Loading...
HomeMy WebLinkAbout06-2697 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF .com Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Darlene F. Tritt 903 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) NO.6t, --?" ?IU?I I 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 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 provisioner 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty 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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Washington Mutual Bank, FA Recording Date: LODGED FOR RECORDING 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 903 West Trindle Road MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township) COUNTY: Cumberland DATE EXECUTED: 10/24/05 DATE RECORDED: 11/9/05 BOOK: 1930 PAGE: 2257 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 5/2/06: Principal of debt due $220,000.00 Unpaid Interest at 6.875% from 12/1/05 to 5/2/06 (the per diem interest accruing on this debt is $41.44 and that sum should be added each day after 5/2/06) 6,343.54 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of 563.02 should be added in accordance with the terms of the note each month after 5/2/06) 126.04 Attorneys Fees (anticipated and actual to 5% of principal) 11,000.00 TOTAL $238,074.58 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 $238,074.58 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF MONROE, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY MADE ON NOVEMBER 16, 1961, BY W.G. RECHEL, REGISTERED SURVEYOR, AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE TRINDLE ROAD LEADING FROM MECHANICSBURG TO CARLISLE AT CORNER OF OTHER LANDS NOW OR FORMERLY OF J. MERLE AND GENEVIEVE L. CLEPPER, SAID POINT BEING SOUTH SEVENTY (70) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED FOUR (104.00) FEET FROM THE POINT OF INTERSECTION OF THE CENTER LINES OF THE TRINDLE ROAD AFORESAID AND ANOTHER PUBLIC ROAD KNOWN AS THE WILLIAMS GROVE ROAD AND ALSO KNOWN AS SINCLAIR ROAD; THENCE ALONG THE LINE OF OTHER LANDS OF CLEPPERS, SOUTH EIGHT (08) DEGREES THIRTY (30) MINUTES EAST, TWO HUNDRED FIFTY- THREE AND FIFTY-SIX ONE-HUNDREDTHS (253.56) FEET TO A STAKE AT THE LINE OF LANDS NOW OR FORMERLY OF PAUL E. WALLACE; THENCE ALONG THE LINE OF LANDS NOW OR FORMERLY OF THE SAID PAUL E. WALLACE, SOUTH SEVENTY (70) DEGREES FIFTEEN (15) MINUTES WEST, ONE HUNDRED (100.00) FEET TO A PIPE AT LINE OF LANDS NOW OR FORMERLY OF R.F. EAKIN; THENCE ALONG THE LINE OF LANDS NOW OR FORMERLY OF THE SADI R.F. EAKIN, NORTH EIGHT (08) DEGREES THIRTY (30) MINUTES WEST, TWO HUNDRED FIFTY-FOUR (254.00) FEET TO A POINT IN THE TRINDLE ROAD AFORESAID; THENCE ALONG A LINE IN THE SAID TRINDLE ROAD, NORTH SEVENTY (70) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100.00) FEET TO A POINT, THE PLACE OF BEGINNING. i HAVING THEREON ERECTED A SINGLE FAMILY DWELLJNG. i Washington Mutual Mailstop JAXB2004 P.O. Box 44090 Jacksonville, FL 32231-4090 March 30, 2006 #BWNCLNN# #0953039279985498# DARLENE TRITT 903 W TRINDLE RD MECHANICSBURG PA 95037 000793 /PA 5303279854 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT# 5303279854 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency my 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTDQUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA ACT 91 M11317-,t HOMEOWNER'S NAME(S): Darlene Tritt PROPERTY ADDRESS: 903W Trindle Rd Mechanicsburg PA 95037 LOAN ACCT. NUMBER: 5303279654 ORIGINAL LENDER: Jax CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1963 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURF - 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 most arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 1301 DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE. ASSISTANCE YOU MUST RRING YOUR MORTGAGE OF TO DATE. THE PART OF THIS NOTICE CA TIED HOW TO CUR YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. 'S1M FR CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies 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 . dd saes. and r_le hone numbers of de ignat d credit counseling agcnciag for the county in which the pylwnyis located a t forth at the consumer end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender imm?diately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - 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 most fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU 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 pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 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.) 