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HomeMy WebLinkAbout06-4854 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 com Mortgage Electronic Registration Systems, Inc. 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff V. Dillsburg, PA 17019 Defendant(s) Eric J. Blaschak Stacy M. Blaschak P.O. Box 550 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. Otw-)4p - / l,. l Cj ? C- ? Pl 1 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 quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. At Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 I 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/a Assignments of Record to: N/a Recording Date: N/a 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 420 North Enola Drive MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 9/27/04 DATE RECORDED: 9/29/04 BOOK: 1882 PAGE: 2007 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 8/21/06: Principal of debt due $127,591.65 Unpaid Interest at 8.59%* from 1/1/06 to 8/21/06 (the per diem interest accruing on this debt is $30.29 and that sum should be added each day after 8/21/06) 6,986.52 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of $49.93 dd d i d d n accor ance shoul be a e with the terms of the note each month after 8/21/06) 699.02 Suspense Balance (11.70) BPO 425.00 Property Inspection 136.50 NSF Charges 50.00 Attorneys Fees (anticipated and actual to 5% of principal) 6.379.58 TOTAL $142,861.57 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $142,861.57 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 19 Aregis MORTGAOICORPORATION NOTICE OF DEFAULT 71074276015105536675 June 02, 2006VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71074276015105536675 Reference Code: 0606 Stacy Blaschak P O BOX 550 Dillsburg, PA 17019-0000 Loan Number: 200037869 Property Address : 420 North Enola Drive, Enola, PA 17025-0000 AC79L I0 Please see the enclosed Document EXHIBIT A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* Agency. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRDIA. 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. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: Stacy Blaschak 420 North Enola Drive, Enola,PA 17025.0000 200037869 Aegis Funding Corporation CURRENT LENDER/SERVICER: Aegis Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meetinq with one of the consumer credit counseling agencies listed at the end of this Notice. THIS 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. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you 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 face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 420 North Enola Drive, , Enola, PA, 17025-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 5 payments in the amount of $ 998.59 from February 01, 2006 through June 02, 2006 Principle and Interest .............................. $ 4,992.95 Escrow .................................................. $ 0.00 Total Late Charges ................................. $ 649.09 Non-Sufficient Funds Charges ................. $ 50.00 Other Advances .................................... $ 551.78 Interest Arrearage ................................. $ 0.00 Non Escrow Balance .............................. $ 0.00 Subsidy Balance (Credit) ........................ $ 0.00 Suspense Balance (Credit) ...................... $11.70 Non-NSF Fees ........................................ $ 0.00 Interest Reserve Balance ........................ $ 0.00 Total Amount Due .................................. $ 6,232.12 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 6,232.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorneys fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have 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 or other 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 a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: AEGIS MORTGAGE CORPORATION Address: 9990 Richmond Avenue Ste 400S, Houston, TX 77043 Phone Number: 1-866-399-5857 Contact Person: Collections Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or IN01 may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and 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 TO BORROW 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, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Aegis MORTOAORCORPORATION NOTICE OF DEFAULT Stacy Blaschak 71074276015105536682 June 02, 2006VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71074276015105536682 Reference Code: 0606 420 North Enola Drive Enola, PA 17025-0000 Loan Number: Property Address 200037869 420 North Enola Drive, Enola, PA 17025-0000 Please see the enclosed Document ACT91.10 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: Stacy Blaschak 420 North Enola Drive, Enola, PA 17025-0000 200037869 Aegis Funding Corporation CURRENT LENDER/SERVICER: Aegis Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MORTGAGE UP TO DATE. 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. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling ag6ncy listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you 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 face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 420 North Enola Drive, , Enola, PA, 17025-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 5 payments in the amount of $ 998.59 from February 01, 2006 through June 02, 2006 Principle and Interest .............................. $ 4,992.95 Escrow .................................................. $ 0.00 Total Late Charges ................................. $ 649.09 Non-Suff icient Funds Charges ................. $ 50.00 Other Advances .................................... $ 551.78 Interest Arrearage ................................. $ 0.00 Non Escrow Balance .............................. $ 0.00 Subsidy Balance (Credit) ........................ $ 0.00 Suspense Balance (Credit) ...................... $ 11.70 Non-NSF Fees ........................................ $ 0.00 Interest Reserve Balance ........................ $ 0.00 Total Amount Due .................................. $ 6,232.12 S. