::. ::-,j -~~: ":-1 .!;- ;:::--. _.".. '-0 ._.J .z:.- "<. - ,.,,' 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 OB003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, Carlisle (South Middleton Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $9,631.60, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff1s 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 attorneyls 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ~! l.() -c' f'-~.) c:.: 0:,;';; C:., "il ,. ......,~ \,-; - ......, ,/ Wells Fargo Home Mortgage Inc. f/kla Norwest Mortgage, Inc. VS Timothy A. Becraft and Pamela J. Becraft In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5408 Civil Term Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on June )4,2004 at 9:55 o'clock AM, he served a true copy of the within Real Est te Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Timothy A. Becraft and Pamela J. Becraft, by makin known unto Pamela Becraft, personally and wife of Timothy A. Becraft, at 1550 Holly Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states th on July 13,2004 at 3:50 o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy A.Becraft and Pamela 1. Becraft located at 1550 Holly Pike, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Timothy A. Becraft and Pan1e1a 1. Becraft, by regular mail to their last known address of 1550 Holly Pike, Carlisle, P A 17013. These letters were mailed under the date of July 13,2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he returns the within writ as STAYED per instructions from Attorney Mark J. Udren. Sheriff s Costs: Docketing Poundage Advertising Posting Bills Law Library Prothonotary Mileage Levy Surcharge 30.00. 30.16 15.00 15.00 .50 1.00 7.15 15,00 30.00. \.60 ~ .-0'1 ( , ! '5'1'{fl,- ~ ~ Law Journal Patriot News Share of Bills Postpone Sale 842.00 501.73 30,49' 20,00 $1538.03 Sworn and subscribed to before me ...., '& /! This ~ day of~ 200€A.D. ~(l )u./tifh> ot onotary ~ So Answers: ?'~~. R. Thomas Kline, Sheriff BY ~/d'1S"YLdj,? Real Estate Deputy 'UDREN LAW OFFrCES, 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 Wells Fargo Home Mort a e ATTORNEY FOR PLAI IFF ~ ,/ " '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 PLAI IFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 NO. 01-5408 Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, nc., Plaintiff in the above action, by its attorney, Mark J. ren, ESQ., sets forth as of the date the Praecipe for the Wr t of Execution was filed the following information concerning th real property located at: 1550 Holly pike South, South Mid leton Township (Carlisle), PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Timothy A. Becraft 1550 Holly pike South Carlisle, PA 17013 Pamela J. Becraft 1550 Holly Pike South 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 judgmen is a record lien on the real property to be sold: Name Address Unemployment Compo Fund 16th Floor, L.I. Building Harrisburg, PA 17121 4. Name and address of the last recorded holder of every roo tgage of record: Name Address Plaintiff herein. See Caption above. The United States of America, Department of Housing and Urban Development 490 L'Enfant Plaza East, Suit Washington, DC 20024 3214 ~. Name and address of every other person who has any recor lien on the property: Name Address None 6. Name interest sale: Name and address of every other person who has any in the property and whose interest may be affected Address Real Estate Tax Dept. ecord the 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 2 0946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plainti f has knowledge who has any interest in the property which m y be affected by the sale: Name Address Tenants/Occupants 1550 Holly Pike South South Middleton Township (Carl'sle), PA 17013 I verify that the statements made in this affidavit are tr and correct to the best of my personal knowledge or informatio and belief. I understand that false statements herein are made s ject to the penalties of 18 Pa.C.S. sec. 4904 relating to u sworn falsification to authorities. UDREN LAW OFFICES, P.C DATED: May 11, 2004 Mark J. dren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. ~Y: 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 J:'LA.L ..L.U.!'" ~ Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 NO. 01-5408 Defendant(sl NOTICE OF SHERrFF'S SALE OF REAL PROPERTY TO: Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, South Middleton Township (Carlisle), PA 17013 is scheduled to be at the Sheriff's Sale on September 8, 2004, at 10:00 am in Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle to enforce the court judgment of $134,798.08, obtained by Plaintiff above (the mortgagee) against you. If the sale i postponed, the property will be relisted for the Next Avail Sale. old he PA, ble NOTrCE 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 p late charges, costs and reasonable attorney's fees. To find out much you must pay, you may call, 18561-669-5400. 2. You may be able to stop the sale by filing a petition asking the to strike or open the judgment, if the judgment was improperly e 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 procee You may need an attorney to assert your rights. The sooner you one, the more chance you will have of stopping the sale. (See n page two on how to obtain an attorney.) 'YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OT R RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. . 1. If the Sheriff's Sale is ~ot stopped, your property will be old to the highest bidder. You may find out the price bid by calling 856-48 - 6900. 2. You may be able to petition the Court to set aside the sale f 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 he full amount due in the sale. To find out if this has happened, you may all 856-482-6900. 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 mount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. A 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 f r your house. A schedule of distribution of the money bid for your house '11 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 af er Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getti g 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 T FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 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 PLAI IFF Wells Fargo Home Mortgage, Inc. f!k!a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 NO. 01-5408 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly Pike South, South Middl ton Township (Carlisle), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, P , to enforce the court judgment of $134,798.08, obtained by Plain iff 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 late Charges, costs and reasonable attorney1s fees. To find out you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Cou 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 proceedin You may need an attorney to assert your rights. The sooner you con act one f the more chance you will have of stopping the sale. (See notic on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE RIGHTS EVEN IF THE SHERIFF'S SALE DDES TAKE PLACE. THER 1. the highest If the Sheriff's Sale is ~ot stopped, your property will be s ld to bidder. You may find out the price bid by calling 856-482-6 DO. 2. You may be able to petition the Court to set aside the sale f the bid price was grossly inadequate compared to the value of your property. 3. amount due 6900. The sale will go through only if the buyer pays the Sheriff th full in the sale. To find out if this has happened, you may call 85 -482- 4. If the amount due from the Buyer is not paid to the Sheriff, yo 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 mount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. A 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 fo house. A schedule of distribution of the money bid for your house will be by the Sheriff within 3D days after the sale. This schedule will state wh be receiving that money. The money will be paid out in accordance with schedule unless exceptions (reasons why the proposed distribution is wron filed with the Sheriff within ten (10) days after Schedule of Distributi filed. your filed will this are n is 7. You may also have other rights and defenses, or ways of gettin home back, if you act immediately after the sale, your YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 WYER om ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 " ALL ~T CERTAIN HOUSE AND LOT OF GROUND SITUATE IN SOUTH MIDDLETON TOWNSHI~ CffilSERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH SUBDIVISION ~!.AN FOR WEIBLEY ESTATE CONSISTING. OF TWO ~AGES WHICH WAS PREPAR D BY FISHER, MOWERY, ROSENDALE & ASSOCIATES, INC., DATED MAY 14, 1997, A COl?Y OF ICH IS RECORDED IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN ~LAN BOOK 75, PAGE 45, AS FOLLOWS: BlilGINN:tNG AT', AN IRON ~IN SET ON THE NORTHERN LIN:E OF LAND NOW OR FORM!:RLY OF CHARLEY 1\NN RHOADS AT Tlm DIVIDING LIN:E BlilTWlillrn LOTS NOS. 4 AND 5 AND WHICR l?IN SET AT THE PLACE OF BEGINNING IS SOUTH 89 DEGRlilES 08 MINUTES 18 SECONDS A DISTANCE OF 69.33 FEET FROM LOT NO.1, MEASURED ALONG SAID NORTlmRN LINE OF NOW OR FORMERLY OF OlARLEY = RHOADS; THENCE FROM SAID IRON l?IN SET AT THE OF BEGINNING ALONG SAID NORTlmRN LINE OF LAND NOW OR FORMERLY OF CHARLEY lINN RHOADS, SOUTH 89 DlilGREES 08 MINUTES 18 SECONDS WEST A DISTANCE OF 593.67 FEE IRON PIN AT A CORNlilR COMMON TO LOTS NOS. 4 AND 5 AND SAID LAND NOW OR FORME CHARLEY lINN RHOADS; THENCE ALONG SAID DIVIDING LIN:E BE'l'WElrn SAID LOTS NOS. 4 Tlm FOLLOWING THREE (3) COURSlilS AND DISTANCES: (1) NORTH 00 DEGREES 45 MINUTE ---~~SlilCONDS EAST A DISTANCE' OF T42. 73 FlilET TO AN IRON PIN, - (2)-'-N'o"RTH 67-DEGRElilS 5 MINTl'TES 36 SECONDS EAST A DISTANCE 01'332.91 FEET TO AN IRON l?IN, AND (3) SO 47 DlilGREES 34 MINUTES 07 SlilCONDS ];lAST A DISTANCE OF 383.71 FElilT TO AN IRON l?IN STAT THE ~LACE OF BEGIIDUNG. THE ABOVEl-DESCRIBlilD LOT OF LAND IS ALL OF LOT NO. 4 AS SROWN ON SAID SUBDIVIS ON l?LAN FOR mIBLEY ESTATE, RECORDB:ll AS AFORESAID, ON WHICH THE1!E IS ERECTB:ll A 0 STORY FRAM];: DWELLING HOUSE AND OTHER IMPROVEMENTS, WEICH HAS THE MAILING ADD OF 1550 HOLLY PIKE, CARLISLlil, PENNSYLVANIA 17013. IN ADDITION, THE ABOVEl-DESCRIBB:ll LOT NO. 4 KNOWN AS 1550 HOLLY PIKE IS CO TOGlilTHER WITH AND SUBJECT TO A RIGHT-OF-WAY 60 FElilT IN WJ:DTH EX'l'ENIlING FROM DIVIDING LINE BETWlilEN LOTS NOS. 1 AND 5 WESTWARDLY TO SAID LOT NO.4, THE SO LINE OF SAID 60 FElilT WIDlil RIGRT-OF-WAY BEING SOUTHERN LINE OF THE RIGHT-OF-WA SHOWN AS A PROPOSED 50 F];lET WIDlil PRrvATE RIGHT-OF-WAY ACROSS LOT NO. 5 ON SAID SUBDIVISION PLAN FOR WEIBLlilY ESTAT];l. IT IS TO Blil NOTED THAT THE ~ROPOSED 50 nZT WJ:Dlil PRIVAT];l RIGHT-OF-WAY SHOWN 0 SUBDIVISION PLAN IS lmlUilBY EXTINGUISHED AND SUBSTITUTED THEREFOR ARl!: THE RI PROVIDED IN AGREE:M:ENT DATED FlmRUARY 22. 