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Home My WebLink About06-2744 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 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. Ole - .;J7l.1Y GU'Lt-T8L~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF. YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted guiere 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. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sUs defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TrENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 717-249.3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within 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. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: 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: 153 Valley Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland DATE EXECUTED: 3/19/04 DATE RECORDED: 3/23/04 BOOK: 1857 PAGE: 4503 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 Unpaid Interest at 5.75% from 12/1/05 to 5/2/06 (the per diem interest accruing on this debt is $7.62 and that sum should be added each day after 5/2/06) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $206.54 and that sum should be added on the first of each month after 5/2/06) Late Charges (monthly late charge of $14.59 should be added in accordance with the terms of the note each month after 5/2/06) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $48,346.86 1,165.92 325.00 280.00 372.34 58.36 2.417.34 $52,965.82 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 $52,965.82 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. Udr~QUlRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT oertaln lot of ground situate in M1ddIeIex. Tov.nllhlp, C~ County, Pennsylvania, more pertlcuIarIy boulded W1d descr1beCI as follows: BOUNDED on h South by V8lley DrIve; bat.r1ded on the WeeI by Lot No. 6 Of Section "G" of Ihe hereinafter referred to Plan of Lots, bouncI8d on the North by Lots 1.2 encI13 of Secticn"(3" on said pIen, and bOI.lndl1d on !he Eest by Lot No.8 of Secllon "G" of said plan, and h8v1/lg a franI8ge of 75 feet on the NOIth side of Valley Drive and exf8l1ding at 11'I even width 140 fat in depIh. TI1e 8:love de8CrIbecIlot 15 Lot No. 7 of SectIon "G" t:I the PI8n of Loti knoWn .. Cloverteaf Acru No.2, rtrCOI'ded In the Office t:I the Record&r t:I 0eecIs of Cumberl;nc1 County, In Plan Bock 8, Page 43 and being Improved with a dwelling known 8'ld numbered as 153 Valley Dtiv9, CarIIa,., PennsyMInla " " Ii il :i \1 fj Washington Mutual Mailstop JAXB2004 P.O. Box 44090 Jacksonville, FL 32231-4090 0614847754 March 22, 2006 #BWNCLNN# #0906149647975497# 001474/PA TINA COYLE 153 VALLEY DR CARLISLE PA 17013 WE ARE A DEBT COLLECTOR. THIS IS AN AITEMPT 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# 0614847754 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi!l: j!l: an official "mice thRt the mnrt~_ 071 your horn... 1"1 in np.rnnlt anti the 1l'!ndfl!T lntl'!nn<; to fnt'lr.1011P. Sp"r.ific information ahnut the natllTf! of the default 1" nrnvirlpn ;n the llttllr.hpil nQfP..'l. The HOMROWNER's' MORTGAnR ASSISTANr.F. PROGRAM lHPMAP) may he able to help to AA.ve vour home Thil\' Notice ernlninlll how tn" nmeram wnTh Tn!llee if HRMAP can help you must M'RPT WITH A rnNSUMER l"1lpnrr r::nIJNSFI TNe; AGF.NC:V WITHIN 30 nAYS OF 'T"HP. DATE OF THIS, NOTTCP. Tn... thili'! NntlC'f! with vnn when you rnf!p.t with ih", Cnn7lClp.linr A2ency The hSlmp. Addre!ll!l: And phone number of C'nn!llumer Credit C.ollnVJHn[f A~nd~ Mrvin~ your C:oun~ 8.1'P. 11!tterl at the end of th1!1{ NotiN'! If you hJWl! any OnJ!'If;nn", VOl] mav ('All thp. pp.nn~lVli1nill Hnll~nf FinJllnrp A_nr.v toll 1TP.P. at l_RO(}..'W?:_~Q7 (Pp.nnn<;: with impairP.rl heaTinll' can call l717\ 780-]AAQ) TJUs Notice contains important legal information. If you have any questions, representatives at the CollSUlller Credit Counseling Agency may be able to help uplain it. You may also waut to contact an attomey in your area. The local bar association may be able to help you imd a lawyer. LA NOTIFICAClON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENlDO DE ESTA NOTIFICAClON OBTENGA UNA TRADUCClON INMEDITAMENTE LLAMANDO ESTA AGENClA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO 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 PAACT91 HOMEOWNER'S NAME(S): Tina Coyle PROPERTY ADDRESS: 153 Valley Dr. Carlisle PA 17013 0614847754 Flo Washington Mutual Bank WAN Acer. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVlCER: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE m.IGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FU11JRE MORTGAGE PAYMENTS. IF YOU COMPLY wrm THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACI' OF 1983 (THE "ACI'''), YOU MAY BE ELIGWLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HA VB A REASONABLE PROSPECI' OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND . IF YOU MEET OTHER ELIGIIIIL1TY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY ~TAV OF FnRF.M.n!i;1TRF. - 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 a.ttend a "faceAo-facell meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THl~ MF.F.TlNG MlJ~ ~1JR WITHIN TAR NF.X'T 110\ nAV~ IF YOU DO NOT APPLY FOR EMF..RnF.NCV MORTGAtrE A~srSTANrn VOl] MUST R'RTNc; YOUR MORTGAGE UP TO nATF. THE PART OF THIS NOTICE rAT T Rn IIHOW Tn n1RR YOUR MORTc"AGF. DEFAIJI Tll PXPT ,ATNS HOW Tn RRING YOUR MORTGAGE UP TO DATE CONmTMF.R MIROn ty)ITN~R' INt': AG'RNrJRS - 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 nll.mfl!.C< arld..---" ll.nd t.r.1pl'hnnp numhe" of dil!!lie:naU!d rnn.mmr.r r.1'Pnit ~nm,_HnlJ "Vndty; for the ('.nuntv in whi~h thf! ])rnnP.rty i~ ll'1('..ll.tM aTf! ~t forth a.t the end of thi~ NntiC'l! It is only necessary to schedule one face-to--face meeting. Advise your lender immetliatelv of your intentions. APPI.lrATION FOR MORTGAnF. AS.'U!irrANCE - 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 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 fa<e.to-fa<e 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. AGF.Nr.v AM'lON - 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 fonh above. You will be notified directly by the Pennsylvania Housing Finance Agency of its .decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECrED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE 15 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.) 00 1474/C0826 HOW TO CURE YOUR MORTGAGE DEFAULT lBriu it uo to dale). NATlJRR OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 153 Valley Dr. Carlisle PA 17013 IS SERIOUSLY IN DEF AUL T BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month, and the following amonnts are now past due: Monthly Installments: 01/0112006 0210112006 0310112006 $498.33 $498.33 5498.33 Other charges (explain/itemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE' $ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): 543.77 $0.00 50.00 HOW TO ClTQF. THE DEFAIJLT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO TIlE LENDER, WHICH IS 5. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE 1HJRTY (30) DAY PERIOD. Pavaumtlll must be mAtiI'! p.ithP.T bv ('..ash ('.J!qhie.r'IIl chfllr.k t'.P.rt;nM r:heck or monev Qrtlp.r lTI!'ltll'! 11lIvahle and !Ilp.nt to' Washington Mutual Bank Cash I'rocasing P.O. Box 3200 Mllwaukee, 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 VOlT no NOT Clmli': THF. DItli'4HI.T ~ Hyou do not cure the default within rnJRTY (30) DAYS ofthe date of this Notice, th..)p.ndP.r ini_tllI tn f!'XP.rri_ ih. rhrhu to JI-..IP.r:sIt.. th.. mortp,e dlF!ht 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 fnrfl!rl_ lI,!,!"n 'Yollr mnrtlUUled nronerh. .W THE' MOR1'G4C:R ,~ Ii'tlIl'F.rl.l11o:F.D I1PON 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 attonery'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. If '011 Mlrl'! th.. deholllt ..;thin th.. THIRTY llO\ DA. Y neriod 'You will not he reouired. to os.. .attorn"'! fees. OTHF..R LENDER RF.MF.nm!; - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACf 91 RI(~HT Tn CIJRF. THF.. DRFAIJI.T PRIOR Tn~H1i'.RTFF'S SALE.- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you mav!!Iti1l haW! the neb! in ~llrp. thf! np.unlt and ])1"P.Vfm1 thp. AAle At any time up to onll'! hnllr hefrirll'! thll'! Sheriff'!Il SlllII'! Ynll may dn sn hv ~vins~ thp. 1.nt1l1 amount thAn pa.llot dull'! Dill'" any late or other charp."l thAn dup. rPJtcrnnAble attornev'1il MP.1iil -'Iml Cll'it1il "nnnectpn with the fnuclcwnre !'UI.)e and anv other "ftIrt.