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HomeMy WebLinkAbout06-2661UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Mechanicsburg, Way (Lot 32) PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. dL - o?, (v (9 [ GA, 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669.5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 1335 Armitage Way (Lot 32) MUNICIPALITY/TOWNSHIP/BOROUGH: Hampden Township COUNTY: Cumberland DATE EXECUTED: 12/27/04 DATE RECORDED: 12/29/04 BOOK: 1892 PAGE: 3645 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 4/25/06: Principal of debt due $379.664.99 Unpaid Interest at 7.65% from 11/1/05 to 4/25/06 (the per diem interest accruing on this debt is $80.63 and that sum should be added each day after 4/25/06) 3,955.71 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges 83 f $162 . (monthlyy late charge o should be added in accordance with the terms of the note each month after 4/25/06) 814.15 Attorne s Fees (anticipated and actual to 5% of principal) 18.983.25 TOTAL $404,023.10 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $404,023.10 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark U en, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 LEGAL DESCRIPTION F` ALL THAT CERTAIN PARCEL OF LAND LOCATED IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, BEING SHOWN AND DESIGNATED AS LOT 32 ON A PLAN ENTITLED "FINAL SUBDIVISION PLAN-PHASE II FOR HAMPDEN STATION", BY DAWOOD ENGINEERING, INC., PLAN DATED MARCH 20, 2002 AND LAST REVISED April 29, 2002. i SAID PARCEL BEING MOTtE FULLY DESCRIBED AS FOLLOWS: BEGINNING AT A 5W' REBAR SET, SAID REBAR BEING ON THE LINE OF LOTS 22 (PHASE I) AND 32 (PHASE 1) WHERE SAID LINE INTERSECTS WITH THE SOUTHERN RIGHT-OF-WAY LINE OF ARMITAGE WAY (50' RIGHT-OF-WAY); THENCE ALONG LOT 22 (PHASE 1), THE FOLLOWING TWO COURSES AND DISTANCES: 1. SOUTH 40 DEGREES 05 MINU'T'ES 54 SECONDS WEST, A DISTANCE OF 132.68 FEET TO A 518" REBAR SET; 2. SOUTH 10 DEGREES 02 MINUTES 14 SECONDS WEST, A DISTANCE OF 10.00 FEET TO A 5/8" REBAR SET AT THE REAR CORNER OF LOTS 31 AND 32 (PHASE II); THENCE ALONG LOT 31, NORTH 79 DEGREES 57 MINUTES 46 SECONDS WEST, A DISTANCE OF 110.00 FEET TO A 5/8" REBAR SET ON THE EASTERN RIGHT-OF-WAY LINE OF ARMITAGE WAY; THENCE ALONG SAID RIGHT-OF-WAY LINE, THE FOLLOWING THREE COURSES AND DISTANCES: 1. NORTH 10 DEGREES 02 MINUTES 14 SECONDS EAST, A DISTANCE OF 7.06 FEET TO A 5/8" REBAR SET; 2. ALONG A CURVE TO THE RIGHT, HAVING A RADIUS OF 125.00 FEET, AN ARC LENGTH OF 218.52 FEET, AND A CHORD BEARING AND DISTANCE OF NORTH 60 DEGREES 07 MINUTES 04 SECONDS EAST, 191.74 FEET TO A 5/8" REBAR SET; 3. SOUTH 69 DEGREES 48 MINUTES 07 SECONDS EAST, A DISTANCE OF 29.88 FEET TO A 518" REBAR SET ON THE FRONT LOT CORNER OF LOT 32 (PHASE II) AND LOT 22 (PHASE 1); THE PLACE OF BEGINNING. CONTAINING: 15,321 SQUARE FEET MORE OR LESS. SUBJECT TO ALL COVENANTS AND AGREEMENTS OF RECORD. aicn ( v( rt: ( ? nrn (Page 1 of 6) eLittoin Date: 2/22/2006 Young Ha 1335 Armitage Wy Loan SeWidnT Mechanicsburg, PA 17050 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999 8501 Fax (713) 966-8936 www.littonloan.com Page I of 5 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached oases. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how to program works. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. H you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 14100-342-2397.(Persons with impaired hearing can call (717)780-1869. This Notice contains important legal information. H you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFCACION EN ADJUNTO ES DE SUMA EVIPORTANCIA, PUTS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTD?ICACION OBTENGA UNA TRADUCCION-WMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A (Page 2 of 6) APPENDIX A HOMEOWNER'SNAME(S): Young Ha MAIIdNG ADDRESS: 1335 Armitage Way Mechanicsburg, PA 170506405 PROPERTY ADDRESS: 1335 Armitage Wy Mechanicsburg, PA 17050 LOAN ACCT. NO.: 13986195 ORIGINAL LENDER: CURRENT LENDER/SERVICE: Page 2 of 5 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGHILE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YO MAKE TUBE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELEGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of the Notice. _THIS MEETING MUST OCCUR WITHIN THE NRYT CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addressec_ and telephone numbers of forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the (Page 3 of 6) APPENDIX A Page 3 of 5 end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They