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Home My WebLink About02-1802COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, OCWEN FEDERAL BANK FSB, 1675 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 VS. . NO. 02 - IPaA, l: tc??l DONALD L. SHIPP and EDITH M. SHIPP 20 Kenwood Ave. Carlisle, PA 17013 CIVIL ACTION- ACTION MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil \\Server\office docum\Diane\COMPLAIN\OCWEN-SHIPP CUMBERLAND 4-02.wpd Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FL., CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 \\Server\office docum\Diane\COMPLAIN\OCWEN-SHIPP CUMBERLAND 4-02.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, OCWEN FEDERAL BANK FSB, 1675 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 vs. : NO. 02 - /fCS';k, (20c C-wu j DONALD L. SHIPP and EDITH M. SHIPP 20 Kenwood Ave. Carlisle, PA 17013 CIVIL ACTION- MORTGAGE FORECLOSURE 1. Plaintiff is Wells Fargo Bank Minnesota, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB, a federal savings bank with offices located at 1675 Palm Beach Lakes Blvd., West Palm Beach, FL 33401. 2. Defendants are Donald L. Shipp and Edith M. Shipp, adult individuals with a last-known address of 20 Kenwood Ave., Carlisle, PA 17013. 3. Under date of August 31, 1995, defendants executed and delivered to American Mortgage Reduction, Inc. a mortgage upon premises 426 Factory Street, Carlisle, PA 17013 to secure the payment of the sum of $50,400.00. The said mortgage is recorded in the Department of Records in and for the County of Cumberland in Mortgage Book No. 1284, page 848, recorded \\Server\office docum\Diane\COMPLAIN\OCWEN-SHIPP CUMBERLAND 4-02.wpd October 2, 1995 and is incorporated herein by reference. A copy of the legal description of the premises is attached hereto and made a part hereof as Exhibit "A". 5. By Assignment which is being duly recorded, the loan was ultimately assigned to Wells Fargo Bank Minnesota, N.A., as Trustee. 6. Ocwen Federal Bank FSB is the duly authorized servicing agent for Wells Fargo Bank Minnesota, N.A., as Trustee. 7. The defendants are the real owners of the premises. 8. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by §403 of Act 6 of 1974, and Act 91 aforesaid, was sent to the defendants and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B". 9. The said loan is in default as a result of the failure to pay the monthly installments of $735.12 due on May 1, 2000 and on the lst day of each month thereafter. 10. The following is due on the loan: PRINCIPAL BALANCE $ 47,153.27 INTEREST (accrued thru 4/9/02 of $6,642.11. 6,642.11 Interest after 4/9/02 shall accrue at the per diem rate of $14.60.) LATE CHARGES (accrued thru 3/02 of $1,397.76. 1,397.76 Late charges after 3/02 shall accrue at the monthly rate of $29.12.) ESCROW ADVANCES 2,225.52 FEES BILLED 110.00 LESS MISC. SUSPENSE BALANCE -399.03 LESS OTHER SUSPENSE BALANCE -13.97 \\Server\office docum\Diane\COMPLAIN\OCWEN-SHIPP CUMBERLAND 4-02.wpd COSTS 300.00 ATTORNEY'S FEE 2,300.00 TOTAL $ 58,005.66 11. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendants may dispute the validity of the debt or any portion thereof. If Defendants do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendants with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendants the name and address of the original creditor if different from above. WHEREFORE, Plaintiff, Wells Fargo Bank Minnesota, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $47,153.27, plus interest thereon of $6,642.11 plus $14.60 per day from April 9, 2002 until judgment is paid in full, late charges of $1,397.76, plus late charges of $29.12 per month from March, 2002until judgment is paid in full, escrow advances of $2,225.52, fees billed of $110.00, costs of $300.00, attorney's fees of $2,300.00, plus record costs, less miscellaneous suspense balance of $399.03, less other suspense balance of $13.97. STERN AND STERCHO BY: HARD F. STERN, Attorney for Plaintiff \\Server\office docwn\Diane\COMPLAIN\OCWEN-SHIPP CUMBERLAND 4-02.wpd VERIFICATION TERESA BRATCHER is the Senior Manager of Default Servicing of Ocwen Federal Bank, FSB, and is authorized to sign this Verification on behalf of same, and states that she verifies the foregoing Civil Action against Donald L. and Edith M. Shipp and avers the statements of fact therein contained are made subject to the penalties of 18 PA C.S. Section 4904 relating to the unsworn falsification to authorities, and that same are true upon the signer's personal knowledge of information and beli9f.