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 6,232.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made Payable and sent to: IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' 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 you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have 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 or other charges then due, reasonable attorney's 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 a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: AEGIS MORTGAGE CORPORATION Address: 9990 Richmond Avenue Ste 4005, Houston, TX 77043 Phone Number: 1-866-399-5857 Contact Person: Collections Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or INO) may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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 THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. July 17, 2006 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency 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 fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNERDS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIbHR SU HH'OTECA. Page 1 of 1 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Stacy M. Blaschak Eric .Blaschak 420 North Enola Drive Enola PA 17025 _ 200037869 __ ._Aeg Funding Corporation _ Aegis Funding CowQration HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RF, F.LIGIRIN FOR FINANCIAL ASSTSTANCF. WHICH CAN SA VF, VQfTR HOME, FROM FORF,CLOSURF, AND HELP YOU MAKE: FUTTTRF MORTGACX, PAYMF,NTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORF,CLOSTTRF __ Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MTT.ST OCCITR WITHIN 0 B CONSITMFR CREDIT COTTNSFT TNC ACFNCTFS __ If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names _ addresses and ted=hr,nP m,mhrrc of designated consumer credit counseling Agencies for the oun4 i which the nr zn rte is for drrl are set forth of the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediate) of your intentions. APPLICATION FOR MORTGAGF, ASSISTANCE __ Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you 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 Page 2 of 2 face- to-face meeting. YOU MU FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATITRE. OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 420 North Enola Drive Enola PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $913.34 for January 1, 2006 = $913.34 Monthly Payments of $912.73 for February 1, 2006 = $912.73 Monthly Payments of $912.12 for March 1, 2006 = $912.12 Monthly Payments of $91150 for April 1, 2006 = $91150 Monthly Payments of $910.88 for May 1, 2006 = $910.88 Monthly Payments of $910.25 for June 1, 2006 = $910.25 _Monthl Payments of $909.62 for J& 1.2006 = $909.62 Monthly Late Charges of $4557 for_Janu 12006 th%Jul? 1, 2006 =$318.99 Other charges (explain/itemize): NSF Fee=$50.00 Property Inspection Fee=$13650 BPO Fee=$425.00 Previous Attorney Fee=$96.28 Other Uncollected Late Fees = $479.89 _ Suspense = 11.70_--_-- _TOTAL AMOUNT PAST DUE: $7875911_ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use. if not applicable): Na HOW TO CURE, THE. DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7$75916 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. pa; tens must he made either by ragh cashier's check certified hxk or money order made, narahle. and sent to- Page 3 of 3 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.): hU IF YOIT DO NOT CiTRF. T14F, DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends t x mice its nigh c to accelerate he mortgage dpht- This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgogcd pa*c tv. IF THE. MORTGAGF. IS FORECLOSED iMM -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if 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 you cure the default within the THIRTY Cull DAY period. yon will not he required to pay nttnrncXN fees. OTHER i.F.NDF.R RF.MMY S -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CITRF. THE. DEFAULT PRIOR TO SHERIFF'S SAi.F, --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 went the gale, at anytime lip to one hour before the Sheriffs Sale You may do co by paying the total amount then ago . 1 chie us and We or other char=s then due reasonable attnrney'c - and costs rnnnected with the foreclosure Sale and any other costs connected with the Sheriffs Sale as .gp fied in writing by the lender and by performing any other requirement-, under the mortoave, 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. F.ARiTEW POSSYRI.F SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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/Servicer: Aegis Mortgage Cor araGon Address: Attn: Cashiering Dept R1-16 9990 Richmond suite 400 _ Houstgn. 77042 Phone Number: __866)399-5845 .____ Fax Number: _L866) 855_3802 --------------.._.-_-- Contact Person: Loss Mitigation Deept EFFECT OF SHERIFF'S SAi E.. -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSi1MMON OF MORTGA-- You may not 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. Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 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 THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 a P f J T 0 Q C2 0 C3 s O O O lR W Oa Oa LT i ti 03 00 FIJI o it 7 x ggi b V 'fit ° m k r P 2t) 1d PUB 2Odtl 21 Pe222tPPe ew uo ef4elfese loo "flop of ssaose fautaful us Auflfew u84s if 1=0=11 806.1 21412A2S :.LNVAOOdWi 'Imw pus eNwood 4NM IW M XWe Pus 4oe3eP'PePeau lou sI 1dle? 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PsrInbej Del IIeW POW80lnoA uo 4pewlre3d QSdSf1 b 9dlom wrgw elimltlnp 9 4" eel a eAIGM ol'„ palsenbeW Wleosa wrgs,, 8090" NUOPu3 'e1 loo w a9alsod epeOlldds pps puu?snewpPre syl of (49S uuod Shc ANON Id a B 10 f nba Gage et FewJMsoea unisa a reNl p loPPs m Jiojj m 'IMVJ pe a Jo pwneul ApleOOO eesep'se WIWA ;I9W P9080 ysm 0301AOad 81 3svw3A0o 3owunSNl ON • Im {euollmmnul 10 seep Aug X4 elg9PS•9lou 91 PIN powso ¦ 4POPd ro 011914490010-lsgd LAW PsulQwOO eq AlNOiepu/uwyl?WA0 0 smeA om1 jru eoKmq Mulad 041 Act lde4 AmAgop to Wm V ¦ aoaldpw nwA M4 iePPll" enblun V ¦ m 39D0, J" 2002 (Reversa) ldleoer 3Nllew v ¦ s9PIA01d IIBW PBIIIP09 V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. V C' o 2 ?O ^C ,D r r_. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc Plaintiff V. Eric J. Blaschak Stacy M. Blaschak Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-4854 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: September t q , 2006 UDREN LAW OFFICES, P.C. Mark J. Udren, SQUIRE ATTORNEY FOR PLAINTIFF ?' c? ?? ?} ??? ? ? ?? ? ?. t w N za? i'? SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04854 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT unable to locate Him in his bailiwick. COMPLAINT - MORT FORE , but was He therefore returns the the within named DEFENDANT , BLASCHAK ERIC J 420 N ENOLA DRIVE ENOLA, PA 17025 PER TENANT, DEFENDANT LIVES IN DILLSBURG. NOT FOUND , as to Sheriff's Costs: So answers* Docketing 18.00 =! Service 13.20 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 46.20,/ UDREN LAW OFFICE 7?2*? `6? 4, 08/29/2006 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - NOT FOUND a -. CASE NO: 2006-04854 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BLASCHAK STACY M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT , BLASCHAK STACY M 420 N ENOLA DRIVE NOT FOUND , as to ENOLA, PA 17025 PER TENANT, DEFENDANT LIVES IN DILLSBURG. Sheriff's Costs: So answer -'' Docketing 6.00 Service .00 Not Found 5.00 R. Thomas line Surcharge 10.00 Sheriff of Cumberland County .00 21.00./ UDREN LAW OFFICE ( 9-2?-OL 08/29/2006 Sworn and Subscribed to before me this day of A. D. Ap UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION Plaintiff :Cumberland County V. Eric J. Blaschak :NO. 06-4854-Civil Term Stacy M. Blaschak Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: November 10, 2006 UDREN LAW OFFICES.. P.C. BY: rk J. Udren, Esquire torney for Plaintiff 40 V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:Sod 61 dooe, T Eric J. Blaschak Stacy M. Blaschak Loan #200037869 MJU #06070181 Name : ,6e fla Title: A#0e !/ ffn,?dpFactcy ll Company: Aegis mortgage Corp. as servicer on behalf of Mortgage Electronic Registration Systems, Inc. r rr 6' - " Y l UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 9990 Richmond Houston, TX 77042 Plaintiff V. Eric J. Blaschak Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854-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) Eric J. Blaschak and Stacy M. Blaschak 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 $142,861.57 Interest Per Complaint 2,453.49 From 8/22/06 to 11/10/06 Late charges per Complaint 99.86 From 8/22/06 to 11/10/06 TOTAL $145,414.92 I hereby certify that (1) the addresses of the P intiff and Defendant are as shown above, and (2) that notice has b en given in accordance with Rule 237.1, a copy of which is attached h reto. ICM P. C. DAMAGES ARE HEREBY ASSESSED AS DATE : J) e3 0 torney for Plaintiff INDICA D PRO ROTHY UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 ATTORNEY FOR PLAINTIFF CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, Inc. Plaintiff V. Eric J. Blaschak Stacy M. Blaschak Defendant(s) TO: Eric J. Blaschak 11 Morari Drive Dillsburg, PA 17019 DATE of Notice: October 30, 2006 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-4854 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO 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 PRACTI S ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT ECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION B I WILL USED FOR PURPOSE. LL Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 VDRBN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, Inc. Plaintiff V. Eric J. Blaschak Stacy M. Blaschak Defendant(s) TO: Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 DATE of Notice: October 30, 2006 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-4854 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 i NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTI S ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT/"'COLLECTORZ THIS IS A;r ATTEMPT TO COLLECT A DEBT. ANY INFORMATION QBT%INED WT/'LL 8X USED FOR T PURPOSE. s Marx .J. Uaren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 agg_AA9_AQnn Mortgage Electronic Registration Systems, Inc. C/o Fidelity National Foreclosure and Bankruptcy solutions 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff V. Eric J. Blaschak Stacy M. Blaschak P.O. Box 550 Dillsburg, PA 17019 De f endant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Minnesota COUNTY OF Dakota SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Eric J. Blaschak Over 18 As captioned above Unknown Stacy M. Blaschak Over 18 As captioned above Unknown Sworn to and subscribed before me this da of 2064. a u c ame : ?I?rn a Title: Company:.?ar?cC , AeAg orp. as serv.icer on behal of Mortgage Electronic Registration Systems,Inc. AMBER KAISER NOTARY PU15LIC. MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 1 OF 2 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN - .1NST#tlK DO 1. PLAINTIFF/SI Mortgage Electronic Registration Systems Inc 3. DEFENDANTISI Eric J. Blaschak et al V01*4" 11 SERVICE CALL (717) 771-9601 PIONS ' L.N1 E 1 THRU 12 ANY COPES 2. COURT NUMBER 06-4854 civil _ 4. TYPE OF WRIT OR COMPLAINT NOT & Notice & Ccmplaint i n C I M F Mortcraae Foreclosure SERVE 5. NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Eric J. Blaschak 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO.. CITY, BORO. TWP, STATE AND ZIP CODE) AT 11 Morari Drive Dillsburg, PA 17019 7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE U DEPUTIZE U ERT MAI U 1ST CLASS MAIL U POSTED U OTHER NOW September 26, 20 06 1, SHERIFF OF COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute this rn, M return ther ording to law. This deputization being made at the request and risk of the plaintiff., - '.,,, 4101 U SHERIFF OF 6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITINt:}?