Will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to snake a decision after it receives your application During that time, no foreclosure proceedings will be pursed against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Brine it uD to date), NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1335 Armitage WY IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 12/1/2005 through 2/1/2006 at $3,498.64 totaling $10,495.92 Other charges Late Charges $ 488.49 Defend Late Charges $ 325.66 NSF Charges $ 0 Deferred NSF Charges $ 0 Suspense Balance $ (0) Corp. Advance $ 112 TOTAL AMOUNT PAST DUE $10,325.66 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do riot use if not avulicablel: HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $$10,325.66 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by ca& cashier's check certified check or money order made navable and sent to Litton Loan Servicine LP, 4828 Larson Central Dr Houston, TX 77081-2226. You can cure any other default by taking the fallowing action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) (Page 6 of 6) APPENDIX A Page 4 of 5 IF YOU DO NOT CURE THE DEFAULT - If you do act cute the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the mortnaee debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your morteaeed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable cost If you cure the default within the THIRTY (30) DAY period. you will not be reauired to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, You still have EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such as Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. LITTON LOAN SERVICING Address: 4828 Loop Central Dr, Houston, TX 77081 Phone Number: (800)999-8501 or (713) 960-9676 Fax Number. (713) 966-8906 Contact Person: Collection Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to five in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and anomey's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. (Page 5 of 6) APPENDIX A Page 5 of 5 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Apoendix C. FOR THE COUNTY in which the property is located. using additional pages if necessarvl. CumberlandCounty CCCS of Western Pennsylvania. Inc. 2000 Linglestown Road Harrisbure. PA 17102 (717(541-1757 (888)511-2227 Urban League of Metropolitan Harrisbure N. 6th Street Harrisburg. PA 17101 (717)234-5925 FAX(717)234-9459 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro. PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(717)731-9589 (Page 6 of 6) Adams County Housing Authority 139-143 Carlisle St Gettvsbure. PA 17325 (717)334-1518 FAX(717)334-8326 Community Action Comm of the Capital Region 1514 Derry Street Harrisbure.PA 17104 (717)232-9757 FAX(717)234-2227 (Page 1 of 6) Litton Date: 2/22/2006 Young Ha Loan Servicing 1335 Armitage Way Mechanicsburg, PA 170506405 APPENDIX A 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999 8501 Fax (713) 966-8936 www.littonloau.com Page 1 of 5 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default i provided in the attached notes, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how to program works. To see if HEMAP can help You must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITH IN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseline AEencv. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. H you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717)780-1869. This Notice contains important legal information. H you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVTENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTTFICACION OBTENGA UNA TRADUCCION MbIEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO ME14CIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA r.r AMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMD2 SU HIPOTECA. EXHIBIT A (Page 2 of 6) APPENDIX A HOMEOWNER'S NAME(S): Young Ha MAILING ADDRESS: 1335 Armitage Way Mechanicsburg, PA 1705116405 PROPERTY ADDRESS: 1335 Armitage Wy Mechanicsburg, PA 17050 LOAN ACCT. NO.: 13986195 ORIGINAL LENDER: CURRENT LENDERISERVICE: Page 2 of 5 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE UM M MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELEGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of the Notice. THIS MEETING MUST OCCUR WITRiN TRIP. xRxT CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of form at me end of this Nonce. It is ohiy necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE A I TAN