1996. AND RECORDB:ll IN THE HEREINAFT];l NAMED RECORDER'S OFFICE IN MISCELLAllEOUS RECORD BOOK 562. PAGlil 936, AND THE DESCRIBED PROPlilRTY IS SPEC!FICALLY CONVEYED TOGlilTHER WITH AND SUBJECT TO THE OF-WAY ~ROVIDB:ll IN SAID AG1<EImICNT DATED FESRUARY 22. 1996, WEICH =S FROM ROAD 0034 KNOWN AS HOLLY l?IKE TO THE ABOVB:-DlilSClUBB:ll LOT NO.4 KNOWN AS 1550 P IICE . IN ADDITION. THE ABOVl!:-DlilSCRIBB:ll LOT NO.4. IS CONVEYJ!:D TOGlilTHER WITH AND SUB T TO THE RIGHT-OF-WAY UTENIlING FROM TRAFFIC ROUTE NO. 34 KNOWN AS HOLLY PIICE TO LO 4 ON SAID ABOVl!:-DlilSCRIBB:ll TRACT OF' LAND AS SlilT FORTH IN THE RIGHT-OF-WAY AGRE DATED APRIL 22, 1949, AND RECORDED APRIL 22, 1949. IN THE ImREDlAFTER NAlmD RECORDE:R'S OFFICE IN MISCELLANEOUS RECORD BOOK 84. PAGE 463. IN ADDITION, THE ABOVl!:-DESCRIBB:ll LOT NO. 4 IS CONVEY.Ell TOGlilTHER WITH A RIGHT-O -WAY OVl!:R THE GRAVI!:L LANE EXTEmJING ALONG THE EASTERN PORT!ON OF LOT NO. S AT A WID OF 20 FElilT FROM LAND NOW OR FORMERLY OF DANIEL W. JOHNSON AND W!FE SOUTHWARDLY TO LOT NO. 4 ABOVB:-DESCRIBED. BEING KNOWN AS: 1550 HOLLY PIKE SOUTH, SOUTH MIDDLETON TOWNSHI (CARLISLE), PA 17013 PROPERTY ID NO. 40-10-0632-038 TITLE TO SAID PREMISES IS VESTED IN TIMOTHY A. BECRAFT AND PAM LA J BELCRAFT HUSBAND AND WIFE AS TENANTS BY THE ENTIRETY BY D ED FROM PAUL E: WEIBLEY, EXECUTOR OF THE LAST WILL AND TESTAMENT OF DORIS R. WEIBLEY, DECEASED DATED 6/15/98 RECORDED 6/17/98 IN D ED BOOK 179 PAGE 380 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5408 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC. F/K/ NORWEST MORTGAGE, INC., Plaintiff (s) From TIMOTHY A. BECRAFT AND PAMELA J. BECRAFT (I) You are directed to levy upon the property of the defendan' (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 fr m paying any debt to or for the account of the defendant (s) and from delivering any property of the defen nt (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added a a garnishee and is enjoined as above stated. Amount Due $134,798.08 L. L. $.50 Interest FROM 5/12104 TO DATE OF SALE 9/3104 PER DIEM @$19.90 - $2,388.00 Ally's Comm % Due Prothy $1.00 Ally Paid $143.25 Plaintiff Paid Date: MAY 18, 2004 Other Costs CURTIS R. LONG (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN. ESQUIRE Address: UDREN LAW OFFICES, P.c. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #30 On June 10,2004 the sherifflevied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 1550 Holly Pike South, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 10,2004 By: ,)od'I.{SrvUiIL Real Estaie Deputy \1 \ ~.~ ti' I~,~)l \ c:; ~'~ H 3d "".' ' \,r \Id E( Z 8\ lVH A1Nf!v~: ,~: .-jn~ JJ11l311cd, J.' ":);~jO ~ e c::;:nJ c::u:;) c:::::J Gf) IiVil It is to be noted that the proposed 50 feet wide private right-of.way shown on said subdivision. plan is herehy. extinguished and substituted therefore are the rights provided in agreement dsted February 22, 1996, and recorded in tbe bere-inafter named Recorder's Ollice in Miscellaneous Reconl Book 562, Page 936, and the . above-described P'\lJlOllY is specifically conveyed together with and subject to the righl. of-W~y provided in said Agreement dated February 22,.I!I96, whicb extends from State Road 0034 lrnoim as Holly Pike to the above. descriiJe4 LotNo, 4lrnown as 1550 Holly Pike, In addition, the above-described Lot No.4 is conveyed together with and subjectto the right- of-way. extending from namc Route No; 34 . knolVn as Holly Pike to Lot No.4 on said above. described tract of land as set fortli in the rlght.of- way agreement dated April 22, 1949,. and recorded April 22. 1949, in the hereinaftir named Recorder's Office in Miscel.laneous Record Book 84,Page463.. . ..' . :." ..../..,:' .... .. '. :. .... ,'" ., .." .,"....".-( In addition. the above-described Lot No, 4 knOwn" 1550 Holly Pike is conveyed to-gether with and suhject to a right-of-way 60 feet in width extending from the dividing line between Lots Nos. I and 5 westwardly to said Lot No, 4, the Southern lioe. of said 60 feet wide. rigbt-of,way being Southern line of the right-of.way shown as a proposed 50-feet.wide private right-of.way !lCI'O" Lot No,. 50n said 8ubdivision plan for WeibleyEslale, . In addition, the above-descrlbed Lot No. 4i8 convey<;d together with 'a ,right,of.way over the gravel lane extend'.ng along the Eastern portion of Lot No.5 at'awilftIi. of2O feet from land now or fonnerly of Daniel, W. Johnson and wife Southwardly to Lot Nu. 4 above-described. . . . BEING KNOWN at. 1550 Holly Pike South, South Middleton Thwn.ship (Carmie). PA J70i3. PROPERTY ill NO.: 40-10-0632-038, TIlLE TO SA1l) premises is' vested in TImothy A. Becraft and Pamela 1. Becraft, hu.band and wife. as tenanti by the entirely by Deed from Pa\JI E. Weibley. Executor of the Last Will and Testament of Dori8 .It Weibley, de- ceased, dated 6/15/98 recorded 6/17/98 in Deed Bookl79 Page ,380. REAL ESTATE SALE No. 30 Writ No. 2001-5408 Civil Term Welle Fargo Home Mortgage, Inc., flkla Norwest Mortgage, Inc. Ve . TlmothyA. Becrllftand Pamela J; Becraft Atty: Mar<<U.....dra..n .. .. .. ".. .