-I\ TERESA BRATCHER Senior Manager of Default Servicing DATE: y(,6a? 15240 EXHIBIT W ALL THAT CERTAIN HOUSE AND LOT OF GROUND LOCATED IN THE FIFTH WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AS No. 426 FACTORY STREET, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WEST SIDE OF FACTORY STREET, SAID POINT BEING 504.55 FEET SOUTH OF "A" STREET, THENCE ALONG LOT NON OR FORMERLY OF HARRY HURLEY, NORTH 83 DEGREES 35 MINUTES WEST 180.4 FEET TO A POST ON AN ALLEY; THENCE ALONG SAID ALLEY SOUTH 6 DEGREES 7 MINUTES WEST 15.3 FEET TO A POST; THENCE ALONG LOT NOW OR FORMERLY OF JOHN BARRICR, SOUTH 83 DEGREES 3 MINUTES EAST 96.8 FEET TO A POINT; THENCE ALONG THE SAME, SOUTH 83 DEGREES 41 MINUTES EAST 83.4 FEET TO A POST ON FACTORY STREET; THENCE ALONG SAID FACTORY STREET, NORTH 6 DEGREES 13 MINUTES EAST 15.8 FEET TO THE PLACE OF BEGINNING. THE IMPROVEMENTS THEREON BEING KNOWN AS NO. 426 FACTORY STREET. BEING THE SAMR LOT OR PARCEL OF GROUND WHICH BY DEED DATED MARCH 21, 1973, AND RECORDED AMONG THE LAND RECORDS OF Q COUNTY IN LIBER 25, FOLIO 364, WAS GRANTED AND CONVEYED BY AND BETWEEN JOSEPH BARGED SHIPP UNTO DQW.D L. sma-0 AND EDrm m.. SHD?P, AS THSU ws Bz 28E HPPIjtB'17[. EOCK12 i.. ..l® 0 O O W E N 7104 5400 2100 0360 0823 February 11, 2002 *0001145411* Donald L. Shipp 426 Factory Street Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when You meet with the counseling agency. The name. address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice If you have any questions. You may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numem mencionado arriba. Puedes ser elegible para un prestamo por el programs llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) : Donald L. Shipp PROPERTY ADDRESS: 426 Factory Street Carlisle, PA 17013-0000 LOAN ACCOUNT NUMBER: 89716146 CURRENTS heIR you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, 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 FORECLOSURE- Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (30) days IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Page two 89716146 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telMhone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately 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 Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed 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 you application. During that additional 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 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) HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it un to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 426 Factory Street Carlisle, PA 17013-0000 IS SERIOUSLY IN DEFAULT because : YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due : (a) 22 Payments @ $735.12 (b) Late charge(s) : (c) Other charge(s): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 02/08/2002: $14,656.96 $1,368.64 $939.20 $13.97 $16,950.83 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable) : HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $16,950.83, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 89716146 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON- . The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period you will not be required to pay attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number: (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and your furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You 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 attorneys' 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 borrower money from another lending institution to pay off this debt. To have this default cured by any third party acting on your behalf. To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a 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. Page four 89716146 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in wriin at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Ocwen Federal Bank FSB, P.O. Box 24737, West Palm Beach, FL 33416 Phone (800) 746-2936 1. •.® :0: O C W E N 7104 5400 2100 0360 0830 February 11, 2002 *0001145412* Edith M. Shipp 426 Factory Street Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta so derecho a continuar viviendo en su case. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente Ilamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para on prestamo por el programs llamado "Homeowners' Emergency Mortgage Assistance Program" al coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) : Edith M. Shipp PROPERTY ADDRESS: 426 Factory Street Carlisle, PA 17013-0000 LOAN ACCOUNT NUMBER: 89716146 CURRENT SERVICER LENDER/SERVICER: Ocwen Federal Bank FSB 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 provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, 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 FORECLOSURE- Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Pagetwo 89716146 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take fiu-ther action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately 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 Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed 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 you application. During that additional 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 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 flied bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 426 Factory Street Carlisle, PA 17013-0000 IS SERIOUSLY IN DEFAULT because : YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due : (a) 22 Payments @ $735.12 (b) Late charge(s) : (c) Other charge(s): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 02/08/2002: $14,656.96 $1,368.64 $939.20 $13.97 $16,950.83 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable) : HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $16,950.83, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 89716146 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon Your mortgaged nrovertv. IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period you will not be required to pay attorneys' fees OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number: (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and your finniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You 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 attorneys' 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 borrower money from another lending institution to pay off this debt. To have this default cured by any third party acting on your behalf. To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a 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. Page four 89716146 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in wriine at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Ocwen Federal Bank FSB, P.O. 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PAZ O y V PIZ O ' I V r7 C: Y1 i1 7" ? r l A7 Cr C r- c Jw \', el 1 0 W C3 -7 { ' 3{y? t ? ^ {l j- 5 off- SHERIFF'S RETURN - REGULAR CASE NO: 2002-01802 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS SHIPP DONALD L ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SHIPP DONALD L DEFENDANT the at 2015:00 HOURS, on the 15th day of April , 2002 at 20 KENWOOD AVENUE CARLISLE, PA 17013 DONALD L SHIPP was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this Ipt?- day of ?a? / a2ls?.L A. D. Prothonotary So Answers: R. Thomas Kline 04/16/2002 STERN & STERCHO By: 7U ?e? 4Lee Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-01802 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA NA VS SHIPP DONALD L ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SHIPP EDITH M the DEFENDANT , at 2015:00 HOURS, on the 15th day of April 2002 at 20 KENWOOD AVENUE CARLISLE, PA 17013 by handing to DONALD SHIPP a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 1yt:? day of 0.1-1 -LO-D.-2, A. D. C -L 0. othonotary So AnsweCrs : d R. Thomas Kline 04/16/2002 STERN & STERCHO By: Dep ty SheriZf- was served upon COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against defendants DONALD L. SHIPP AND EDITH M. SHIPP for failure of said defendants to file a responsive pleading to the Complaint within twenty (20) days after service thereof. Please assess damages as follows: BALANCE DUE $ 47,153.27 INTEREST (accrued dim 5/17/02 of $7,196.91. 7,196.91 Interest after 5/17/02 shall accrue at the per diem rate of $14.60.) LATE CHARGES (accrued thru 5/02 of $1,456.00. 1,456.00 Late charges after 5/02 shall accrue at the monthly rate of $29.12.) \\Smer\office docum\Dia \SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd ESCROW ADVANCES FEES BILLED LESS MISC. SUSPENSE BALANCE LESS OTHER SUSPENSE BALANCE COSTS ATTORNEY'S FEE TOTAL 2,225.52 110.00 -399.03 -13.97 300.00 2.300.00 $ 60,328.70 STERN AND STERCHO r' BY: RICHARD F. STERN, Attorney for Plaintiff \\Server\office docum\Diane\SALES\OCWE3N-SHIPP CUMBERLAND 5-02,wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY RICHARD F. STERN, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, defendants': 1. Last-known address is: 20 Kenwood Ave., Carlisle, PA 17013 2. Are over the age of twenty-one. 3. Are not now nor have been within the last six (6) months in the Armed Services of the United States, as defined in the Soldiers' Civil Relief Act of 1940, as amended. I, 4 8f Fvt;416?r J?DRABorn. . Mon Sworn to and subscr*bed before me this/ I da of M " , 2002. STERN AND STERCHO BY: RI TERN, Attorney for Plaintiff \\Semv \office docum\Di=e\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP CERTIFICATION UNDER RULE 237.1 I, the undersigned, attorney on the writ and attorney for plaintiff, hereby certify that a ten day notice of intention to enter judgment by default was sent to defendants in accordance with Pa. R.C.P. 237.1. A true and correct copy of said notice is attached hereto. STERN AND STERCHO BY: ?