0007931co826 HOW TO CURE YOUR MORTGAGE DEFALII T Bring it uR to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 903W Trindle Rd Mechanicsburg PA 95037 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 01/012006 $1260.42 02/012006 $1260.42 03/012006 $1260.42 Other charges (explain/itemim): Uncollected Late Charges $63.02 Uncollected Fees: $000 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $3844.28 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (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 $3844.28, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa= n c must made either b ach cashier's check- certified check- or money order d payable and sent to- Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee, WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): 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 tender intends to x - it, rights tg accelerate the manage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the 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 mortg290LIZI oRMIL *IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to payoff 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 fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable atumery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. H ynn eure the default within the THIRTY Ptnl DAY period, You will not he required to attorney's fees. pay OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA AC[ 91 RIGHT TO CARE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY and foreclosure proceedings have begun, you mU still have the right to cure the d fanlt and prevent the sale at any time up to one restore your mortgage to the same position as if you had never Curing your default in the manner set forth in this notice PART JEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by comacting the lender. Name of Lender: Washington Mutual Bank Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926.8937 Fax Number: 904-281.3914 Contact Person: Collection Department Email Address: wwwmamuhomeloans.com EFFECTS OF SHERIFF'S SALE, - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or ,$ may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE 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 ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACC 91 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. ?` . Z) - 4-u ~ rr r : ? , . c ?,,, rs C? a Vi=i [? N 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Darlene F. Tritt :NO. 06-2697 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE : June `?O, 2006 ICES, P. C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAI J FF c^+ - - CD .-.,.t UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA Plaintiff V. Darlene F. Tritt Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County €NO. 06-2697 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the abovl-captioned matter. DATE: July 21, 2006 CE), P.C. UDREN LA4 lofff Mark J. Udren, ESQUIRE 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 pleadings@udren.com Washington Mutual Bank, FA :COURT 1270 Northland Drive :CIVIL Suite 200 ATTORNEY FOR PLAINTIFF OF COMMON PLEAS DIVISION Mendota Heights, MN 55120 ;Cumberland County Plaintiff v. Darlene F. Tritt 903 West Trindle Road Mechanicsburg, PA 17055 De f endant (s) NO. COMPLAINT IN MORTGAGE FORECLOSURE C ° C3 Ml- YOU a ? rr3 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 ? r-?.? ?- : ,-' _? - ,_. , _, _.._ "'•` --= i-'a ?. _ . .. -i _ 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 Washington Mutual Bank, FA Plaintiff V. Darlene F. Tritt Defendant(s) ATTORNEY FOR PLAINTIFF ;COURT OF COMMON PLEAS CIVIL DIVISION ;Cumberland County NO. 06-2697 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. UDREN LAW OFFICES, P.C. DATED: September 1, 2006 BY: J. Udren, Esquire ney for Plaintiff l ? . a V E R I F I C A T I O N 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: 2D©G N e: Title : M VI" Pr" M Company: Wa:(,,.ul ? OW ,t &,tt F4 Darlene F. Tritt Loan #5303279854 MJU #06050079 Q min ?lY} y. m 3 ? ? *r4 SastaleaA 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff :MORTGAGE FORECLOSURE V. Darlene F. Tritt ENO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 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) Darlene F. Tritt 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 $238,074.58 Interest Per Complaint 5,055.68 From 5/3/06 to 9/1/06 Late charges per Complaint 252.08 From 5/3/06 to 9/1/06 TOTAL $243,382.34 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 cgpy of which is attached hereto. FILES DAMAGES ARE HEREBY ASSESSED AS DATE : Ma K V judreN9 KESQUIRE At orney for Plaintiff NDICATED PRO PR HY - a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Washington Mutual Bank, FA ;COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 Mendota Heights, MN 55120 :Cumberland County Plaintiff V. Darlene F. Tritt `` pry 903 West Trindle Road € NO. Mechanicsburg, PA 17055 De f endant (s) COMPLAINT IN MORTGAGE FORECLOSURE n.:t -•c 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 SHERIFF'S RETURN - REGULAR w CASE NO: 2006-02697 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS TRITT DARLENE F KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRITT DARLENE F the DEFENDANT , at 1929:00 HOURS, on the 27th day of July 2006 at 101 LONGWOOD DRIVE MECHANICSBURG, PA 17055 by handing to DARLENE TRITT 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 .00 Service .00 Affidavit .00 Surcharge .00 Sworn and Subscibed to before me this day of , So Answer R. Thomas Kline 07/28/2006 UDREN LAW OFFICE By: A. D. 