~.. "";"".. " ,',',. DESCRIPTION '''''> .... .... AI.LT6AT'tERrAIN house and lot 0 ground~i\Uatein South MiddletonT0wn8hip, Cumbetland CountY, PenniylVania," bounded and described in accordance with subdivision plan for Weibley Estate consisting of two page. which'was prepared by Fisher; Mowery, Rosendale & Associates, Inc., dated May 14,1997. a copy 0 which.. recorded in ~Iiereinafter._ed l\eciluler'. Office in Plan. Book }5, !\ige 45, as follows: ." .......... ". .,. BEGlNNlNG at an.iron pin set on the Northern. line of land noW or fonnerly of Charley Ann Rhoads III the dividing. line be,tween Lots No~4 8Ild5 and. which iron piJt set atthe place 0 beginning is South 89 degrees OS minutes 18 seconds W~a dis-tance of 69.33 j~ from Lot No.1, ~ured along saidNorthem line of land now .or formeny Of Charley ADn Rhoads; thence from said iron pin sei at .the place of beginning along said Northern line of land now or formeriy of ctuu:1ey Ann Rhoad8, SoUth 89 de.grees 08 minutes 18 SecondsWC8t a distance of 593.67 feet to an iron pinlll,s""",erconunon to Lots Nos. 4 and Sand 8lU.'d lind. now. orfonne. rtyo. fCharley Ann Rh<Jnds;tbCn~ along said dividing line between said Lots J:los, 4 and 5. thefollowing ~ (3) COlIr8Ils and. distance" (1) North 00 degrees 45. minutes 20 second8'Ea8la distance of 142.73 feet to8lliroD pin; (2)North 67 degrees 55 minule8}6 ~dsEast a distanceof.332.91 feel to an' iron pIn; and (3) South 47 degrees 34 minutes rn seconds East a distance of 383.71 feet to an iron pin set III the place ofBEGlNNlNG, Theobove-described Lot of Land is all of Lot No, 4 as shown 9n .aid subdivi8ionplan for Weibley Estate, recorded as afore.aid, on which there is .erected.a one-story frame dwelling house and other iro-provemen18. which has the mailing address of 1550 Holly Pike, Carlisle. 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"'''- . . .r'"~ ~a . ~ a~ edl. o. . , ~"'o~~."'~ 0 oo~ ~4~o. _5'~o'" .~_.oo""- ~.o"''''S~S~B o"OS'__oao"," ._.a'~.R w . 0_.- - ,~. 1- no..... - .1.. ..-."".'." :":~;I"'!~;;'\I'lil~!j;I'l;;';;lj;lill!!;'ll'\!!';I~l, 8:?'ls~SR ;!~!r.,,;l'&_lga2Ii~i.llliQ' ~.I:ISr,~i~ ~ ~rgi~fi:r " ,,_ o' Z-l ".0 0.' ..._ .0." " ." "z " .,.."a:;" S'~"- ,,_.O~ _~~;~~~.~O ~~W~~~S~O ~S~.~S~z~a.~~~s~o o~~~~o ~~ g~*o~~o~S~ ~o. ._ ~ ~~OO....o'-' p-".' o-".a-; o~ z'. '" ~.-- D=~l-lil~ a...llo~",,,,,,,~s.~g,.~~g1.la~ ....~1_..4 -l....~-I.~ .,,"_R'" ~ v>"z< "'''a,~'''{Jl-~'v~.~o. "-' "-~~S''' ""60".'00.- '0,1., ,!: j'h alii "h'l t, h' 1 ,~, '!"hli'! l' a:, :,d ..1...... ...~,.......'.., ....... 1....'. ". .,....... 9-11(~!~. 9PI;il"<oH8S'!il1i ~~l' 0&' .S'.;o~ll. ~~ii!~..'& .., _ ,,' _ _ 0"'.S'0.. _._, .. '{Jl~~o ~ 0..... ~ ..--.a.... ~:.~aa~~ 'b o'::.~~;;tl"6 aa~\\'H& l:?-~!'o'l~ z.~".':'-~p~g, ~%;;,:;.3~:;~ -.a ~..",. t ~'~a' ..~_, s. ,.. ..0 o.,_....~. :;K&~~alr.; \l ~~ ~Hg ;;~~[~~g 11'ag" H& 5hHl~h! h~~g,n~?;iO UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY r.D. NO. 04302 WOODCREST CORPORATE CENTER ~11 WOODCREST ROAD, SUITE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLArNTrFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF CO~~ON PLEAS CIVIL DIVISION Cumberland County v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 AFFrDAvrT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. 1Jdren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execut:ion, on the date (s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on t:he attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalti.es of 18 Pa.C.S. Section 4904 relating to unsworn falsification to autho it:ies. BY: OFFICES, P.C. Dated: August 16, 2005 UDREN LAW OFFrCES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUrTE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLArNTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-5408 v. Timothy A. Becraft Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Defendant(s) DATE: April 4, 2005 TO: ALL PARTIES rN INTEREST AND CLArMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY~ OWNER(S): T~othy A. Becraft & Pamela J. Becraft PROPERTY: 1550 Holly Pike South South Middleton Township (Carlisle), PA 17013 Improvements: RESIDENTrAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on Sectmober 7, 2005, at 10: 00 am, at the Commissioners Hearing Room, 2nd Floor Courthouse, Carlisle, Pa. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 da}'s after the filing of the schedule. EXHIBIT A !~ .. 3. .J! %. ..,,~ ~.. a~-4~lt ill ?:,O 0 .... n\~!\ a: X:~ \ \! \\~ ",... ...~~ .. dl-~ '& ' ~ q$ ~\~hi ~,g ~. ",'" \"\0 ~ ~ - \ \ ~~ ~~'O ~ tt,$ ~r68\ ~\\ ! ",u. \r _ ~l h 1 is -. i~ Pll ~! 'H~ ;;~: \\\161 n1 k 1l"" 0 l ~,\~ l~ \\~l!..l ,g ,i \ ~. . '" li\! 1 \! " a'" \ .. - %~ :--. w~ ~~ \i~\l! \\i\ >] ~l~~ ~5 '" .,l" II II l ~~. \..1 \it 1'~~ "~.r \\\~i\ ;!:. . J.......-: ~ ~ , 1" a~[th ~ i . '. ~$ ! i 'iji . $ , " . ~~.&~ ~ ~\j ... , ; . ~~-\::1t ;;: . ;o'~:~1 S'; 1 ! jc .