$ElVIC5 F C O U N T Y eland ADVANCE FEE PAID BY ATTY. Please mail return of service to Cumberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss. destruction. or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE MARK J. U D R E N , ESQ. 10. TELEPHONE NUMBER 11. DATE FILED WOODCREST CORPORATE CENTER, CHERRY HILL, NJ STE.200 1856-669-5400 9-20-2006 N 1 C TO NAME AND ADDRESS BELOW: (This area must be completed 9 notice is lobe nta/ed). CUMBERLAND CO. SHERIFF SPACE' OM'OW FOR' USE OF, TfE SIfRff, = 0 'NOT `1111 WE EL6W- TM iJ+E 13. 1 sdvwvAedge receipt of the writ 14. DATE RECEIVED 15 ExpiratiorVHearing Date or complaint as indicated above. Y C S O M J M C G I L L 19/27/2006 110/20/2006 16. HOW SERVED: PERSONAL ( RESIDENCE ( POSTED(.) POE ( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. 0 I hageby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 1 W `? 19. ^at? Se? 20 Time '??rvice? ff, 8. O O U SERVED /LIST AQDREC HERE IF MAoTSHO WNABOVE (Relationship to Deft A PTS T Miles Int. Date Time Miles lint. Date Time Miles Int. Date Tone Miles kK Time Miles Int. 1113a-lelTirnelMilesr l Int. 22. 23. Advance Costs 24 Service Costs 25. N/F 26. Mileage 27. Postage 26. Sub Total 29. Pound 30. Notary 31. Surchg. 32. Tot. Costs 33 Casts Due Rat Check $100.00 00 °26.63 1 W-6 .OV 1 51.63 t.4. (112-2 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. Found 39. Total Costs 40. Costs Due or Refund 41 AFFIRMED 6TH d b i d t ANSWERS . an su scr be to be o me this 42. day of -bi 114O1?rv trtArLfi 44 Signs of Dep. R 13-? 45. DA 46. Sgnatu of York Z" DATE NOTARIAL SEAL county LISA L. BOWMAN, NOTARY PUBLIC WILLIA H 0 S , SHERIFF 10/6/06 CITY OF YORK, YORK COUNTY 48. Signature of Foreign 49 DATE MY COMMISSION EXPIRES AUG. 12, 2009 County Sheriff 50. 1 AC SIGNATURE 51 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing AuVKN* 2. PINK - Attorney 3. CANARY - SheriRa Office 4. BLUE - Shenfrs Office 2 OF 2 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST.,YORK, PA 17401 K SERVICE CALL (717) 771-9601 SHERIFF SERVICE WSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LW 1 TI#tU 12 1010140T, DETACH ANY COPIES 1. PLAINTIFF/S/ 2. COURT NUMBER nc eor;n --l riot t a a r??t; u yr i ??: n i5 t t -Lt QXtil-t=- IL 4. TYPE OF WRIT OR COMPLAINT N U T & 3. DEFENDANT/S/ Notice and Complaint Eric J. Blaschak et al C I M F SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Stacy M B1ascbak 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, TWP. STATE AND ZIP CODE) AT 11 Morari Drive Di 11Ghttrq, RA 17019 7. INDICATE SERVICE: O PERSONAL U PERSON IN CHARGE U DEPUTIZE '-1 ERT. MA LI 1 ST CLASS MAIL U POSTED U OTHER NOW September 26 20 06 I, SHERIFF OF COUNTY, PA ,,do hereby dep i the sheriff of York COUNTY to execute t " make r ter ording to law. This deputization being made at the request and risk of the plaintiff., SHERIFF OF COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITIN$fff VIC.EF COUNTY ADVANCE FEE PAID BY ATTY. Please mail return of service to Cmberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after ratifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATUFiM A R K J . U D R E N , E S Q . 10. TELEPHONE NUMBER 11. DATE FILED WOODCREST CORPRATE CENTER,111 WOODCREST ROAD, STE, 200 1856-669-4500 19/20/2006 -49 H4. R& i kW D 1 S C ADDRESS BELOW: (This area must be completed d notice is to be marled). CUMBERLAND CO. SHERIFF SPAN BELOW 1F0R=USE'0IF"TW S , - 00440T ' WIM REIOW M LIf+E 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 ExpirstionlHearing Date or complaint as indicated above. M J M C G I L L Y C S O 6/27/2006 110/20/2006 16. HOW SERVED: PERSONAL ( RESIDENCE ( POSTED(.) POE( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. O 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, conpany, etc, named above. (See remarks below.) 16 AND TITL D UAL S RVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Se ice c?k? cY -gtasc?c?,?, 10-S-dG r3???ii! 21. A PTS T Miles Mt. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. 22. 23. Advance Costs 24. Service Costs 25. N/F 1 26. Mileage 1 27. Postage 28. Sub Total 29. Pound 1 30, Notary 31. Surchg. 1 32, Too. Costs 33 Costs Due or Refund Check No. 34. Foreign County Costs 35. Advance Costs 36. Service Costs 37 Notary Cert. PostagdNol nd 39. Total Costs 40. Costs Due or Refund 41 i AFFIRMED d b 6T14 A /I so ANSWERS . and su scr to before me this be 42. day ON OF r ? u. Si u S 45. D TE -j--4 AQMK / NOTAR NOTARIAL SEA LISA L BOWMAN NOTARY PUBLIC 46. Signalu of York County S ?? Pig (?? .GATE . , CITY OF YORK, YORK COUNTY WILLIAM OSE SHERIFF 10/6/06 MY COMMISSION EXPIRES AUG. 12, 2009 48. Signature of Foreign 49 DATE County Sheriff 50.1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 51. DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. W HATE - Issuing Authority 2. PINK - Attorney 3. CANARY . SheriRS Office 4. BLUE - Shardrs Office SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BLASCHAK ERIC J but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On October 12th , 2006 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York Count y 51.03 Postage 1.83 89.86 10/12/2006 UDREN LAW OFFICES So ansW. r yy. -- -? R. Thomas K i.ne Sheriff of Cumberland County Sworn and subscribe to before me this day of A. D. 0 U16 M SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: BLASCHAK STACY M but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On October 12th , 2006 , this office was in receipt of the attached return from YORK* Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 ,, ,, mow....,. 10/12/2006 UDREN LAW OFFICES Sworn and subscribe to before me this day of So an R. Thomas Kline Sheriff of Cumberland County A. D. zl? I-fl lv 43 ?- a d _;o' CZ) Cf'+ C;'S t 1 1 ?v? r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Eric J. Blaschak :NO. 06-4854-Civil Term Stacy M. Blaschak De f endant (s) To: Eric J. Blaschak 11 Morari Drive Dillsburg, PA 17019 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered "against you t above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin I I Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY_ Mark J. Udren, Esquire At this telephone number: 856-669-5400 J e 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 Mortgage Electronic ICOURT OF COMMON PLEAS Registration Systems, Inc. ?CIVIL DIVISION 9990 Richmond :Cumberland County Houston, TX 77042 Plaintiff :MORTGAGE FORECLOSURE V. Eric J. Blaschak NO. 06-4854-Civil Term Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Eric J. Blaschak and Stacy M. Blaschak 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 $142,861.57 Interest Per Complaint 2,453.49 From 8/22/06 to 11/10/06 Late charges per Complaint 99.86 From 8/22/06 to 11/10/06 TOTAL $145,414.92 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has ben given in accordance with Rule 237. 