<i ~onnected with the Sheriff's SAle :u:c 'lpl!dfiPil in writinl' hv the lender and by nerlnrming lID}" other rP.auirf'!111ent.<!. under the mortp2l! Curing ,.our default in the manner set forth in this notice will restore your mortple to the same position as if' you had neTer defaulted.. RART.WJ;.T ~TR1.R ~1Or.RTFF'S ~AT.F. nATR -It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from tile 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 T.RNDRR: Name of Lender: Address: Washington Mutual Bank 725S Ba;,meadow. Way JaekaonmIe, FL 32256 8Ii6-926-B937 904-281-3914 Co11eciion Department www....muhmnelaanJI..com Phone Number: Fax Number: Contact Penon: Emaii Add.....: ~ OF ~~fI1'F'S u,' R. - 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 laW5Uit to remove you and your furnishings and other belongings could be started by the lender at any time. AS~lJMPTION OF MORTGAGF. - You _ mayor ..xmay not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO 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 ACI1NG ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TillS 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 BEUEVE 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 ACT 91 V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J~!! ESQUIRE UDREN LAW OFFICES, P.C. \.) ~ 8 70 ut 7' t \t. U"\ r-> CI"\. g ~ .".. %,:!l - \- C> ::t:: ~ :;,... \) -< -,,\=n -J - -.00 ~ ..c:: U1 () l. - ..".-\~:? ~ () ?- ~ :'(:'"', ,'-,..- 20 <2 c;{(1 "" "!2 ". N ~ W -( ~ . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Tina Coyle Defendant(s) NO. 06-2744 civil Term 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: June 23, 2006 BY: Mark J. Udren, Esquire Attorney for Plaintiff It .. V E R I F I CAT ION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: I II Name: Title: Company: Greg Allen A.f. P Tina Coyle Loan #0614847754 MJU #06050092 ., ~ ... .\ .-, 'C:::~, (-".., '. . ('-) ~ '-" {" ",> W -0 .- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. 06-2744 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) Tina Coyle for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 5/3/06 to 6/23/06 Late charges per Complaint From 5/3/06 to 6/23/06 Escrow payment per Complaint From 5/3/06 to 6/23/06 $52,965.82 396.24 29.18 206.54 TOTAL $53.597.78 I hereby certify that (1) the addresses Defendant are as shown above, and (2) that notice accordance with Rule 237.1, co of which is atta he Plaintiff and as been given in ed hereto. ark J. Udren, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE:...J/~.'e .:7~ ;:)DOb , PRO PR b~~K~~~'b K~l~~~ - K~G0LAK CASE NO: 2006-02744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS COYLE TINA DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COYLE TINA the DEFENDANT , at 1423:00 HOURS, on the 17th day of May at 153 VALLEY DRIVE , 2006 CARLISLE, PA 17013 by handing to TINA COYLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.40 .00 10.00 .00 32.40 .~~~~ , , R. Thomas Kline A.D. 05/18/2006 UDREN LAW OFFICE/) /} a<h~'p? DepUt"! She By: Sworn and Subscribed to before me this day of Prothonotary C)lo()~'CJd .~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@Udren.com Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights,MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF ~ "" = = 0", 'i; X::rJ rt'),- -r.;rn :-:JO (') ; -..:., C.l :.;5'9:1 -7-""CJ '511"1 ::;.-f $ -< :-.., :::: .:.:w-. -.: COURT OF COMMON PLEAS CIVIL DIVISION c.r; :e: --.. Cumberland County '2 N (..,;, v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. Cf.s, -:2/JLlY G-Q~L';-~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE. YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 -- ,.C-'-, -, ((~'\ ((-. 7!L{)sf1J!;;J Df3 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE. CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA Plaintiff ATTORNEY FOR PLAINTIFF v. ~ COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County Tina Coyle Defendant(s) NO. 06-2744 Civil Term Tina Coyle 153 Valley Drive Carlisle, PA 17013 DATE of Notice: June 12, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED 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 NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME paR TELEFONO A LA OFICINA, CDYA 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. """ __m. ""T'""'"'!