E-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the (Page 3 of 6) APPENDIX A Page 3 of 5 end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They Will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application During that time, no foreclosure proceedings will be pursed against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1335 Armitage Wy IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 12/1/2(X)5 through 2/112006 at $3,498.64 totaling $10,495.92 Other charges Late Charges $ 488.49 Deferred Late Charges $ 325.66 NSF Charges $ 0 Deferred NSF Charges $ 0 Suspense Balance $ (0) Corp. Advance $ 112 TOTAL AMOUNT PAST DUE $10,325.66 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $$10,325.66 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made pavable and sent to: Litton Loan Servicing LP, 4828 Loop Central Dr Houston, TX 77081-2226. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable.) (Page 4 of 6) APPENDIX A Page 4 of 5 IF YOU DO NOT CURE THE DEFAULT - if you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the leader intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the tender also intends to instruct its attorneys to start legal action to foreclose upon Your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable cost. If you cure the default within the THIRTY (30) DAY OTHER LENDER REMEDIES - The lender may also sae you personally for the unpaid principal balance and all other sums due under the mortgage. under the mortgage. Curing your default in the manner set forth mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such as Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. LITTON LOAN SERVICING Address: 4828 Loop Central Dr, Houston, TX 77081 Phone Number: (800)999-8501 or (713) 960-9676 Fax Number. (713) 966-8906 Contact Person: Collection Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale (Page 5 of 6) APPENDIX A Page 5 of 5 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C. FOR THE COUNTY in which the property is located. using additional pages if necessary). CumberlandCounty CCCS of Western Pennsvlvania. Inc. 2000 Linglestown Road Harrisburg. PA 17102 (717(541-1757 (888)511-2227 Urban League of Metropolitan Harrisburg N. 6th Street Harrisbu re. PA 17101 (717)234-5925 FAX(717)234-9459 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(717)731-9589 (Page 6 of 6) Adams County Housine Authority 139-143 Cadisle St Gettvsbum, PA 17325 (717)334-1518 FAX(717)334-8326 Community Action Comm of the Cauital Reidon 1514 Dem Street Harrlsbure, PA 17104 (717)232-9757 FAX(717)234-2227 V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. W u 1 Ts , ? Jm n.? W UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY Z.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY SILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Young S. Ha 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 $404,023.10 Interest Per Complaint 7,014.81 From 4/26/06 to 7/21/06 Late charges per Complaint 488.49 From 4/26/06 to 7/21/06 TOTAL I hereby certify that (1) the addresses of the P] Defendant are as shown above, and (2) that notice has be accordance with Rule 237.1, alcopy of which is attached here for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE :1 Jf. i .2 Dn?o stiff and given in SHERIFF'S RETURN - REGULAR CASE NO: 2006-02661 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS HA YOUNG S MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HA YOUNG S the DEFENDANT at 1933:00 HOURS, on the 6th day of June 2006 at 615 HILLTOP DRIVE NEW CUMBERLAND. PA 17070 YOUNG HA by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 47.52 Affidavit .00 00 Surcharge 10.00 R. Thomas Kline .00 75.52 06/07/2006 UDREN LAW OFFICE Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. UDREN LAPP OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Mechanicsburg, Way (Lot 32) PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION ca PLEAS Cumberland County NO. 6L -- ?lolo? COMPLAINT IN MORTGAGE FORECLOSURE N b O 0 c,o 0 ny PIP= pm 23 T c> Um lC?t(j YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 06003 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems Inc. Plaintiff V. Young S. Ha Defendant(s) TO: Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-2661 Civil Term DATE of Notice: June 29, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9106 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A THIS IS AN Y INFORMATION B Q OBTAINED/Dif }t X4LrBE USED FOR THAT PURPOSE. COLLECT A DEBT. AN Woodcrbst Corporate Center 111 Woodcrest oad, Suite 200 Cherry Hill, New rsey 08003-3620 VDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, ; COURT OF COMMON PLEAS Inc. '-CIVIL DIVISION Plaintiff V. Young S. Ha Defendant(s) T0: Young S. Ha 615 Hilltop Drive New Cumberland, PA 17070 DATE of Notice: July 10, 2006 IMPORTANT NOTICE Cumberland County NO. 06-2661 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED BE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION BE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-,9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTO THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED W?BE TUBED FOR THAT PURPOSE. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY SILL, NJ 08003-3620 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers, Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Young S. Ha Over 18 As captioned Unknown Sworn to and subscribed before me this 21st day ?y, 2006. 4r lic STFARS WOU PUBLIC OF NEW JEW cogw6 on Expires 411612MT., itle: ATTORNEY FOR PLAINTIFF ompany: UDREN LAW OFFICES, P.C. 17 o ..? ?- l• r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term TO: Young S. Ha 615 Hilltop Drive New Cumberland, PA 17070 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 A// 1 / Judgment for Possession ?/ 01?1 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, Esauire At this telephone number: 856-669-5400 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 ARK-FAO-Sdnn Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $411,526.40 Interest From July 22, 2006 11,126.94 to Date of Sale December 6, 2006 Ongoing Per Diem of 80.63 to actual date of sale including if sale is held at a later date (Costs to be added) LAW OFFICES, P. •, ?Yv raffia. FOR PLAINTIFF Na Rs Lo w O G ?F t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-2661 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From YOUNG S. HA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $411,526.40 L.L. $.50 Interest FROM 7/22/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $80.63 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $11,126.94 Arty's Comm % Due Prothy $1.00 Arty Paid $157.52 Other Costs Plaintiff Paid Date: JULY 24, 2006 CURTIS R. LONG Prothonottaa? (Seal) By: f//JM a Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 NO. 06-2661 Civil Term Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. CES, F/. C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF r.s m G- -t Cw- t?. r+ - S7 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1335 Armitage Way (Lot 32)Hampden Township Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed owner(s): Name Address Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 615 Hilltop Drive New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Mortgage Electronic PO Box 2026, Flint, MI 48501-2026 Registration Systems, Inc. 5. Name and address of every other person who has any record lien on the property: Name Address Theodore Feisner Address to Follow Anthony Misitano Address to Follow Peter A. Patuzzro Address to Follow Hampden Township Address to Follow Cumberland Township Address to Follow Hampden Station, A Address to Follow Pennsylvania General Partnership Corporation Hampden Township Sewer Address to Follow Authority Verizon Pennsylvania Inc. Address to Follow Hampden Station Phase II Address to Follow 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 Commonwealth of PA, Department of Revenue 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants every other person of whom the plaintiff any interest in the property which may be Address 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 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 mad subject to the penalties of 18 Pa.C.S. sec. 4904 relating o unsworn falsification to authorities. UDREN LAW OFFICES, P.C DATED: July 21, 2006 r7r J. Udren, ESQ. torney for Plaintiff v ?> <-; _ °'' .