1, a copy, of which is attached h reto. P. C. M rx J. oaren, ESQUIRE torney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : ??L f L?.dCj(o PRO OTHY 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 Mortgage Electronic Registration Systems, Inc. Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Eric J. Blaschak Stacy M. Blaschak De f endant (s) To: Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 NO. 06-4854-Civil Term NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you ' n the above proceeding as indicated below. X Judgment by Default Prothonotar Money Judgment Judgment in Replevin Judgment for Possession ff/it olo Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY- Mark J. Udren Esquire At this telephone number: 856-669-5400 t.. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 9990 Richmond Houston, TX 77042 Plaintiff V. Eric J. Blaschak Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854-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) Eric J. Blaschak and Stacy M. Blaschak 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 $142,861.57 Interest Per Complaint 2,453.49 From 8/22/06 to 11/10/06 Late charges per Complaint 99.86 From 8/22/06 to 11/10/06 TOTAL $145,414.92 I hereby certify that (1) the addresses of the Plraintiff and Defendant are as shown above, and (2) that notice has ben given in accordance with Rule 237.1, a copy of which is attached h reto. P. C. DAMAGES ARE HEREBY ASSESSED AS DATE: ifl V • VlAl l?Li, ?YViivL.l torney for Plaintiff INDICA PRO ROTHY WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4854 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From ERIC J. BLASCHAK AND STACY M. BLASCHAK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $145,414.92 L.L. $.50 Interest FROM 11/11/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $30.29 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,543.93 Atty's Comm % Atty Paid $255.06 Plaintiff Paid Due Prothy $1.00 Other Costs Date: NOVEMBER 16, 2006 (Seal) 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 Curtis ,R. Long, ro otary By: Deputy Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Eric J. Blaschak Stacy M. Blaschak De f endant (s) NO. 06-4854-Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $145,414.92 Interest From 11/11/06 3,543.93 to Date of Sale 3 7 07 Ongoing Per Diem of 30.29 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. TTORNEY FOR PLAINTIFF n u ter, ? t ?? ?x i • '? 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 Mortgage Electronic Registration Systems, Inc ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff V. Eric J. Blaschak Stacy M. Blaschak MORTGAGE FORECLOSURE NO. 06-4854-Civil Term Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties,bf 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to / authorities. FILES, P. Mark J. Udren, ETTQUIRE ATTORNEY FOR PLAINTIFF -Ti It UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. V. Plaintiff Eric J. Blaschak Stacy M. Blaschak Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854-Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 420 North Enola Drive, (East Pennsboro Township) Enola, PA 17025 1. Name and address of owner(s) or reputed Owner(s): Name Address Eric J. Blaschak Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 11 Morari Drive Dillsburg, PA 17019 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 East Pennsboro Township 98 South Enola Drive Enola, PA 17025-2796 4. Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic 9990 Richmond Registration Systems, Inc. Houston, TX 77042 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants Address 420 North Enola Drive (East Pennsboro Township) Enola, PA 17025 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 f unsworn falsification to authorities. LAW OFFICES, P.C. DATED: November 10, 2006 MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be cn ,. Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854-Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. V. Plaintiff Eric J. Blaschak Stacy M. Blaschak To: Eric J. Blaschak 11 Morari Drive Dillsburg, PA 17019 Your house (real estate) at 420 North Enola Drive, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,414.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 CD :.S - r>> t _' {,? .?j ?e UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. V. Plaintiff Eric J. Blaschak Stacy M. Blaschak Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-4854-Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 Your house (real estate) at 420 North Enola Drive, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,414.92, 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.) f YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD 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 Fri cT _ V., SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: BLASCHAK ERIC J but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On October 12th , 2006 , this office was in receipt of the attached return from YORK Sheriff's Costs: So ansW r Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas K ine -- Dep York County 51.03 Sheriff of Cumberland County Postage 1.83 89.86 ? in/1P/OC 10/12/2006 UDREN LAW OFFICES Sworn and subscribe to before me this day of A. D. SHERIFF'S RETURN - OUT OF COUNTY i CASE NO: 2006-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS BLASCHAK ERIC J ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: but was unable to locate Her deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On October 12th , 2006 , this office was in receipt of the attached return from YORK' Sheriff's Costs: So