- 1 O~O ; ~ ' /, '-" ~ , ,,~-;~~, ~z ^ 'L'~ ...., 1 F -~~~ i "- \, . , ~\gt 1-':1c i .JJ "* o~ 'ls 000 .. "$ ~ .. "- 8 ~ l ~ iJ5 '" ~- 1:(\1 i~a~. .. ' ~ 'S \ u: "i l~. 1; st;:. ,,- ~ ;V\ "- (,) ~" ~, .; ~ $ ..Il- ~\ ,$ g ~ :so t~ ~.~. ~ € \ ~ &~ \ 1 ~ ~ ~\ 'E:lg -g ",\Il-~ ~ l ~ oB~'" .. '" ..i u,l ::>~ ll- l - "6;1: 11 ~ri\ '1 ~ ~ ~,.... il 0... "'''' .s.'" .... oii& t - 0$ 1- ~ !IS ..0 lD ' . ! .. -,g ~~ <> CI'. ~'r ~en_ e:&"di~ \!'" ~~ . "-- oe' i io \li ';:Il- ~1 'O~ ,_u..' ... ~ -e~ ~ !~ ,.. 'CD'~ s~ 3~1~ '0 S a:~ I~&~ em ~ "i~~ I ~ <> ""K d '" . u,l", mJ!! i\ i~ en- H eo-a 10 B~ ~~ ~i ~~ ~,,',~"~ ,..a: cr.';: 5:! ~~ F:J \ .. . , i ~~ ~ " --.. ~ , "-- 1 "5-8 \'- o(~ ~ % s: 1* -g 1A' Q) - :> <A <<S CD -g 0 (,)"0 z: a~ U&\ 5 m~ !'QS 0 .. '" '" ... '" ~~ .. '" '" ... '" <D t- eX> '" .. .. .. .. .. .. c: ~ ~ '0 ~ :i ~ o ~ j 'c:' '- ~ ~ 1 II ~ o u ! ~ " :E E o ... ... ~ ~ ~ .. " ~ ... ,.: i g o ... <J) C\. EXHIBIT A Wells Fargo Home Mortgage, Inc. f/kla Norwest Mortgage, Inc. VS Timothy A. Becraft and Pamela J. Becraft The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5408 Civil Term Ron Kerr, Deputy Sheriff, who being duly sworn a.:cording to law, states that on June 21, 2005 at 6:49 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Timothy A Becraft, by making known unto Timothy Becraft, personally, at 1550 Holly Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on May 18,2005 at 8:55 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Pamela 1. Becraft, by makiing known unto Pamela 1. Becraft, personally, at 1550 Holly Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on July 12,2005 at 7:22 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy A. Becraft and Pamela J. Becraft, located at 1550 Holly Pike, Carlisle, Pennsylvania, according to law. R Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Timothy A. Becraft and Pamela 1. Becraft, by regular mail to their last known address of 1550 Holly Pike, Carlisle, PA 17013, These letters were mailed under the date of July 01,2005 and never returned to the Sheriffs Office. Sworn and subscribed to before me ~~ --<~, This _ day of Prothonotary R. Thomas Kline, Sheriff By--0~jJ \."" ,+~ RealEs~ 2005, A.D, EXHIBIT B (") c ....' ~ c:...;:'.) ""' ,.,. c: en N >.D ..\ ~<. ~ "t'".", ::;i:: -< m~ '- :gC,:.\ -;~~1,,1;') ~-~~ t~t ,<--rn S -J; '-< '2 o - COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND } 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 Wells Fargo Bank N A is the grantee the same having been sold to said grantee on the 7th day of Sept AD" 2005, under and by virtue of a writ Execution issued on the 4th day of April, AD., 2005, out ofthe Court of Common Pleas of said County as of Civil Term, 2001 Number 5408, at the suit of Wells Fargo Home Mtg Inc against Timothy A Becraft & Pamela J is duly recorded in Sheriff's Deed Book No. 271, Page 2973. f/ ; Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. VS Timothy A. Becraft and Pamela J. Becraft The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5408 Civil Term Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2005 at 6:49 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Timothy A. Becraft, by making known unto Timothy Becraft, personally, at 1550 Holly Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on May 18,2005 at 8:55 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Pamela J. Becraft, by making known unto Pamela 1. Becraft, personally, at 1550 Holly Pike, Carlisle, Cwnberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on July 12,2005 at 7:22 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy A. Becraft and Pamela 1. Becraft, located at 1550 Holly Pike, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Timothy A. Becraft and Pamela 1. Becraft, by regular mail to their last known address of 1550 Holly Pike, Carlisle, PA 17013. These letters were mailed under the date of July 0 I, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 07, 2005 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attorney Mark Udren for Wells Fargo Bank, N.A. slb/m/t Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. It being the highest bid and best price received for the same, Wells Fargo Bank, N.A. slb/mlt Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. of One Home Campus, Des Moines, IA 50328, being the buyer in this execution, paid to SheriffR, Thomas Kline the sum of $1,602.46. ~ Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution ofPraceeds Sheriffs Deed $30.00 31.42 15.00 15_00 30,00 10.00 1.00 12.00 3.46 15.00 30,00 773.00 553.88 18.20 25.00 39.50 $ 1,602.46 Sworn and subscribed to before me 2005, A.D. Prat ~~ ~c.~~ V \ cJt. oil 76 ..2e.- /7D 71 S , . so~ Ai-A r ~~~ R. Thomas Kline, Sheriff BY j ~d U~"~U'L Real Estate Skrgeant f , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HrLL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1550 Holly pike South, Carlisle (South Middleton Township), PA 17013 I. Name and address of Owner(s) or reputed Owner(s): Name Address Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Pamela J. Becraft 1550 Holly pike South 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 Unemployment Compo Fund L.1. Building, 16th Floor Harrisburg, PA 17121 Agway Energy Products 530 E. North St. Carlisle, PA 17013 ~ 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. The United States of America Dept. Of Housing and Urban Development 490 L'Enfant Plaza East, Ste 3214 Washington, DC 20024 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of the property and whose Name every other person who has any record interest interest may be affected by the sale: Address in Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 17013 Domestic Relations Section 13 N.. Hanover St. Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 1550 Holly pike South Carlisle, (South Middleton Township), 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 u worn fa ification to authorities. DATED: March 23, 2005 Mark J. Udren, ESQ. Attorney for Plaintiff , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Timothy A. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly pike South, Carlisle (South Middleton Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $9,631.60, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffls Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorneyls fees. you may call: (856) 669-5400. mortgagee the back payment, late To find out how much you must pay I 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. more chance you will have of stopping the sale. to obtain an attorney.) The soo~er you contact one, the {See notice on page two on how t 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. S. 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 (101 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 1 ,. UD~EN 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 PLArNTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd Charlotte, NC 28217 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Timothy A. Becraft Pamela J. Becraft 1550 Holly pike South Carlisle, PA 17013 Defendant(s) NO. 01-5408 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela J. Becraft 1550 Holly Pike South Carlisle, PA 17013 Your house (real estate) at 1550 Holly pike South, Carlisle (South Middleton Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on September 7, 2005, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $9,631.60, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be reI isted 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 charges, costs and reasonable attorney's fees. you may call: (856) -669-5400. mortgagee the back payment, late To find out how much you must pay, 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how ~ 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 Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ASSOCIATION DE LICENCIDADOS Cumberland Court Bar Association 2 Liberty Avenue Carlisle, PA 17013 ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CU;~ERLAND COUNTY, PENNSYLVANIA, BO~ED ANp DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN FOR WEIBLEY ESTATE CONSISTING OF TWO PAGES WHICH WAS PREPARED BY FISHER, MOWERY, ROSENDALE & ASSOCIATES, INC., DATED MAY 14, 1997, A COPY OF WHICH IS RECORDED IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN PLAN BOOK 75, PAGE 45, AS FOLLOWS: BEGINNING AT ,AN IRON PIN SET ON THE NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY "ANN RHOADS AT THE DIVIDING LINE BETWEEN LOTS NOS. 4 AND 5 AND WHICH IRON PIN SET AT THE PLACE OF BEGINNING IS SOUTH 89 DEGREES 08 MINUTES 18 SECONDS WEST A DISTANCE OF 69.33 FEET FROM LOT NO.1, MEASURED ALONG SAID NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, THENCE FROM SAID IRON PIN SET AT THE PLACE OF BEGINNING ALONG SAID NORTHERN LINE OF LAND NOW OR FORMERLY OF CHARLEY ANN RBOADS, SOUTH 89 DEGREES 08 MINUTES 18 SECONDS WEST A DISTANCE OF 593.67 FEET TO AN IRON PIN AT A CORNER COMMON TO LOTS NOS. 4 AND 5 AND SAID LAND NOW OR FORMERLY OF CHARLEY ANN RHOADS, THENCE ALONG SAID DIVIDING LINE BETWEEN SAID LOTS NOS. 4 AND 5, THE FOLLOWING THREE (3) COURSES AND DISTANCES: (1) NORTH 00 DEGREES 45 MINUTES 20 SECONDS EAST A DISTANCE' OF 142.73 FEET TO AN IRON PIN, (2) "N(lRTH 67 DEGREES 55 MINUTES 3 6 SECONDS EAST A DISTANCE OF 332.91 FEET TO AN IRON PIN; AND (3) SOUTH 47 DEGREES 34 MINUTES 07 SECONDS EAST A DISTANCE OF 383.71 FEET TO AN IRON PIN SET AT THE PLACE OF BEGINNING. THE ABOVE-DESCRIBED LOT OF LAND IS ALL OF LOT NO. 4 AS SHOWN ON SAID SUBDIVISION PLAN FOR WE:tBLEY ESTATE, RECORDED AS AFORESAID, ON WHICH THERE IS ERECTED A ONE- STORY FRAME DWELLING HOUSE AND OTHER IMPROVEMENTS, WHICH HAS THE MAILING ADDRESS OF 1550 HOLLY PIKE, CARLISLE, PENNSYLVANIA 17013. IT IS TO BE NOTED THAT THE PROPOSED 50 FEET W:tDE PRIVATE RIGHT-OF-WAY SHOWN ON SAID SUBDIVISION PLAN IS HEREBY EXTINGUISHED AND SUBSTITUTED THEBEFOR ARE THE RIGHTS PROVIDED IN AGREEMENT DATED FEBRUARY 22, 1996, AND RECORDED IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN MISCELLANEOUS RECORD BOOK 562, PJ>.GE 936, AND THE ABOVE- DESCRIBED PROPERTY IS SPECIFICALLY CONVEYED TOGETHER W:tTH AND SUBJECT TO THE RIGHT- OF-WAY PROVIDED IN SAID AGREEMENT DATED FEBRUARY 22, 1996, WHICH EXTENDS FROM STATE ROAD 0034 KNOWN AS HOLLY PIKE TO THE ABOVE-DESCRIBED LOT NO. 4 KNOWN AS 1550 HOLLY PIKE. IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 IS CONVEYED TOGETHER WITH AND SUBJECT TO THE RIGHT-OF-WAY EXTENDING FROM TRAFFIC ROUTE NO. 34 KNOWN AS HOLLY PIKE TO LOT NO. 4 ON SAID ABOVE-DESCRIBED TRACT OF LAND AS SET FORTH IN THE RIGHT-OF-WAY AGREEMENT DATED APRIL 22, 1949, AND RECORDED APRIL 22. 