-, t . T; , 111-= ? ^-.) _G I/ ?ft UDREN LAW OFFICES, P.C. BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 NOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2661 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Your house (real estate) at 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $411,526.40, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (see notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LKWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 .. '„ SHERIFF'S RETURN - REGULAR CASE NO: 2006-02661 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS HA YOUNG S MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HA YOUNG S the DEFENDANT , at 1933:00 HOURS, on the 6th day of June 2006 at 615 HILLTOP DRIVE NEW CUMBERLAND, PA 17070 by handing to YOUNG HA a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 47.52 Affidavit .00 Surcharge 10.00 R. Thomas Kline 75.5--2-/ 06/07/2006 UDREN LAW OFFICE Sworn and Subscibed to By: - - before me this day Deputy Sheriff of A. D. { , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 De f endant (s) -NO. 06-2661 Civil Term AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penal ie 18 a.C.S. Section 4904 relating to unsworn falsification to author t' s. Dated: December 1, 2006 UDRE AW F ICE P. . BY: Mar J. U ren, Esquire Attorney for Plaintiff i ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION 4828 Loop Central Drive Houston, TX 77081 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Young S. Ha NO. 06-2661 Civil Term 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1335 Armitage Way (Lot 32)Hampden Township Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 615 Hilltop Drive New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Mortgage Electronic PO Box 2026, Flint, MI 48501-2026 Registration Systems, Inc. 5. Name and address of every other person who has any record lien on the property: Name Address Theodore Feisner Anthony Misitano Peter A. Patuzro, Jr. Hampden Township Cumberland Township Hampden Station, A Pennsylvania General Partnership Corporation Hampden Township Sewer Authority Verizon Pennsylvania Inc Hampden Station Phase II 4002 Pamay Drive Mechanicsburg, PA 17050 12 Maybelle Court Mechanicsburg, PA 17050 4000 Pamay Drive Mechanicsburg, PA 17050 230 S. Sporting Hill Road Mechanicsburg, PA 17050 1370 Fairfield Road Gettysburg, PA 17325 3815 Market Street Camp Hill, PA 17011 230 S. Sporting Hill, Road Mechanicsburg, PA 18050 1717 Arch Street, 3rd Floor Philadelphia, PA 19103 3815 Market Street Camp Hill, PA 17011 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, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 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 ec. 4904 relating to unsworn falsification to authorities./ OFFICES, P.C. DATED: December 1, 2006 Mark J. Udren, Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic €COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION 4828 Loop Central Drive Houston, TX 77081 -:Cumberland County Plaintiff V. :NO. 06-2661 Civil Term Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) DATE: August 18, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): YOUNG S. HA PROPERTY: 1335 Armitage Way (Lot 32), Hampden Township Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 6, 2006, at 10:00am, in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later 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. EXHISITA _® C6 LL w ..om C6 LL N y O rt.. drill per.. m. ? m LC LL m ? a Ema co a, ? 08 v ?= w c> O y ;m a ? c ? m m a m '- o? 10 ? mDC? s¢ r= O s E °m C y O o° j } m LL gt ? io r e -'- 'G CD a U °7g F.01 r _? w m n O n w p o Ti Z i a Z a H? 2 Q U Q, T f= z t? ; Q c - O q F- J1 O t X I a N w o J O d a= c) 0? a. z 9 W9 Z a b Ua !s 0: U s vio ? r io DO f- V ?J Or ?ID F 0 J z J i U w c wJ D? L`d ?v J m 1-p z =a = M \a d W V? Ud V)2 U. IL Q o t) w LLj M \ q,.W v U, U w Wm U 33 a ui z S 0) z d 0? 2 X W O o? r ZEW- U _ L a 1tWin? » m 0 tj t? e'?C9 d 0?t O? t-tL' U ?tlf d j ?? F?Q y Za 4d Vaaa _0 - v °W K2 U D " Nm m 00 ? W Q= yb u? c UDe°h?wa U? Ha?W vz R, z?a'?Z? ?? } W wm W W W w= 2 Z r z?A m ?i F?: t-?° zzd Z n wN O U o nm Wp? W w1 cnW am - O a m ad.a? N2 as $ _= z m ? WW z C z aU f U U ?K Z?: °- QQ =tit ;a W UL 1 g Uc9v a U q?. in ?5r-tJ Uv n? am M U- a m `m o l o .6 is 0 E ?' to m n Z m Irj y ?- z -Z W a ?? 8 8 Ug = a c LA. w F°- n. Z O r- ON co co n CD rn A -el EXHIBIT A %. Mortgage Electronic Registration Systems, Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Young S. Ha Writ No. 2006-2661 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2006 at 2011 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Young S. Ha, by making known unto Lynn Ha, wife of Young Ha, at 615 Hilltop Drive, New Cumberland, 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 October 12, 2006 at 1047 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Young S. Ha located at 1335 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Young S. Ha, by regular mail to his last known address of 615 Hilltop Drive, New Cumberland, PA 17070. This letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. So? e ??d R. Thomas Kline, Sheriff BY Cti I Real state Sergeant EXHIBIT B p C'7 PLC. ?y °?i Mortgage Electronic, Registration Systems, Inc. Plaintiff VS. YOUNG S. HA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-2661 Civil Term ENTRY OF APPEARANCE AS LOCAL COUNSEL Dear Sir: I hereby enter my appearance as local counsel, in conjunction with Mark J. Udren, Esquire, for the limited purpose of filing a Petition for Postponement of Sheriff's Salmi, Date: January 10, 2007 N V. Wolf S r Court I.D. 87380 Da a F. Shughart, Jr. Supreme Court I.D. 19373 10 West High Street Carlisle, PA 17013 (717) 241-4311 CC: Mark J. Udren, Esquire i n -" ' 'ta ? " t ?:', .