any r -' Docketing 6.00 Out of County .00 Surcharge 10.00 R' Thomas Kline .00 Sheriff of Cumberland County .00 16.00 ? io f IP'o L Q4 10/12/2006 UDREN LAW OFFICES Sworn and subscribe to before me this day of A. D. I OF 2 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 ?H SERVICE CALL (717) 771-9601 SHERIFF SERVICE W' T MTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEA TYPE ONLY LM 1 THRU 12 DO MOT DETACH ANY COPES 1 PLAINTIFF/S/ Mortgage Electronic Registration Systems Inc 3. DEFENDANT/S/ Eric J. Blaschak et al 2 COURT NUMBER 06-4854 civil _ 4. TYPE OF WRIT OR COMPLAINT N 0 T & Notice & Complaint i n C I M F Mortgage Foreclosure SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Eric J. Blaschak 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO, CITY, BORO. TVW. STATE AND ZIP CODE) AT 11 Morari Drive Dillsburgr PA 17019 7. INDICATE SERVICE' U PERSONAL U PERSON IN CHARGE U DEPUTIZE L.) ERT MAI U 1ST CLASS MAIL U POSTED U OTHER NOW September 26, 2006 I, SHERIFF OF COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute this Wrja? Lac) r110e return ther ording to law. This deputization being made at the request and risk of the plaintiff. w- N RILF ns: 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING.,$ 1"96 F COUNTY Clanberland ADVANCE FEE PAID BY ATTY. Please mail return of service to Cmberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watcMnan, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE MARK J. U D R E N , ESQ. 10. TELEPHONE NUMBER 11 DATE FILED WOODCREST CORPORATE CENTER, CHERRY HILL, NJ STE.200 1856-669-540, 9-20-2006 R'-.7[IVl7•rvV71G['Vr'A[RVII?C`l7VrP PU rv~t: AIVU AUUKtaa ULLUVT (i nos area must oe completed t notice is to oe mated). CUMBERLAND CO. SHERIFF SPAN BELOW FOR USE OF THE SHERIFF - DO NOT IIY TMS LME 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaint as indicated above. Y C S O M J M C G I L L 19/27/2006 110/20/2006 16. NOW SERVED: PERSONAL ( RESIDENCE ( POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 h4qeby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) NOT SHOWN 16. W44D= DI UAj SERVED /LIST ApDR S; ERE IFV a "A ABOVE (Relationship to w,? 19. oDateC-of Service 20 Time f eFf7 A S Da Ti Miles Int. Date Time Miles Int Date Time Miles Int. Date Time Milesk* Time Miles Into l Dale Ti`me7? M,d7esP Int. 22. 23. Advance Costs $100 00 24 Service Costs 25 N/F 2? Mileage 27. 1 28. Sub 7 29. Pound 30 t4olary 31. Surclg. 32. Tot oats 33 Costs Due Re ChTck . oC 3 W6 5 3 I? 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. Found 39. Total Costs 40 Costs Due or Refund AFF 61H RMED and s bscribed t 41 b thi ( ANSWERS I . u o o me e s day _ n f 44. Signal e of Dep. iR !3 .3 45. DA -.r' ?X. RY 46. Signatur of Yank / DATE NOTARIAL SEAL Count S LISA L. BOWMAN, NOTARY PUBLIC WILLIA HOS , SHERIFF 10/6/06 CITY OF YORK, YORK COUNTY MY COMMISSION EXPIRES AUG. 12, 2009 46 Signature of Foreign Count Sheriff 49 DATE 50. 1 AC SIGNATURE 51 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriffs Office 1 ht :1 d LZ d3S WU ] 1? F 2 f COUNTY'OF YORK .OFFICE OF THE SHERIFF SE R )I7 E A L 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE MTIMTIOM TYPE ONLY 1 THRU 12 PLEASE UNE PROCESS RECEIPT and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES 1 PLAINTIFF/S/ 2 COURT Ng BER Mortgage Electronic Registration Systc-ns Inc 06-4 54 civil 3 DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT N O"T & Eric J. Blaschak et a1 Notice & Complaint in C I M F Mortgage Foreclosure SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED. OR SOLD Eric J. Blaschak 6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO, CITY, BORO. TWP. STATE AND ZIP CODE) AT 11 Morari Drive Dillsburg, PA 17019 7 INDICATE SERVICE O PERSONAL U PERSON IN CHARGE U DEPUTIZE JaSRLMA14 a LUST CLASS MAIL U POSTED U OTHER NOW September 26, , 20 06 I, SHERIFF OF C COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute this-,,X",-9 ?d a?i ake return t ccording to law. This depuliz?ateon being made at the request and risk of the plaintiff. ? a• SKR!IFF OF MIM COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST 19 EXPEDITING SERVICE CUnberlaiO OUT of COUNTY ADVANCE FEE PAID BY ATTY. Please mail return of service to Cumberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction. or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY /ORIGINATOR and SIGNATURE MARK J. U D R E N , ESQ. 10. TELEPHONE NUMBER I 1 DATE FILED WOODCREST CORPORATE CENTER, CHERRY HILL, NJ STE.200 1856-669-5400 18 - 2 0 - 2,00 6 j0 NAME AND ADDRESS BELOW: (This area must be completed it notice is to be nwled). *jjE CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SWJWF - DO NOT iAfMM SMOW TM L.IPE 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaintas mdicatedabove. YCSO MJ MCGILL 19/27/2006 10/20/2006 16. HOW SERVED. PERSONAL (V) RESIDENCE ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. O 1 h eby cerlify and return a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks below.) 18. AND TIT D DU SERVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to 19. Dale of Service 20 Time of Service Safi?t}roc y p,lc5c?a I{.. 4,?.h r 1. A EMPTS Da Ti jNfili} Int. Date I Time I Miles I Int I Dale I Time I Miles I Int I Date I Time I1/ies I Int. I Dafi? I Time I Miles I Int. I Date I Time I Miles I Int 22 REMARKS: w 23. Advance Costs Service Costs 25 N/F Mileage 27 Postage 28 Sub Total 29. Pound 30 Notary 31. Suroltg. 32 Tot. Costs 33 Costs Due or Refund Check No. ioo.oo 24 26c? o3 G 9.00 .5 1,63 ??.??? )?2_2 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38 -_ Mdea0PoslagdN0 Found 39. Total Costs 40 Costs Due or Refund 41. AFFIRMED and subscribed to before me this SO ANSWERS 4 - f r, ? 44. Signa re of L? / , '4 1 y, ! -3 45. p TE a?- 42, day of . 