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 856-669-5400 Washington Mutual Bank, FA COURT OF COMMON PLEAS Plaintiff -;CIVIL DIVISION E Cumberland County V. Darlene F. Tritt Defendant (s) ::NO. 06-2697 TO: Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 DATE of Notice: August 21, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED USED FOR THAT PURPOSE. ss a squire 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 HILL, NJ 08003-3620 856-482-6900 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff V. Darlene F. Tritt 903 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2697 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF ?1?kH?s COUNTY OF 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: Darlene F. Tritt Age: Over 18 Residence: As captioned above Employment: Unknown Sworn to and subscribed Ury me this "3( dayy yl. .7 2 09 . QJ?? Pubi 10 ?. PARIS Y. JACKSON NOTARY PUBLIC • MINNESOTA MY COMMISSION EKPIRES JAN. 31, 2011 Vice President 01'4--.( &., Fit N 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 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff V. Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-2697 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $243,382.34 Interest From September 2, 2006 7,749.28 to Date of Sale March 7, 2007 Ongoing Per Diem of 41.44 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. Wark W. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ?r f OV) s? e °o ?J 41Q ? C c t ? a 1 1 "r 1 1 ti 1 w c ? Y, 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 :MORTGAGE FORECLOSURE Plaintiff V. Darlene F. Tritt :NO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 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. .? OFFICW, PAC. rk J. Udren, ESQUIRE TORNEY FOR PLAINTIFF s^-? ?> _ } c>> . ? f,Fs -r -. a" ?, ..__ ?j?. ' i'= -- _. G? - .. ,. ;. _, t , i ?. °J?1 ffl? 'ft 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 ::Cumberland County Mendota Heights, MN 55120 :MORTGAGE FORECLOSURE Plaintiff V. Darlene F. Tritt ::NO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, 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: 903 West Trindle Road(Monroe Township)Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 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 ,?f record: Name Plaintiff herein. First Magnus Corporation, Corporation Financial An Arizona 5. Name and address of on the property: Name None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 903 West Trindle Road (Monroe Township) Mechanicsburg, PA 17055 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. T UDREN LAW OFFICES,/P.C. DATED: September 1, 2006 the last recorded holder of every mortgage Address See Caption above. 603 North Wilmot Road Tucson, AZ 85711 every other person who has any record lien Address Mark J. Udren, ESQ. Attorney for Plaintiff `.. u T1 - `..... ??d UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ' B70: 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff :MORTGAGE FORECLOSURE V. Darlene F. Tritt :NO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 Your house (real estate) at 903 West Trindle Road(Monroe Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $243,382.34, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 'YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 r°'? ?a t-- ?? ?? '' ,` G'+ 7l "`-? ,...? T,...., i 1 -,_ C? .. _,s?? ?j ._' `-'? =?-J ---J -- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2697 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA Plaintiff (s) From DARLENE F. TRITT (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 $243,382.34 L.L. $.50 Interest FROM 9/2/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $41.44 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $7,749.28 Atty's Comm % Atty Paid $197.40 Plaintiff Paid Due Prothy $1.00 Other Costs Date: SEPTEMBER 11, 2006 (Seal) C is R. Lo , ro onotary 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 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-02697 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS TRITT DARLENE F R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TRITT DARLENE F but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 903 WEST TRINDLE ROAD MECHANICSBURG, PA 17055 903 WEST TRINDLE ROAD IS VACANT. TRITT DARLENE F NOT FOUND , as to Sheriff's Costs: So answers: ?,- :!