1949, IN THE HEREINAFTER NAMED RECORDER'S OFFICE IN MISCELLANEOUS RECORD BOOK 84, PAGE 463. IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 KNOWN AS 1550 HOLLY PIKE IS CONVEYED TOGETHER W:tTH AND SUBJECT TO A RIGHT-OF-WAY 60 FEET IN W:tDTH EXTENDIllG FROM THE DIVIDING LINE BETWEEN LOTS NOS. 1 AND 5 WESTWARDLY TO SAID LOT NO.4, THE SOUTHERN LINE OF SAID 60 FEET W:tDE RIGHT-OF-WAY BEIllG SOUTHERN LINE OF THE RIGHT-OF-WAY SHOWN AS A PROPOSED 50 FEET W:tDE PRIVATE RIGHT-OF-WAY ACROSS LOT NO. 5 ON SAID SUBDIVISION PLAN FOR WEIBLEY ESTATE. IN ADDITION, THE ABOVE-DESCRIBED LOT NO. 4 IS CONVEYED TOGETHER WITH A RIGHT-OF-WAY OVER THE GRAVEL LANE EXTENDING ALONG THE EASTERN PORTION OF LOT NO. 5 AT A WIDTH OF 20 FEET FROM LAND NOW OR FORMERLY OF DANIEL W. JOHNSON AND WIFE SOUTHWARDLY TO LOT NO.4 ABOVE-DESCRIBED. BEING KNOWN AS: 1550 HOLLY PIKE SOUTH,CARLISLE, (SOUTH MIDDLETON TOWNSHIP) PA 17013 PROPERTY ID NO.: 40-10-0632-038 TITLE TO SAID PREMISES IS VESTED IN TIMOTHY A. BECRAFT AND PAMELA J. BECRAFT, HUSBAND AND WIFE AS TENANTS BY THE ENTIRETY BY DEED FROM PAUL E. WEIBLEY, EXECUTOR OF THE LAST WILL AND TESTAMENT OF DORIS R. WEIBLEY, DECEASED DATED 06/15/98 RECORDED 06/17/98 IN DEED BOOK 179 PAGE 380. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5408 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff (s) From TIMOTHY A. BECRAFT AND PAMELA J. BECRAFT (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $134,798.08 L.L. Interest FROM 5/12/04 TO DATE OF SALE 9/7/05 - PER DIEM @$19.90 - $9,631.60 Atty's Comm % Due Prothy $1.00 Atty Paid $1693.78 Plaintiff Paid Date: APRIL 4, 2005 Other Costs CURTIS R, LONG (Seal) Prothonotary 'J3r~/J/,1 n~ 0 - Q . 7f---9 /1../1., ;--- Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #2-0 On May 05, 2005 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 1550 Holly Pike South, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 05, 2005 By:\jdCL/J~ Real Estat<iDeputy ZO :[ V '1- 8dV ~OOI \-'d '/,1-,,; I:"", :",( ;,.L;~"<' ~~.! '. \" ...., , ,., J~\ I 1(, .:lJ\~jt' S .:jj-lJ_ :jtJ __~ J ~.:J,~ ra ~.' ~\ ~ ~-q:;' ~ 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 15, 22, 29, 2005 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 29 day of July. 2005 NOT ARI l SEAL LOIS e, SNYDER, Notary Public I' C ."isle 80ro, Cumberland County , Mv Commission Ewires March 5.2009 REAL ESTATE SALE NO. 20 THE ABOVE-DESCRIBED lot of land is an of Lot No.4 as shown on said Subdivision Plan for Weibley Es- tate, recorded as aforesaid, on which there is erected a one-story frame dwel1in~ house and other 1m prove- menis, -which has the mailing ad~ dress of 1550 Holly Pike, Carlisle. Pennsylvania 17013. IT IS TO BE NOTED that the proposed 50 feet wide private right- of-way shown on said Subdivision Plan is hereby extinguished and substituted therefor are the rights provided in agreement dated Feb- ruary 22, 1996, and recorded in the hereinafter named Recorder's Office in Miscellaneous Record Book 562, Page 936. and the above-described property is specifically conveyed together with and subject to the right of-way provided in said agreement dated February 22, 1996. which ex- tends from State Road 0034 known as Holly Pike to the above~described Lot No.4 known as 1550 HoUy Pike. IN ADDITION, the above-de- scribed Lot No. 4 is conveyed to- gether with and subject to the right- of-way extending from Traffic Route No. 34 known as Holly Pike to Lot No.4 on said above-described tract of land as set forth in the right-of- way agreement dated April 22. 1949. and recorded April 22, 1949, in the hereinafter named Recorder's Office in Miscellaneous Record Book 84, Page 463. IN ADDITION, the above-de- scribed Lot No. 4 known as 1550 Holly Pike is conveyed together with and subject to a right-of-way 60 feet in width extendinR from the divid- ing line between LOts Nos. 1 and 5 westwardly to said Lot No, 4, the southem line of said 60 feet wide right-of-way being southen1 line of the right-of-way shown as a pro- posed 50 feet wide private right-of- way across Lot No. 5 on said Sub- division Plan for Weibley Estate. IN ADDITION, the above-de- scribed Lot No.4 is conveyed to- gether with a right-of-way over the gravel lane extending along the east- ern portion of Lot No. 5 at a Vlidth of 20 feet from land now or fonnerl; of Daniel W, Johnson and wife south- wardly to Lot No.4 above-described. Being known as: 1550 Holly Pike South, Carlisle, (South Middleton TO\vnship) PA 17013. Property ID No, 40-10-0632-038, TITLE TO SAID PREMISES IS VESTED IN Timothy A. Becraft and Pamela J. Becraft, husband and wife as tenants by the entirety by deed from Paul E. Weibley. Exec\.ltor of the Last Will and Testament of Doris R. Weibley, deceased dated 06/15/ 98 recorded 06/17/98. in Deed Book I 79, Pa~e 380. Writ No. 200 I -5408 Civil Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage. Inc. VS. Timothy A. Becraft and Pamela J. Becraft Atty.: Mark Udren ALL THAT CERTAIN house and lot of ground situate in South Mid- dleton Township, Cumberland County, Pennsylvania bounded and described in accordance with subdivi- sion plan for Weibley Estate consist- ing of two