- - G7 `-}3 .? y?. ??' e ?- ?,; ( ? 4 UDREN LAW OFFICES, P.G. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Enquire ATTY I.D., NO. 04302 Ill WOODC!REST ROAD, SUITE 200 CHERRY H-.11LL, NJ 08003 856-669-">400 pleadingi?j@udren.com Mortgage:: Electronic "COURT OF CQMON PLEAS Registration Systems, Inc. :CIVIL DIVISION Plaintiff Cumberland County v. Young S. Ha Defendant(s) NO. 06-2661 Civil Term PETITION FOR_PQSTPONEMENT OF SHERIFF'S SALE Pl.-";intiff, by its counsel, Mark J. Udren, Esquire, petitions the Cou:r"t for a two (2) month (s) postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following1. A Sheriff's sale of the mortgaged property involved herein, located at 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 was originally scheduled for December 6, 2006, then postponed to January 10, 2007. 2. The Plaintiff seek-- the postponement of the Sheriff's sale inasmu..:h as Plaintiff awaits review of proof of financing and attendant: loan documentation in connection with the proposed payoff of the mortgaged property 3. A two (2) month(s) postponement, of the Sheriff's sale is necessary to allow Plaintiff to review all said loan information described herein. Y?'HEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the March 7, 20C:7 Sheriff's sale. 4;$- Dal gars, Jr. Esquire Local Counsel Respect f Mark J. U en, Esquire ,Udren Law Offices, P.C. Attorney for Plaintiff 'ON xvi UDREN LAW OFFICES, P.C. BY; Mark J. Udren, Esquire ATTY I.D. NO. 04302 111 WOODCREST ROAD, SUITE 200 CHERRY H.LL, NJ 08003 856-669-5400 pleadingsa@udren. com ATTORNEY FOR PLAINTIFF Mortgage Electronic ;COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION Plaintiff 'Cumberland County V. Young IS. Ha Defendant (s) ` NO. 06--2661 Civil Term PLAINTIFF'S MEMORANDUM OF LAW PeVinsylvania R.C.P. 3129.3(b) allows for one postponement of a Sher f f I s sale. In the present matter, the sale has been previou,>ly postponed. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriffs sale, a tow (2) month postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postpoz,.tement of the sale more than once, and without new notice, by Special Order of Court. Ac.:cordingly, for the reasons hereinabove stated, and as more partic-.zlarly set forth in the Motion, Plaintiff respectfully requests a two (2) month continuance of the Sheriff's Sale of the mortgaged premises located at 1335 Armitage Way (Lot. 32) Hampden Township Mechanicsburg, PA 17050, to the March 7, 2007 Sheriff's sale. Respect ful,i!^,?fbr?iitte ?.. v Y By Dale ::7hu a t, Jr. Esquire Markl J Ud'iexr; Esquire Local ux el UIX?EN LAW?FFICES, P.C. A'T'TORNEY FOR PLAINTIFF b0 'd 'ON o ? - - - -- - - -- - - - - - - - -- Wd MEO ?0? L00?-?n-r?Hr s , VERIFICATION MarR. J. Udren, ESQUIRE, hereby states that he is the Attorney for the ?laint.iff in this action, that he is authorized to take this Ver:if ication, and that the statements made in the foregoing Petition, for Postponement of Sheriff ' s Sale are true and correct to the best of his knowledge, information and beli.ef. ThE2 underaigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unswcrn falsif i?:..-ation to authorities. Date : t1a;PaW 9, 2007 , Jr. Esquire fff Da14' SI-s. Local 1>ou0 1 Mar?;7! Ud?, ESQUIRE LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF so Id 'ON, AWHj Wd t0 60 Ifli aoO -60-NHr UDREN LAW OFFICES, P . C - BY: Mark: J. Udren, Esquire ATTY I.D. NO. 04302 III WOODc::'REST ROAD, SUITE 200 CHERRY H::?: LL , NJ 0 8 0 0 3 856-669-1:5400 pleadinga@udren. coin ATTORNEY FOR PLAINTIFF Mortgage: Electronic COURT OF COMMON PLEAS Regiatr,:Ition Systems, Inc. :CIVIL DIVISION Plaintiff :Cumberland County v. Young ?? . Ha Defendant (s) 1,10. 