~:Q'" '"'' ""'T """"'... Mark J'I J Upl~~. sgu~re Woodcrest Corporate Center III 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 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HI~~, NJ 08003-3620 856-482-6900 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tina corle 153 Val ey Drive Carlisle, PA 17013 Defendant(s) NO. 06-2744 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF fv(rl COUNTY OF OAfon> SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon invest~gations 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: Tina Coyle Age: Over 18 Residence: As captioned above Employment: Unknown fj ('1 / ~ame: Title: Company: Greg AOen A. V.() Sworn to and subscribed before me this day f 20 e. Christina Noel SeIbrlghl .......... NOTARY PUBLIC. MINNESOTA . MY COMMISSION ..' EXPIRES JAN. 31,2011 n:,:if~i~ ~1 ~ ~ ~ t ~ . '..) ~ ~ , :-C 6' 8 t; ~ (/) t? -J:- () ~~ s~ ~~ ~-A -~\ f;'1 f'-.) -0 w ~:.J r.,,_) '.-) -:,:;! -- ~iJ _J --< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. 06-2744 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the .above matter: Amount due $53.597.78 Interest From June 24. 2006 1.264.92 to Date of Sale December 6. 2006 Ongoing Per Diem of ~ . to actual date of sale including if sale is held at a later date (Costs to be added) $ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF S ?, ..... ~ ~ f) 1"'_.) -:r ..... W ':.::::.- C) ~ ~ ~ /""- ,. ~; -q D ..f;}. -l:: "-.1 ~ -, 0-'" '- .-{ f . ..... d . ..,.. ~ () (:-::: hl,~;;, ~ . .c ~ .t:. \) V) D C ~..'.,- ~ C J"0 i~\ , Q ().- 0 C. L.) \ I I ....... r-- \ \ ~ ~~ '0 t ~ ~ r-f) -- -0 ~ ... C.) ~ ~ ~ ... t1 - , -'-.; ~~ ~ ... ... '" - ~ t . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2744 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due W ASIDNGTON MUTUAL BANK, FA Plaintiff (s) From TINA COYLE (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) 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 bas been added as a garnishee and is enjoined as above stated. Amount Due $53,597.78 L.L. $.50 Interest FROM 6/24/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $7.62 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $1,264.92 Ally's Comm % Due Prothy $1.00 Ally Paid $114.40 Other Costs Plaintiff Paid Date: JUNE 23, 2006 C~SR (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court 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 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 NO. 06-2744 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: 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 t,o authorities. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF -,,0." r-~,]: ~l ,~:-' c;r-, f"-J W ...,., G.~ i,:,-) ;::-.:~ '0 _J ~ ./ "_""lo. 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 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 NO. 06-2744 Civil Term 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: 153 Valley Drive (Middlesex TownshiplCarlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Tina Coyle 153 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None / '- 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other has knowledge who has any interest affected by the sale: Name person of whom the plaintiff in the property which may be Address Tenants/Occupants 153 Valley Drive (Middlesex Township) Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 23, 2006 Mark J. Udren, ESQ. Attorney for Plaintiff -;:-: ,.. ;~. n" o C ;,:< r_i = ('".:? C;;;..... L_ C:"~_~ i',' W ..- \. o -n .-1 f~,f0 ( c-" -0 e,y - cr.) ~ , 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 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. 06-2744 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Your house (real estate) at 153 Valley Drive (Middlesex Township) Carlisle, PA 17013 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 $53,597.78, 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 L . r: ,- () -\1 -, - ,- ~-r'\ ;),\ ~":c'^. ,~., .' ..,,- I'~ vJ -0 -- -- . t.:? -- 0") ,,5 '...i.:.. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS COYLE TINA DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COYLE TINA the DEFENDANT , at 1423:00 HOURS, on the 17th day of May , 2006 at 153 VALLEY DRIVE CARLISLE, PA 17013 by handing to TINA COYLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~ 5/1fiJO~ 18.00 4.40 .00 10.00 .00 32.40 .r~/<:~ R. Thomas Kline 05/18/2006 UDREN LAW OFFICE Sworn and Subscribed to before By: me this day of A.D. Prothonotary Washington Mutual Bank, FA VS Tina Coyle In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-2744 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Ddren. Sheriffs Costs: Docketing Surcharge Law Library Prothonotary Poundage Levy 30.00 20.00 .50 1.00 145.84 15.00 ./ $ 212.34 JlID 3/6(, ~ ?O~~.' ~ r1' ~ , R. Thomas Kline, Sheriff ,,9' ~S()'ql.-l ~ I 'i'~D~t ~ / .. '. 1 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 NO. 06-2744 Civil Term 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: 153 Valley Drive (Middlesex Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Tina Coyle 153 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None , . ., 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other has knowledge who has any interest affected by the sale: Name person of whom the plaintiff in the property which may be Address Tenants/Occupants 153 Valley Drive (Middlesex Township) Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 23, 2006 Mark J. Udren, ESQ. Attorney for Plaintiff hE :( d 8l Nnr Gnoz '\;'d .A 1 Ii; lLt".- Ud \ i~j~1 i,'~, ~ .:L:HB3HS 3!.U 30 3JIJ.:lO -. . '" 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 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Tina Coyle 153 Valley Drive Carlisle, PA 17013 Defendant(s) NO. 06-2744 Civil Term NOTICE OF SHgRIFF'S SALE OF REAL PROPERTY TO: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Your house (real estate) at 153 Valley Drive {Middlesex Township) Carlisle, PA 17013 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 $53,597.78, 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 willbereceiving 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 hE :E d 82 Nnr qQOZ id 'iU",ID.; "'; JHIIJ .:UI~3HS 31ll .:JO 3::11.:1:10 ... '- . \ , AlL THAT certain lot of ground situate in Middlesex Township, Cumberland County, Pennsytvania, more partioularly bounded and described as follows: BOUNDED on the South by Valley Drive; boUnded on the west by Lot NO.6 of Section fiG- of the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Section """ on said plan, and bouoded on the East by Lot No.8 of Seetron .G" of said plan, and hiving a frontage of i5 feet on the North side Of Valley Drive and extending at an even width 140 feet in depth. The above de8crfbed lot Is lot No. 7 of SectIon "G" of the Plan of Lot& known as Cloverteaf Acres No.2, recorded In the Office of the Reccrder eX Deeda of Cumberla'ld County, In Plan Book 8, Page 43 and being improved with a dwelling known and numbered as 153 Valley Oriv~, CarliSI., Pennsylvania . BEING KNOWN AS: 153 Valley Drive(Middlesex Township) Carlisle/ PA 17013 PROPERTY ID NO. : 21-18-1363-014 TITLE TO SAID PREMISES IS VESTED IN TINA COYLE, ADULT WOMAN BY DEED FROM KATHY ZAMPELLI AND TINA BOYER/ NOW KNOWN AS TINA COYLE, INDIVIDUALLY AND AS EXECUTRIXES OF THE ESTATE OF DONA D. BOYER/ A/K/A DONA DELORES BOYER A/K/A DONNA DELORES BOYER/ DECEASED DATED 3/19/04 RECORDED 3/23/04 IN DEED BOOK 262 PAGE 799. WRIT OF EXECUTION and/or ATTACHMENT , ". ,. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2744 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 TINA COYLE (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 accoWlt of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is fOWld 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. AmoWlt Due $53,597.78 L.L. $.50 Interest FROM 6/24/06 TO DATE OF SALE 12/6/06 - ONGOING PER DIEM OF $7.62 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $1,264.92 Arty's Comm % Due Prothy $1.00 Arty Paid $114.40 Other Costs Plaintiff Paid Date: JUNE 23, 2006 Prothonotary By: (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 ~ ~ t::::::I &f:: 9 Real Estate Sale # 40 On August 25, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, P A Known and numbered as 153 Valley Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 25,2006 By: <J~~ Real Estate Sergeant