`- RI HARD F. STERN, Attorney for Plaintiff \\Smer\offiw dm=\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW RICHARD F. STERN, ESQUIRE STERN and STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK, MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, OCWEN FEDERAL BANK FSB VS. DONALD L. SHIPP and EDITH M. SHIPP NO. 02-1802 CIVIL TERM TO: Donald L. Shipp, 20 Kenwood Avenue, Carlisle, PA 17013 Edith M. Shipp, 20 Kenwood Avenue, Carlisle, PA 19013 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 1-800-990-9108 STERN AND STERCHO DATE: 5/07/02 BY; Ax C HARD f. TERN, Attorney for Plaintiff \\Smcr\office docum\Am Marie\Tm Day\OCWEN.SHIPP.CUMBERLAND.5.o2.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriff's Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to defendants and no timely response was made. STERN AND STERCHO BY: A- .STERN, Attorney for Plaintiff \\Smer\office dm=\Diam\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Ocwen Federal Bank FSB 1675 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Donald L. and Edith M. Shipp 20 Kenwood Ave. Carlisle, PA 17013 STERN AND STERCHO BY: CHARD F. STERN, Attorney for Plaintiff \\Semer\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd e Q.- Cy C-r Y c C) n w, a ;v ,v N U CT ?n C7 17?n PRAEC IFE Yon W ttrt ur r Ajw u t tu,v-(140ATGAGB FORECLWURi) Pa.R.C.P.3180-3183 Wells Fargo Bank Minnesota, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2 by...i-ts--attorney...i*i--f act-r ....................... Ocwen Federal Bank FSb In the ftva of Common Pleas of CUMBERLAND County , Pennsylvania. 02-1802 vs No. Donald L. Shipp and Edith M. Shipp .............................................................................. PRAECIPE FOR WRIT OF EXECUTION (AIORTGAGE FORECLOSURE) To the Prothonotary: Issue writ of execution in the above matter: Amount Due ;60-'328.7Q..... .?. Interest from the date judgment$ ............................ and Costs. is entered at the per diem rate of $14.60. RA RD .oSTERN,oE $(R615 Note: Please attach description of Property. N N O 6 z v N. to N ? d 4 .] v d C Z?w = m ro 7" e r . , U ., E U3 >1 o V £ oG a C x O N V ?- 4J '-I ` 1 e o w V 4J W :--1 W s ? 0 r 11 $4 3 w ? O R x a 41 a .l a a V C? O PC W O 00 O w o a W Qi C. d l to a N Eaa: H N M O n a0 m 3 o w U a w H 'LO N a v a O - c_) ti n C7 n ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Joseph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/21/73 in the County of Cumberland in Deed Book 25B page 364. Tf'' C'f 0 0 N -n c. ? n N ?.trft N =b -zI N Urn J COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP AFFIDAVIT PURSUANT TO RULE 3129.1 RICHARD F. STERN, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 426 FACTORY STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s): Donald L. and Edith M. Shipp 20 Kenwood Ave. Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Donald L. and Edith M. Shipp 20 Kenwood Ave. Carlisle, PA 17013 \\Smer\office d0cum\Dieue\SALES\0CWEN-SH1PP CUMBERLAND 5-02.wpd 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: Household Realty Corp. 25 Gateway Dr., Ste. 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: N/A 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: N/A 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: Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Occupant 426 Factory Street Carlisle, PA 17013 \\Server\office docum\Di=e\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd 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. Section 4904 relating to unsworn falsification to authorities. Date: 5/17/02 STERN AND STERCHO BY l ARD F. STERN, Attorney for Plaintiff \\SmeAoffice dmc \Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Joseph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/21/73 in the County of Cumberland in Deed Book 25B page 364. n o n ?: illA? ,a '?-^] ?l 1,? N _, ..?-i ? p _ ?. N J. : ` ??r ? : Li -p C -r5 'i> -, 4 ? -t. ?j ? N ?r ?? l (_ {V ??5771 .J -< COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP NOTICE OF SHERH F'S SALE OF REAL PROPERTY TO: DONALD L. AND EDITH M. SHIPP 20 KENWOOD AVE. CARLISLE, PA 17013 Your real estate at 426 FACTORY STREET, CARLISLE, PA 17013 is scheduled to be sold at Sheriff's Sale on SEPTEMBER 4, 2002 at 10:00 A.M., in the Cumberland County Courthouse, Carlisle, PA, to enforce the court judgment of $60,328.70 obtained by Ocwen Federal Bank FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: \\Smer\office do m\Diaw\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd 1. The sale will be cancelled if you pay to Stem and Stercho the back payments, late charges, costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stern and Stercho, telephone (215) 572-8111. 