06-2661 Civil. Term CERTIFICATE OF SERVICE 1, Mark J. Udren, ESQUIRE, hereby certify that I have served true and correct copies of the attached petition for postponement of Sheriff's sale upon the following person(s) named herein at their lest known address or their attorney of record by. xxxx Regular First Class Mail Certified Mail Other Date Served: January 9, 2007 TO : Y{ rung S. Ha 1::;35 Armitage Way (Lot 32) and 615 Hilltop Drive Mechanicsburg, PA 17050 New Cumberland, PA 17070 UOREN LAW P.C. Dale ::h =44, Jr. Esquire Ma)Lx9r,?d . Ud?n, Esquire Loco o t rney for Plaintiff 90 'ON xvi -- fed ME0 3a / nn?.-nn-mpr f'? r•' o p -? .-, .r- t, ?'a -=?: -' -v :?? T ?. ?=. ? ? tT't G ?...-{. taJ :I 3 N ? pro 2om?r ],-.N THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL DTVTSTON Mortgage Electronic Registr4s!tion Systems, Inc:. 4$2$ Loc?p Central Drive Houston,. TX 77081 NO. 06-2561 Civil Term Plaintiff Young S. Ha 1335 Armitage Gray (Lot 32) Mechanicsburg, PA 17050 Defendant (s) 0 R D E R ANK) NOW, this 10 A day of January, 2007, after cons ide-.ration of Plaintiff ` ti Petition fax Postponement of Sheriff I s Sale of the mortgaged property located at 1335 Armitage- Way (Lot 32)14ampden Township Mechanicsburg, PA 17050, it is hereby ORDERED that tI,e said Sale currently scheduled far January 10, 2007, is extended t,wo (2) Month(s) to the regularly scheduled Cumberland County Sheriff' ° Sale scheduled for March. 7, 2007. No ft.rther adverw i since gat: addit,Aonal n.otj.ce to lienholders or Defendant ;g) is required. Y J. ON x ? w c (i : Y 1? x(11 ? nna_en Ri:_r, ? f yF?? Aj,'+ jNN3d p?fi ?ha a 1:6 WV 01 Or LODZ AUVlONv'HiOdd 3Nl 30 3oj-U, iU Mortgage Electronic Registration Systems, Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Young S. Ha Writ No. 2006-2661 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2006 at 2011 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Young S. Ha, by making known unto Lynn Ha, wife of Young Ha, at 615 Hilltop Drive, New Cumberland, 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 October 12, 2006 at 1047 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Young S. Ha located at 1335 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Young S. Ha, by regular mail to his last known address of 615 Hilltop Drive, New Cumberland, PA 17070. This letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Mark J. Udren. Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Certified Mail Mileage Levy Surcharge Law Journal Patriot News Share of Bills Postpone Sale So Ans rs: ' R. Thomas Kline, Sheriff BY `o Real Estate Sergeant 30.00 5,757.35 15.00 15.00 .50 1.00 4.92 23.76 15.00 20.00 449.00 367.58 15.94 20.00 $6735.05 V #11 1 3)6-7 4 6 k- s -p.zo z. /r//Y35 • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION 4828 Loop Central Drive Houston, TX 77081 Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Young S. Ha :NO. 06-2661 Civil Term 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Def endant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1335 Armitage Way (Lot 32)Hampden Township Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Young S. Ha 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 615 Hilltop Drive New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None V 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Mortgage Electronic PO Box 2026, Flint, MI 48501-2026 Registration Systems, Inc. 5. Name and address of every other person who has any record lien on the property: Name Address Theodore Feisner Anthony Misitano Peter A. Patuzzro Hampden Township Cumberland Township Address to Follow Address to Follow Address to Follow Address to Follow Address to Follow Hampden Station, A Pennsylvania General Partnership Corporation Hampden Township Sewer Authority Verizon Pennsylvania Inc. Hampden Station Phase II Address to Follow Address to Follow Address to Follow Address to Follow 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 Commonwealth of PA, Department of Revenue 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 P 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 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C DATED: July 21, 2006 ar?t'J. Udren, ESQ. ttorney for Plaintiff L F .E d 01 MY 9Q61 LEGAL DESCRIPTION ALL THAT CERTAIN PARCEL OF LAND LOCATED IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, BEING SHOWN AND DESIGNATED AS LOT 32 ON A PLAN ENTITLED "FINAL SUBDIVISION PLAN-PHASE H FOR HAMPDEN STATION", BY DAWOOD ENGINEERING, INC., PLAN DATED MARCH 20, 2002 AND LAST REVISED April 29, 2002. t j SAID PARCEL BEING MORE FUMY DESCRIBED AS FOLLOWS: BEGINNING AT A 5/8" REBAR SET, SAID REBAR BEING ON THE LINE OF LOTS 22 (PHASE I) AND 32 (PHASE 1) WHERE SAID