_ Docketing 18.00 Service 8.80 Affidavit .00 R. Thomas K `ne Surcharge 10.00 Sheriff of Cumberland County .00 3 6 . 8 0 UDREN LAW OFFICE 05/15/2006 Sworn and subscribed to before me this day of A. D. Prothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-102697 P COMMONTWEALTH OF PENNSYLVANIA 'COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS TRITT DARLENE F R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TRITT DARLENE F but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT , TRITT DARLENE F 903 WEST TRINDLE ROAD NOT FOUND , as to MECHANICSBURG, PA 17055 903 WEST TRINDLE ROAD IS VACANT. Sheriff's Costs: So answers: Docketing 18.00 Service 8.80 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.80 UDREN LAW OFFICE n ) -7 ,GL 06/27/2006 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02697 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS TRITT DARLENE F KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ----- TIT TIT ?TTTI T, the DEFENDANT , at 1929:00 HOURS, on the 27th day of July , 2006 at 101 LONGWOOD DRIVE MECHANICSBURG, PA 17055 by handing to DARLENE TRITT 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 .00 Service .00 Affidavit .00 So Answer Surcharge .00 R. Thomas Kline .00 / .00 07/28/2006 9 ?4 Uc?? UDREN LAW OFFICE Sworn and Subscibed to By: before me this day of A.D. 7 SHERIFF'S RETURN - REGULAR CASE NO: 2006-02697 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS TRITT DARLENE F KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRTTT DART,FNF; F the DEFENDANT , at 1904:00 HOURS, on the 23rd day of August , 2006 at 101 LONGWOOD DRIVE MECHANICSBURG, PA 17055 DARLENE TRITT 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 .00 //. Service .00 Affidavit .00 -"9 Surcharge .00 R. Thomas Kline .00 .00! 08/24/2006 06 L)- UDREN LAW OFFICE Sworn and Subscibed to By: before me this day of A.D. 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff V. Darlene F. Tritt 101 Longwood Drive :NO. 06-2697 Mechanicsburg, PA 17055 Defendant(s) 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 subjec to the penalt' s of 1Pa.C.S. Section 4904 relating to unsworn falsifica on to autho t eX-) Dated: March 1, 2007 UDRE#/LAW/OFtICES, P.C. BY: Mar J. Udr n, 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff ENO. 06-2697 v. Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 Def endant (s) DATE: September 1, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Darlene F. Tritt PROPERTY: 903 West Trindle Road(Monroe Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 7, 2007, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. W! EXHIBIT A E M =m U. vEn. a wc?o m? xQ?? ao 35 w qyC? ? W N 0) ?" p 7y C ? w o ? v? Q o°'.dd o ? U W Y 30ViSOd *s,n a c r t ?? OS' c ? a d 'O C m E 0 4 co 0 4) C713? a eo QN m co 4? M W T 2 Z o Fw- a Z N o rU? V a ~vi1 ?a N ? N Q c w Oa a co JQ U p; pO C ?aW N O p '? T o ?V wo =) ) ui tI LL, a LLO cc' ?i ; co C H p V w- = E 00 g iu ? h-?? 3 poi ? v v w w? ? z? ?40 oM ?v0it m ogci ?-? ?w ?zd ?? wo$W z mir wW oN ?` ..? ?? ?oC x o o z w? D to tL tD F- ? ?i OC U U o? ?` rn m $ o [] Z 2z V c v E 4 z w O ? r b N Za0 l[) C N M Co tD ?' O 1 r L ?'Jf. .. 11-1-2-L Is. a?? a co .g D ??E?• C w E Pl m BES Oil 3 42.1 C a C O Ck. m V O x a .m. m CL 0 v a LL 90.S-1?0 ` z M r 2 Q LL ov ti M N O E U Ww - ,EXKiBIT A Washington Mutual Bank, FA In the Court of Common Pleas of VS Cumberland County, Pennsylvania Darlene R. Tritt Writ No. 2006-2697 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2007 at 2009 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: Darlene R. Tritt, by making known unto Darlene R. Tritt personally, at 101 Longwood Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 2027 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 Darlene R. Tritt located at 101 Longwood Drive, 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: Darlene R. Tritt, by regular mail to her last known address of 101 Longwood Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of January 12, 2007 and never returned to the Sheriffs Office. So Ans ers: R. Thomas Kline, Sheriff BY U C Real Estate eputy EXHIBIT 8 " -? ?, ? a ? ?? :?7 r. , "Y'? r t? ? ? Y t - ? ?y "S'J?' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Washington Mut%&O Bank F A is the grantee the same having been sold to said grantee on the 4th day of April A.D., 2007, under and by virtue of a writ Execution issued on the 11th day of Sept, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 2697, at the suit of Washington Mutual Bank F A against Darlene F Tritt is duly recorded in Deed Book No. 280, Page 2829. IN TESTIMONY WHEREOF, I have hereunto set my hand an eal of said office this 7 ^ day of t? A.D. ,Recorder of Deeds Cw "ewW CW1%C *K PA *U #* Fist MW4@y a AWL 20M Washington Mutual Bank, FA In the Court of Common Pleas of VS Cumberland County, Pennsylvania Darlene R. Tritt Writ No. 2006-2697 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2007 at 2009 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: Darlene R. Tritt, by making known unto Darlene R. Tritt personally, at 101 Longwood Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 2027 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 Darlene R. Tritt located at 101 Longwood Drive, 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: Darlene R. Tritt, by regular mail to her last known address of 101 Longwood Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of January 12, 2007 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 April 4, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Washington Mutual Bank, F.A. It being the highest bid and best price received for the same, Washington Mutual Bank, F.A., of 7577 Baybarry Road, Jacksonville, FL 32256, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1069.51. Sheriffs Costs: Docketing $30.00 Poundage 20.97 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 15.84 Certified Mail 9.28 Levy 15.00 Surcharge 20.00 Post Pone Sale 20.00 Law Journal 389.00 Patriot News 378.59 Share of Bills 16.83 Distribution of Proceeds 25.00 Sheriff s Deed 39.50 $ 1069.51 ? 41 ? ?'? So Answers: R. Thomas Kline, Sheriff BY Q off' ? w CkC 5 €9l? P l,7g5l?i ft 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 :MORTGAGE FORECLOSURE Plaintiff V. Darlene F. Tritt ":NO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, 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: 903 West Trindle Road(Monroe Township)Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 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. First Magnus Financial Corporation, An Arizona Corporation See Caption above. 603 North Wilmot Road Tucson, AZ 85711 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 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 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 903 West Trindle Road (Monroe Township) Mechanicsburg, PA 17055 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. J UDREN LAW OFFICES,/P.C. DATED: September 1, 2006 Mark J. Udren, ESQ. 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 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff :MORTGAGE FORECLOSURE V. Darlene F. Tritt :NO. 06-2697 101 Longwood Drive Mechanicsburg, PA 17055 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 Your house (real estate) at 903 West Trindle Road(Monroe Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $243,382.34, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE: YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 J ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF MONROE, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY MADE ON NOVEMBER 16, 1961, BY W.G. RECHEL, REGISTERED SURVEYOR, AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE TRINDLE ROAD LEADING FROM MECHANICSBURG TO CARLISLE AT CORNER OF OTHER LANDS NOW OR FORMERLY OF J. MERLE AND GENEVIEVE L. CLEPPER, SAID POINT BEING SOUTH SEVENTY (70) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED FOUR (104.00) FEET FROM THE POINT OF INTERSECTION OF THE CENTER LINES OF THE TRINDLE ROAD AFORESAID AND ANOTHER PUBLIC ROAD KNOWN AS THE WILLIAMS GROVE ROAD AND ALSO KNOWN AS SINCLAIR ROAD; THENCE ALONG THE LINE OF OTHER LANDS OF CLEPPERS, SOUTH EIGHT (08) DEGREES THIRTY (30) MINUTES EAST, TWO HUNDRED FIFTY- THREE AND FIFTY-SIX ONE-HUNDREDTHS (253.56) FEET TO A STAKE AT THE LINE OF LANDS NOW OR FORMERLY OF PAUL E. WALLACE; THENCE ALONG THE LINE OF LANDS NOW OR FORMERLY OF THE SAID PAUL E. WALLACE, SOUTH SEVENTY (70) DEGREES FIFTEEN (15) MINUTES WEST, ONE HUNDRED (100.00) FEET TO A PIPE AT LINE OF LANDS NOW OR FORMERLY OF R.F. EAKIN; THENCE ALONG THE LINE OF LANDS NOW OR FORMERLY OF THE SADI R.F. EAKIN, NORTH EIGHT (08) DEGREES THIRTY (30) MINUTES WEST, TWO HUNDRED FIFTY-FOUR (254.00) FEET TO A POINT IN THE TRINDLE ROAD AFORESAID; THENCE ALONG A LINE IN THE SAID TRINDLE ROAD, NORTH SEVENTY (70) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100.00) FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A SINGLE FAMILY DWELLING. BEING KNOWN AS: 903 West Trindle Road (Monroe Township) Mechanicsburg, PA 17055 PROPERTY ID NO.: 22-24-0783-015 TITLE TO SAID PREMISES IS VESTED IN DARLENE F. TRITT BY DEED FROM JIMMY R. HAMILTON, SINGLE MAN DATED 10/24/05 RECORDED 11/09/05 IN DEED BOOK 271 PAGE 4459. WRIT OF EXECUTION and/or ATTACHMENT 4 COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2697 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA Plaintiff (s) From DARLENE F. TRITT (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 $243,382.34 L.L. $.50 Interest FROM 9/2/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $41.44 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $7,749.28 Atty's Comm % Atty Paid $197.40 Plaintiff Paid Due Prothy $1.00 Other Costs Date: SEPTEMBER 11, 2006 (Seal) Curtis . Long, o otary 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 # 09 On October 31, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as 903 West Trindle Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 31, 2006 By: NOD \Jcc+, ? ?Pvuf(, Real Estate Sergeant Dam h :b b' 8 d3S 9001 a ,'jj(j. . ? r ' ud . 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 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION .................... ............................ COPY Sworn to and su cr 136re me this 26th day of February 2007 A.D. SALE #9 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, in County My comm'ion Exp' June 6, 2010 NOXAR CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 1 feet b L at Olt; koodJl B ?dl kw4il b Not of ? eow a 64d=;LIif OZOR) Ole uw L?Nrly bt ?n soil wmw (w4to w :soon ow, "Mo"dwasaft lio #b a-lw?firll l W a two 1? IV, dobom lp go* Nm4 *A* dog do PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE 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: January 26, February 2 and February 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing ,tatements as to time, place and character of publication are true. Marie SWORN TO AND SUBSCRIBED before me this 9 day of NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 RrAL EiTATE SALE NO. 9 Writ No. 2006-2697 Civil Washington Mutual Bank, FA VS. Darlene R. Tritt Atty.: Mark Udren ALL THAT CERTAIN piece or par- cel of land situate in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylva- nia, bounded and described in ac- cordance with a survey made on No- vember 16. 1961, by W.G. Rechel, Registered Surveyor, as follows, to wit: BEGINNING at a point in the Trindle Road leading from Mechan- icsburg to Carlisle at corner of other lands now or formerly of J. Merle and Genevieve L. Clepper, said point being South seventy (70) degrees thirty (30) minutes West, one hun- dred four (104.00) feet from the point of intersection of the center lines of the Trindle Road aforesaid and another public road known as the Williams Grove Road and also known as Sinclair Road; thence along the line of other lands of Cleppers, South eight (08) degrees thirty (30) minutes East, two hun- dred fifty-three and fifty-six one- hundredths (253.56) feet to a stake at the line of lands now or formerly of Paul E. Wallace; thence along the line of lands now or formerly of the said Paul E. Wallace, South seventy (70) degrees fifteen (15) minutes west, one hundred (100.00) feet to a pipe at line of lands now or for- merly of R.F. Eakin: thence along the line of lands now or formerly of the said R.F. Eakin, North cjgbt_LWW degrees thirty (30) minutes West, two hundred fifty-four (254.00) feet to a point in the Trindle Road afore- said; theme along a line in the said Trindle Road, North seventy (70) degrees thirty (30) minutes East, one hundred (100.00) feet to a point, the place of beginning. HAVING thereon erected a single family dwelling. BEING KNOWN AS: 903 West Trindle Road (Monroe Township), Mechanicsburg, PA 17055. PROPERTY ID NO.: 22-24-0783- 015. TITLE TO SAID PREMISES IS vESTED IN Darlene F. Tritt by deed from Jimmy R. Hamilton, single man dated 10/24/05 recorded 11/09/ 05 in Deed Book 271 Page 4459. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCRSST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA :COURT OF COMMON PLEAS 1270 Northland Drive =CIVIL DIVISION Suite 200 :Cumberland County Mendota Heights, MN 55120 Plaintiff `•NO. 06-2697 v. Darlene F. Tritt 101 Longwood Drive Mechanicsburg, PA 17055 De f endant (s ) PRASCIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter WITHDRAWN, upon payment of your costs only. 2 0 ~~ -cs 7~ c'~ =~ N ~~ --~ -<; ~., --sue ~: 2 ~=, tdi,9. 1 Attorney for Plaintiff DATED: August 24, 2012 Elena B. Fkhinger, Esq PA ID 209197 06050079-1 ~R~ a~N~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA COURT OF COMMON PLEAS 1270 Northland Drive CIVIL DIVISION ~: Suite 200 Cumberland County Z5 L'-` Mendota Heights, MN 55120 rnca Plaintiff Plaintiff - 1- NO. 06-2697 tnr- -- Darlene F. Tritt -v '. 101 Longwood Drive = Mechanicsburg, PA 17055 :" - �`'1- Defendant (s) - I PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. I All AMP( Att•' ey 1.4r Pia ' . tiff HARRY B. REESE, ' QUIRE DATED: October 7th 2013 PA ID 310.01 06050079-1