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 Stem and Stercho, telephone (215) 572-8111. 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 Stem and Stercho, telephone (215) 572-8111. 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 a 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 on a date specified by the Sheriff no later than 30 days after the sale date. 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 the date of filing of said schedule. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. \\Smer\office dw=\Diane\SALES\OCWEN-SmPP CUMBERLAND 5-02.wpd 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 REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 \\Smer\office docum\Diam\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Joseph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/21/73 in the County of Cumberland in Deed Book 25B page 364. n o N O Cart, ? r.T ?-? U?C? tN ,-,:n cj? ??E', !, c `? ,; <? ' C PJ n ? j ? N •J .? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1802 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, MN, NA, AS TRUSTEE FOR DELTA FUNDING HOME EQUITY LOAN TRUST 199-2 BY ITS ATTORNEY IN FACT, OCWEN FEDERAL BANK FSD PLANTIFF(S) From DONALD L. & EDITH M. SHIPP, 20 KENWOOD AVE., CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 426 FACTORY ST., CARLISLE PA 17013. (SEE ATTACHED LEGAL DESCRIPTION.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 $50,328.70 Interest FROM 5/22/02 AT $14.60 PER DIEM Atty's Comm % Arty Paid $119.45 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MAY 22, 2002 REQUESTING PARTY: Name RICHARD F. STERN, ESQ. Address: 410 THE PAVILION JENKINTOWN PA 19046 Attorney for: PLAINTIFF Telephone: (215) 572-8111 Supreme Court ID No. 03315 CURTIS R. LONG Prot`on`-- . Civil Division By: RICHARD F. STERN, ESQUIRE STERN and STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA, :IN THE COURT OF COMMON PLEAS N.A., as Trustee for Delta Funding Home CUMBERLAND COUNTY equity Loan Trust 1995-2, by its attorney in fact, OCWEN FEDERAL BANK FSB VS. : NO. 02-1802 CIVIL DONALD L. SHIPP and EDITH M. SHIPP CERTIFICATE OF SERVICE I, RICHARD F. STERN, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendant by regular and certified mail, return receipt requested on June 17, 2002. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on June 17, 2002 as evidenced by copy of certificates of mailing attached. STERN AND STERCHO BY• ??--- RICHARD F. STE Attorney for Plaintiff 6/17/2002 \\Server\office docum\Anne Marie\Certificates\OCWEN.SH PP.CERT.CUMBERLAND.6.02.wpd ._.,._....POS,._.,. JOE FOR INSURANCE-POSTMASTER PAEI ??" ?, STERN STERC PAV/ZOO Att2qlpygLat Jenkintown, n - OM pace of ottlmMT mw wameeen to: Aps I V d C7 Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 re rarm o01 r, mar. naa 8oetmAter fZ? Tfss. 0 N ?f tE a Z`.l \ Ilt `« V 1..71 nt .......... POSTAL MY BE USED FOR DOMESTIC AND INTERNATIOfML FRAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER RoNaleed Fmm: STERN & STERCHO Attome e a _ Jenkintown W=4,/O\, h Ni oR. q.e. of eraRw mw wm.Ma fe: ? -f zo Tax Claim Bureau s ?? Cumberland County Courthouse I Courthouse Square Carlisle PA 1 O1 a N ..0 .A r E10C if Fu .?ie:nREP 0 .. ,:I'm 1 i r aver w? ?n a m ? v ei A .rivzp..? no?? i% ra ronn oD I r, mr. I aea III 1„ f?;l STERN & STERCHO o Attonne at Law ZT ? 6' 11A. 1,41 PA spliffia" 111 rA IRn4in.n.... M. Ft mw ws....e m: 11 !„ hold Realt Coro. Ga eway Drive, Ste. h icsburg, PA 17055 U.S. POSTAL SERARCE CERTIFICATE OF MAI LING M11V BE USED FOR DOMESTIC AND INiMNAnONAI MAIL. 000 NOT FAMIDE FOR INSURANCE-POSTMASTM Recelrw Fmm: STERN & STERCHO 4q4gpq at 611w 10 1 no Pavilion 4 Jenkintown, PA 18046 Dm Meee w eMwere RME .aM.Mw m: P Occupant /O,y 426 Factory Street rn ti?' C4 ~ c sG. Carlisle PA 17013 L Cf) Z N ?' 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 Wells Fargo Bk of Minnesota N A is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 22nd day of May, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1802, at the suit of Wells Fargo Bk Minnesota, N A Tr for Delta Fund Home Equity Loan Trust 95-2, aif against Donald L Shipp & Edith M is duly recorded in Sheriff s Deed Book No. 253, Page 3681. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this o7 (a day of A.D. 2002 Deeds MyyCCwwnMW EiiptrCwrbe tlIBemWFUet=- ? ? Wells Fargo Bank Minnesota, N.A., as In The Court of Common Pleas of Trustee for Delta Funding Home Equity Cumberland County, Pennsylvania Loan Trust 1995-2, by its attorney in fact, Writ No. 2002-1802 Civil Temr Ocwen Federal Bank FSB VS Donald L. Shipp and Edith Shipp Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2002 at 7:45 o'clock PM, 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: Donald L. Shipp, by making known unto Donald Shipp personally, at 20 Kenwood Ave., Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2002 at 7:45 o'clock PM, 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: Edith Shipp, by making known unto Donald Shipp, at 20 Kenwood Ave., Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2002 at 3:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donald L. Shipp and Edith Shipp located at 426 Factory Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Donald Shipp, by regular mail to his last known address of 20 Kenwood Ave, Carlisle, PA 17013. This letter was mailed under the date of July 8, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Edith Shipp, by regular mail to her last known address of 20 Kenwood Ave, Carlisle, PA 17013. This letter was mailed under the date of July 8, 2002 and never returned to the Sheriff s 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, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Richard Stern for Wells Fargo Bank Minnesota, N.A. It being the highest bid and the best price received for the same Wells Fargo Bank Minnesota, N.A. of c/o Ocwen Federal, 1675 Palm Beach Lakes Blvd., West Palm Beach, FL 33401, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $702.84, it being costs. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed $30.00 13.78 15.00 15.00 30.00 10.00 .50 1.00 6.90 1.16 15.00 30.00 251.45 203.35 25.20 25.00 29.50 $ 702.84 paid by attorney 9/19/02 Sworn and subscribed to before me So This 16 '- day of Qe,64? R. Thomas heriff 2002, A.D. BY, A4 t P othonotary Real state eputy 30 CIO Ck - 3,72 19 ,„, 130gy?.' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. k 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP AFFIDAVIT PURSUANT TO RULE 3129.1 RICHARD F. STERN, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 426 FACTORY STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s): Donald L. and Edith M. Shipp 20 Kenwood Ave. Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Donald L. and Edith M. Shipp 20 Kenwood Ave. Carlisle, PA 17013 \\Smer\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: Household Realty Corp. 25 Gateway Dr., Ste. 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: N/A 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: N/A 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: Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Occupant 426 Factory Street Carlisle, PA 17013 \\Ser er\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd 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. Section 4904 relating to unsworn falsification to authorities. Date: 5/17/02 STERN AND STERCHO BY: R ARD F. STERN, Attorney for Plaintiff \\Server\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Joseph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/21/73 in the County of Cumberland in Deed Book 25B page 364. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 WELLS FARGO BANK MINNESOTA, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 02-1802 civil DONALD L. SHIPP and EDITH M. SHIPP NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DONALD L. AND EDITH M. SHIPP 20 KENWOOD AVE. CARLISLE, PA 17013 Your real estate at 426 FACTORY STREET, CARLISLE, PA 17013 is scheduled to be sold at Sheriff's Sale on SEPTEMBER 4, 2002 at 10:00 A.M., in the Cumberland County Courthouse, Carlisle, PA, to enforce the court judgment of $60,328.70 obtained by Ocwen Federal Bank FSB against you. 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: \\Ser er\office docum\Diane\SALES\0CWEN-SH1PP CUMBERLAND 5-02.wpd 1. The sale will be cancelled if you pay to Stern and Stercho the back payments, late charges, costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stem and Stercho, telephone (215) 572-8111. 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 Stern and Stercho, telephone (215) 572-8111. 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 Stern and Stercho, telephone (215) 572-8111. 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 a 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 on a date specified by the Sheriff no later than 30 days after the sale date. 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 the date of filing of said schedule. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. \\Smer\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd 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 REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 \\Smer\office docum\Diane\SALES\OCWEN-SHIPP CUMBERLAND 5-02.wpd ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Joseph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/21/73 in the County of Cumberland in Deed Book 25B page 364. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1802 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, MN, NA, AS TRUSTEE FOR DELTA FUNDING HOME EQUITY LOAN TRUST 199-2 BY ITS ATTORNEY IN FACT, OCWEN FEDERAL BANK FSD PLANTIFF(S) From DONALD L. & EDITH M. SHIPP, 20 KENWOOD AVE., CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 426 FACTORY ST., CARLISLE PA 17013. (SEE ATTACHED 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/are 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 $50,328.70 Interest FROM 5/22/02 AT $14.60 PER DIEM Atty's Comm % Atty Paid $119.45 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MAY 22, 2002 REQUESTING PARTY: Name RICHARD F. STERN, ESQ. Address: 410 THE PAVILION JENKINTOWN PA 19046 Attorney for: PLAINTIFF Telephone: (215) 572-8111 CURTIS R. LONG Prothonotary, Civil Division BY: Supreme Court ID No. 03315 Real Estate Sale # 78 On June 18, 2002 the sheriff levied upon the defendant's interest in the real property situated in The Borough of Carlisle, Cumberland County, PA known and numbered as 426 Factory Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 18, 2002 By: Jod-q f Real Estate Deputy %09 ? ale .. t ? 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 Frank J. Epler being duly sworn according to law, deposes and says: 'That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. 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 subscribed before me., SALE#78 REAL (ESTATE SALE No. 78 Writ No. 2oo2-1802 Clvll Term Wells Fargo Bank (Minnesota N.A. as Trustee for Delta Funding Home Equity Loan Trust 1895-2, by Its Attorney-In-Fact, ocwen Federal Bank FSB vs Donald L. Shipp and Edith Shipp A.tty: Richard Stern DESCRIPTION ALL THAT CERTAIN house and lot of ground located in the Fifth Ward of the Borough of Carlisle. Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particularly bounded and described as follows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of IA" Street; thence along lot now or formerly of Harry Hurley, North 83 degrees 35 minutes West Notarial Seal Terry L. Russell, Notary Public `- City Of Harrisburg, Dauphin County My Commission Expires June 6, 2006 Member, Pennsylvania Association CK Notar 14th day pf"Aug i? A. D. NOTARY PUBLIC commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 201.60 Probating same Notary Fee(s) $ 1.75 Total $ 203.35 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. 180.4 feet to a post on an alley; thence along said alley South 6 degrees 7 minutes West 15.3 feet to a post; thence along lot now or formerly of John Barrick,. South 83 degrees 3 minutes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes Easl 15.8 feet to the place of BEGINNING. By TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife, by deed from Joseph Harold Shipp, a single man, by deed dated 3121173 recorded 3121/13 in the County of Cumberland in Deed Book 25B page 364. 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. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 38 Writ No. 2002-1802 Civil Wells Fargo Bank Minnesota, N.A., as Trustee for Delta Funding Home Equity Loan Trust 1995-2, by its Attorney-In-Fact, Ocwen Federal Bank FSB VS. Donald L. Shipp and Edith Shipp Atty.: Richard Stern ALL that certain house and lot of ground located in the Fifth Ward of the Borough of Carlisle. Cumberland County, Pennsylvania, known as No. 426 Factory Street, more particu- larly bounded and described as fol- lows: BEGINNING at a point on the West side of Factory Street, said point being 304.55 feet South of "A" Street; thence along lot now or for - R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST, 2002 tUAR LO' E. SN (DE'St, my C Warch 55.2405 merle of Harry Hurlev, North 83 degrees 35 minutes West 180.4 feet to a post on an alley: thence along said alley South 6 degrees 7 min- utes West 15.3 feet to a post; thence along lot now or formerly of John Barrick, South 83 degrees 3 min- utes East 96.8 feet to a point; thence along the same, South 83 degrees 41 minutes East 83.4 feet to a post on Factory Street; thence along said Factory Street, North 6 degrees 13 minutes East 15.8 feet to the place of beginning. TITLE to said premises is vested in Donald L. Shipp and Edith M. Shipp, his wife by deed from Jo- seph Harold Shipp, a single man by deed dated 3/21/73 recorded 3/ 21/73 in the County of Cumberland in Deed Book 25B page 364. tLS