LINE INTERSECTS WITH THE SOUTHERN RIGHT-OF-WAY LINE OF ARMITAGE WAY (50' RIGHT-OF-WAY); THENCE ALONG LOT 22 (PHASE 1), THE FOLLOWING TWO COURSES AND DISTANCES: 1. SOUTH 40 DEGREES 05 MINUTES 54 SECONDS WEST, A DISTANCE OF 132.68 FEET TO A 5/8" REBAR SET; 2. SOUTH 10 DEGREES 02 MINUTES 14 SECONDS WEST, A DISTANCE OF 10.00 FEET TO A 5/8" REBAR SET AT THE REAR CORNER OF LOTS 31 AND 32 (PHASE II); THENCE ALONG LOT 31, NORTH 79 DEGREES 57 MINUTES 46 SECONDS WEST, A DISTANCE OF 110.00 FEET TO A 5/8" REBAR SET ON THE EASTERN RIGHT-OF-WAY LINE OF ARMITAGE WAY; THENCE ALONG SAID RIGHT-OF-WAY LINE, THE FOLLOWING THREE COURSES AND DISTANCES: 1. NORTH 10 DEGREES 02 MINUTES 14 SECONDS EAST, A DISTANCE OF 7.06 FEET TO A 5/8" REBAR SET; 2. ALONG A CURVE TO THE RIGHT, HAVING A RADIUS OF 125.00 FEET, AN ARC LENGTH OF 218.52 FEET, AND A CHORD BEARING AND DISTANCE OF NORTH 60 DEGREES 07 MINUTES 04 SECONDS EAST, 191.74 FEET TO A 5/8" REBAR SET; 3. SOUTH 69 DEGREES 48 MINUTES 07 SECONDS EAST, A DISTANCE OF 29.88 FEET TO A 5/8" REBAR SET ON THE FRONT LOT CORNER OF LOT 32 (PHASE II) AND LOT 22 (PHASE 1); THE PLACE OF BEGINNING. CONTAINING: 15,321 SQUARE FEET MORE OR LESS. SUBJECT TO ALL COVENANTS AND AGREEMENTS OF RECORD. BEING KNOWN AS: 1335 Armitage Way (Lot 32) Hampden Township Mechanicsburg, PA 17050 PROPERTY ID NO.: 10-15-1285-214 TITLE TO SAID PREMISES IS VESTED IN YOUNG S. HA, MARRIED MAN BY DEED FROM CHATEAU CUSTOM HOME BUILDERS, INC., A PENNSYLVANIA CORPORATION DATED 12/27/04 RECORDED 12/29/04 IN DEED BOOK 266 PAGE 4533. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic -:COURT OF COMMON PLEAS Registration Systems, Inc. €CIVIL DIVISION 4828 Loop Central Drive Houston, TX 77081 :Cumberland County Plaintiff V. ;MORTGAGE FORECLOSURE Young S. Ha :NO. 06-2661 Civil Term 1335 Armitage Way (Lot 32) Mechanicsburg, PA 17050 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Young S. Ha 615 Hilltop Drive New Cumberland, PA 17070 Your house (real estate) at 1335 Armitage Way (Lot 32)Hampden Township Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on December 6, 2006, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $411,526.40, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2661 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From YOUNG S. HA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $411,526.40 L.L. $.50 Interest FROM 7/22/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $80.63 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $11,126.94 Atty's Comm % Due Prothy $1.00 Atty Paid $157.52 Other Costs Plaintiff Paid Date: JULY 24, 2006 CURTIS R. LONG Prothonota (Seal) 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 # 57 On September 8, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Eno ? Known and numbered as 1335 Armitage Way, Mechanicsburg, more fully described on Exhibit "A" 0 filed with this writ and by this reference incorporated herein. Date: September 8, 2006 By. J 0 S,,? Real Estate Sergeant L d 0 19fid 9QQl ?I??NS ANI j o 3?1 ??w r - ? THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of October and the 1st and 8th day(s) of November 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION f ?MIJr? ??MI? Vo. = !fo lilt i? 28 IZ ? L-rradrw SW 00d >?e hk a®eie?,a : Ulm l?iitY le Sm C(Uk zsa2?2 OW '4 . tiwf? ad 32 ^w tl lba mid fii? Won" ?* &e mob= WYX *9W *4 t* U (mac lk the hft1ft1-gftWu1 #Wwm *SM 0 *WOO N "MM AK ewe Of JUSIM WtIr NO& at 2. %0'0! de?? ? wYrr? 14 ? wit. rin?re' ................... ?. ............................... Sworn to and subs 'b b re me this 15th day of ????? C0MM0NWEALNN9b NSYL A Notarial Seal Terry L. Russell, Notary Public City of Harrisburg, Dauphin County My Commis 'on Expires ne 6, 2010 Member, Penn vlvania A . ' tion of Notaries NOTARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 20, October 27 and November 3, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 57 Writ No. 2006-2661 Civil Mortgage Electronic Registration Systems, Inc. VS. Young S. Ha Atty.: Mark Udren LEGAL DESCRIPTION ALL THAT CERTAIN parcel of land located in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, being shown and designated as Lot 32 on a plan entitled "Final Subdivi- sion Plan-Phase II for Hampden Sta- tion", by Dawood Engineering, Inc., plan dated March 20, 2002 and last revised April 29, 2002. SAID PARCEL BEING MORE FIT[ i:v T)F?,t`RTRED AS FOLLOWS_ sa arie Coyne, Edi or SWORN TO AND SUBSCRIBED before me this 3 day of November, 2006 NO AIIIAL SEAL V LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009