pages which -was prepared by Fisher, Mowery, Rosendale & Associates. Inc.. dated May 14, 1997, a copy of which is recorded in the hereinafter named Recorder's Office in Plan Book 75, Page 45, as follows: BEGINNING at an iron pin set on the northern line of land now or fonnerIy of Charley Ann Rhoads at the dividing line between Lots Nos. 4 and 5 and which iron pin set at the place of beginning is South 89 degrees 08 minutes 18 seconds West a distance of 69,33 feet from Lot No. I, measured along said north- ern line of land now or formerly of Charley Ann Rhoads; thence from said iron pin set at the place of be- ginning along said northern line of land now or formerly of Charley Arm Rhoads, South 89 degrees 08 min- utes 18 seconds West a distance of 593.67 feet to an iron pin at a cor- ner common to Lots Nos. 4 and 5 and said land now or formerly of Charley Ann Rhoads; thence along said dividing line between said Lots Nos. 4 and 5, the following three (3) courses and distances: (1) North 00 degrees 45 minutes 20 seconds East a distance of 142.73 feet to an iron pin; (2) North 67 degrees 55 minutes 36 seconds East a distance of 332.91 feet to an iron pin; and (3) South 47 degrees 34 minutes 07 seconds East a distance of 383.71 feet to an iron pin set at the place of beginning. ...~ . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005, 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, COpy S ALE #20 Sworn to and su sc PUBLICATION CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE. PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attached hereto on the above stated dates 553.88 REAL ESTATE SALE No. 20 WrIt No. 2OO1-li408 CIwIl T...... w.". F"'9" Home Mortgage,lnc. I/kIa Mol wlllll MQrlgeg., Inc. vs nmolhy 10.__ Pemela J._ Atty: IIlitrtc Ud..... DESCRIP110N , ALl.TI1fJ CEIITAiN house and lot 01 grollOd _ m Sooth Middkm Township, Comb.dand COllIlIy, Penmyt...... bounded and described in ~withSU_PlanforWcillley E&tate_g 01 IWo pages wbidI wasl'l'l"'l'l by 11sher, M"""J', Rooeodale &~ 1m: _May 14, t997.a_olwbidIis~ . m the here-inaftcs: lWJlI:dR<<order's Office in Plan Book 75. Page 45," follows: , BEGlNNlNG at aD iron pin set on tl1e Noohem .line of land now or formerly of Charley Ann Rboalkal tbe dividin,g line be-lw= Lots NoS. 4 and 5 and which iron pin set at the Place of lleginolns is Sooth 89 depi 0& mim>Ies 18 seconds West a distance of 69.33 feet from Lot No.1, measured along said NOrthern line of land llOWorformerlyolClJadeyAnnRboalk'tbeo<e from~iroo._PinsetattbePlaceof~ along said Nortbom line of land now or fonnerly 01 Cbasloy Ann Rboods, Sooth 89 depi 08 _18_W"'.dis....,.0159J,67feet to an 1l'OD. pip at a comer conunon t\) Lro Nos 4 and 5 and said land now or _y 01 Charity Ann Rbood5: tbence along said di~diog line between said Lots Nos, 4 and 5, tbo following three (3) C;O~ at',~ distances: (1) North 00 degrees 45 1l11DUte5o W seconds.East a distance of 142,73 feet'" anironpin: (2)Non!l67 deg<oes55 _"'36S<<OOdsEast.dislanceoI332,91feet "', an noo pm: _(3) Sooth 47 depi J4 mmu~ O1.secoods BasI: a distance of 383.71 feet to an lroll pm set at the Place of BEGINNING n.. abo,,",",,"bed 10< ofland is all ofW No 4 as shown on said Subdivision Plan for Weible; Estate, recorded as afrmaid, on whicb there is ""'red, a one story ftame dwelling bo... and otberuopro__hhastbomailing oIdr<aa 01 1550 IIoUy Pike, Cm-1isIe, Penm,_ non, Itis"'beooltdlbaltbe(lll>1lOS'd5Ofeetwide priva!e r.iP-of~way .dIowA QI laid ~vi&io& ftIa....,. '_'.'-~ dlioe6loo, .. .. .. ...... II ..0- _ ~ 22, 1l96. BOll .-..Iii .... _ ...... _'a 0IIi0! iI lIiIce1lnneoos ~ Book 562, page 936. -.I .... ~bed _ is speci1Wll' _edtogelberwilbandaobj"'",dIe~' w., provmed in sai4'Agreemeot _l'ebnwl' 22, 19%, whicb exteods from State Road 0034 mown as lkilly Eike to the above-described Lot No. 4 known as 1550aolly Pike. lD addition, the above-de-scribed Lot No.4 is "'""yed tog<:tht<wilbandaobject'odleright-<>f- way extending from Traffic Route No. )4 known lll\ Holly Pike to Lot No.4 on said. above- describedtractofIandassetforthintherighl:-of- woy agreement_^,"" 22. 1949, and~ ^'"" 22. 1949, in III< hereinafter IllIlIled Recordc:r's Office ia ~ Record Book &4, Page 463. In addition, me above~bt-r"ror"i'\U.~" known as 1550 HoUy Pike is conveyed together with and subject to a.rigbt-of-way 60 feet in width exteW!ing from the dividing line between. Lets Nos. 1 and 5 wesrwardly \0 Mlid Lot No.4, the SoUlbern line of said 60 feet wide right-of-way being Soudioro line of Ibe righl-ol,woy -.". proposed 50 feet wide private right..of-way across Lot No.5 on ~d Subdivision Plan for Weibley Estate. In addition. the above-de-scribed Lot No.4 is oonveyed rogether -with a right-of-way over \he pel IJme extending along tbo ~ ponion o! Lot No. .5 at a width i1. 20 feet from Iaod now or funnedy _of Daniel W. JohnsoD and wife Soutbwat<ll,"'LotNo,4~beI\. BElNG 'KNOWN A!l: 1550 HoUy Pike SoUlb, Carlia1e, (SoutbMiddktonTowosbip), PA t70t3. PROretm' LD. No, 4O-t~3z.o38. rm.E"'said~is-...tedin'l\mothyA- _ and l'amela I. _ busband and wile, as tenants by the entirely by Deed from Paul E. w.ibloy. ElolOItor oftbe Last Will and T_ o! \llxi$ \l WeibIoy, de<ooed. dated 061\5/98, recoodolll6ll71'lll in Dool Book \79 Pag. 380.