2043 Dep. S eriR - ` dti' NOTARY 46. Signatu'W of York 47 DATE County Shenrt q .1 ?1)r+l"1016 48 Signature of Foreign 49 DATE County Sheriff 50. I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 51 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY -Sheriff's Office 4. BLUE - Sheriffs Office 2 OF 2 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST.,YORK, PA 17401 SERVICE CALI. (717) 771-9601 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LMT 1 THRU 12 DO NOT DETACH ANY COPES 1 PLAINTIFFIS/ 3. DEFENDANTISI Eric J. Blaschak et al 2 4 TYPE OF WRIT OR COMPLAINT N O T & Notice and Ccmplaint C I M F SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Stag M Blaschak 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO. CITY, BORO, TWP. STATE AND ZIP CODE) AT 11 Ml rigri Drive Di 11 sh11rg, PA 17019 7. INDICATE SERVICE U PERSONAL U PERSON IN CHARGE U DEPUTIZE U ERT MA U 1ST CLASS MAIL U POSTED -I OTHER NOW September 26 20 06 I, SHERIFF OF COUNTY, PA do hereby dep i the sheriff of York COUNTY to execute t r1 turr f. Ording to law. This depubzation being made at the request and risk of the plaintiff., SHERIFF OF COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITIN%ffT" ff F COUNTY Cw e ADVANCE FEE PAID BY ATTY. Please mail return of service to Cumberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATU94 A R K WQODCREST CORPRATE CENTER 111 WOODCREST J. UDREN, ESQ. ROAD STF 200 10. TELEPHONE NUMBER 111. DATE FILED ' ' 1856-669-4500 4.4& I S •' ? C ^ ^ l4^ 906 ADDRESS BELOW: (This area must be completed d notice is to be mailed) CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SHEFdFF - DO NOT WWM BELOW THIS LM 9/20/200 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaint as indicated above. M J M C G I L L Y C S O [1/27/2006 110/20/2006 16. HOW SERVED: PERSONAL ( RESIDENCE ( POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks below.) 18 AND TITL D UAL S RVED ) LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Se ice C cy $Ila5C,"n0,?, ?0 S dG 3,'6 ;M 21. ATTEMPTS TinWj Miles Int. Date Time Mlles Int Dale Time Miles Int Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. 22. 23. Advance Costs 24 Service Costs 25 N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30 Notary 1 31 Sur----. 32 Tot. Costs 33 Is Oue or Refund Check No 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cent. Mite PoslagrJNol and 39 Total Costs 40 Costs Due or Refund 41 AFFIRMED ib d b d f ANSWERS . an scr su e to be ore me this ON OF 1pn? 42 day 44. Sgnatur 45. D pp NOTARIAL SEAL"/ NOTAR 46. Slgnatu of York ?a DATE LISA L. BOWMAN NOTARY PUBLIC County Shdnq , , CITY OF YORK, YORK COUNTY WILLIAM OSE SHERIFF 10/6/06 MY COMMISSION EXPIRES AUG. 12, 2009 48 Signature of Foreign 49 DATE County Sheriff 50. IAcRNUVVLt JUt KtGtlrI OF I Mt5MtKlfI "S Kt1UKN 51UNAIUKt 151 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing AuBlority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Shenfrs Office CQTY OF YORK OFFICE OF THE SHERIFF SERVICE(717) 7719601[, 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LIB 1 THRU 12 DO NOT DETACH ANY COPIES 1 PLAINTIFF/S/ - 2 CO ,RT NUMBER Mortgage Electronic Registration Systems Inc O6? 4854 civil 4 TYPE OF WRIT OR COMPLAINT 3. OEFENDANTIS/ Notice- and CcImplaint Eric J. Blaschak et al C I M F Mnrtrraeiuy Fnr?+r1 narra in SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED. OR SOLD Stacy M. Bldschak 6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO, CITY. BORO, TWP. STATE AND ZIP CODE) AT 11 Morari Drive Dills g, PA 17019 7 INDICATE SERVICE U PERSONAL U PERSON IN CHARGE U DEPUTIZE E T L U 1 ST CLASS MAIL U POSTED 'J OTHER NOW September 26 20 06 I, SHERIFF OF COUNTY, PAA do hereby deputize the sheriff of York COUNTY to execute this f! make return -according to law. This deputip4ion being made at the request and sk of the plaintiff. r 71 7 f' > S RdFF O COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITIN er b"VIFF COUNTY r' Al WANCE FEE PAID BY ATTY. Please mail return of service to Ctmberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN Any dep shenff levying upon or attaching any property under within writ may leave same without a watchman, in cu3tody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any 1osa, destruction: or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and, SIGNATUIKA. R Kf J . U D R E N , E B Q , 10. TELEPHONE NUMBER 11 DATE FILED W60DCREST CORPRATE CENT£R,111 WOODCREST ROAD, STE, 200 8a6-669-4500 9H D C D ADDRESS BELOW: (This area must be completed if notice is to be mailed) )UMA CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SHOW 00 140T. WRITE BELOW ,TM twE 11 1 acknowledge receipt of the wrd 14. DATE RECEIVED 15- Expiration/Hearing Date or complaint as indicated above. M d M C G I L L Y C S O / 2 7/ 2 0 0 6 110/20/2006 16. HOW SERVED PERSONAL (73" ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 hereby certify and return a NOT FOUND because I am unable to locale the individual, company, etc named above. (See remarks below.) ttt AND TITLE DrUAL S RVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19 Date of Service 20 Time of SWvi 21 . ATTEMPTS D rime Miles Int. Date Time Miles Int. Date Time Miles Int Date Time Miles Int. Date Time Miles Int. Date Time Miles Int- ' , 22. :- 23. Advance Costs 24 ServiceCosts 25 N/F 26. Mileage 27 Postage 28. Sub Total 29. Pound 30 Notary 31 . Surchg. 32. Tot. Costs 33 Costs Due or Refund Check No 34. Foreign County Costs - 35. Advance Costs 36 Service Costs 37. Notary Cert. Mileage/Postage/Not ound 39 Total Costs 40 Costs Due or Refund I ANSWERS 41. AFF RMED and subscribed to before me this L? j :;'Cy*? `/' 44. 45. O T1 y a 42 day _ 20 ) 43 r S t/ , fAR%/ NOTARY 46. of York f 1 2 ;r f . €, , ate. Count 7 DATE 4 y t'f' L I 1"I n0S;-'' SIIEf-"1E'[' 48 Signature of Foreign 49 DATE County Sherrill 1 50. t ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 151 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Isstang Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sherdrs Office Mortgage Electronic Registration Systems In The Court of Common Pleas of Inc. Cumberland County, Pennsylvania VS Writ No. 2006-4854 Civil Term Eric J. Blaschak and Stacy M. Blaschak R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Eric J. Blaschak and Stacy M. Blaschak, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. York County Return: And now, December 06, 2006 at 2:15 PM served the within Real Estate Writ, Notice and Description upon Eric J. Blaschak and Stacy M. Blaschak by personally handing to Stacy M. Blaschak, defendant and wife of Eric J. Blaschak, two true attested copies of the original Real Estate Writ, Notice and Description and making known to her the contents thereof at 11 Morari Drive, Dillsburg, PA 17019. So answers: William Hose, Sheriff of York County, PA. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 1124 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Eric J. Blaschak and Stacy M. Blaschak located at 420 North Enola Drive, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Eric J. Blaschak and Stacy M. Blaschak, by regular mail to their last known address of 11 Morari Drive, Dillsburg, PA 17019. These letters were mailed under the date of January 16, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Mark Udren. Sheriff s Costs: Docketing 30.00 Poundage 121.13 Advertising 30.00 Posting Handbills 30.00 Mileage 14.08 Levy 30.00 Surcharge 40.00 Prothonotary 1.00 Law Library .50 Postpone Sale 20.00 / 935- let" Out of County 9.00 York County 51.03 Share of Bills 16.83 Law Journal 557.00 Patriot News 488.72 $1,439.29 7 So Answers: R. Thomas Kline, Sheriff BYC G Real Estate ergeant v UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. :CIVIL DIVISION €Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Eric J. Blaschak NO. 06-4854-Civil Term Stacy M. Blaschak Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 420 North Enola Drive, (East Pennsboro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Eric J. Blaschak Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 11 Morari Drive Dillsburg, PA 17019 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 East Pennsboro Township 98 South Enola Drive Enola, PA 17025-2796 4. Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic 9990 Richmond Registration Systems, Inc. Houston, TX 77042 S. Name and address of on the property: Name none every other person who has any record lien Address 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants 420 North Enola Drive (East Pennsboro Township) Enola, PA 17025 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. LAW OFFICES, P.C. DATED: November 10, 2006 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be Address MARK J. UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic :COURT OF COMMON PLEAS Registration Systems, Inc. 'CIVIL DIVISION :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Eric J. Blaschak NO. 06-4854-Civil Term Stacy M. Blaschak Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Eric J. Blaschak 11 Morari Drive Dillsburg, PA 17019 Your house (real estate) at 420 North Enola Drive, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 7, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,414.92, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (see notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL TADSL' CERSAIW lots, paroai or pieces of land situate in Saint P-Sbeso township. CUMbsrlRRd COMM PenasYlvevia, Marc particularly bounded and dmeeribed as follows, to wit: TAA= 100. 1: - Utoete am the lest side at Altoona Road, boandad an the Rorth by Lot No. 97 on Plan of lots hereinafter taotiaaed; on tha zaat by the lfestato sift of an allay (tae abandoned); an ape acoth by Lot ,fa. 94 an Plan Of Lots bmreinafler xsft oad: and as the Mat by Altoona Reed. COIMMUM in front on Altoona Reed one hundred feet, mod extsadliq in 4Fth at mtitvm width throwghout Lrstuardly one hundred fifty feet to the eestera aide Of a fazmer 15 foot alley faov abandamM in the seat. TAMN Lots foe. 95 and 96 as Plan of Late knowv as Shady Lane, said plus being doly recorded is the Cumberland County Recorder's office in Plan look No. i, Page 92. Said lots being ieproved and new dnabmr'ed trod known as 420 Aorth unola crave. Enels, eeenlylvauis.. TSSS MU !.s not intended to tbvey wW interest in at to the said Absuulnned fifteen toot alley to the rmar of the lot. 22h= No. 2 - .l1L(=uQ at s point an tom *"can right-ofwsp line o! Old Alruaam Avenue (as shown an the Plan of part of shady Lane heselahetore -entiened) where it would inte=sct with the projected Raetu= lot line Of Lot No. 95 on the aforssetd Plano thence won said Projected lot Line South forty-lie (45) degrees forty-live )45) mioates West twenty-firs {25) fast, move or lean, to the MRatera right-of-way live of north Ynols Drive (L.R. 21015211 thraeaoalang the $astara tight-of-way line of Ao%IA EnWA Drive is a Ro=taally Cireati,on nivety MO fast, tore of less, to the point of iatemoccSOR of the Sssterm right-cf-may of forth Laois Drive with the llmetara right-of-way UAW of Old Altoona Avenue; thecae South fusty-lour (44) dipraes titteea Ml -mates last, sloaq the festarn v&q%t--ot-way line of old Altoona A-"Us, almety (00) test, more or lesa, to the pwjectsd aaeterO lot line of Lat so. 93 an the AazatinD,dere refeased to plan, the point and Plaeea at Lmmm. Dx=6 a triangTlm shaped flat of land Ding between the Reasesa Lim of Old Altoona nreane (now abandoned) and the !astern linalor forth ROola Drive. OuDSA AM SOIa= to ail restriotioas, reservations end aaeees+cts of Accord. BEING KNOWN AS: 420 NORTH ENOLA DRIVE, (EAST PENNSBORO TOWNSHIP) ENOLA, PA 17025 PROPERTY ID NO.: 09-13-1002-188 TITLE TO SAID PREMISES IS VESTED IN ERIC J. BLASCHAK AND STACY M. BLASCHAK, HUSBAND AND WIFE BY DEED FROM JAMES E. HOMER, JR. AND ESTER L. HOMER, HUSBAND AND WIFE DATED 09/24/04 RECORDED 09/29/04 IN DEED BOOK 3727 PAGE 211. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 064854 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From ERIC J. BLASCHAK AND STACY M. BLASCHAK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $145,414.92 L.L. $.50 Interest FROM 11/11/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $30.29 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,543.93 Atty's Comm % Atty Paid $255.06 Plaintiff Paid Due Prothy $1.00 Other Costs Date: NOVEMBER 16, 2006 (Seal) Curti . Long, P otary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 56 On November 30, 2006 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 420 North Enola Drive, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2006 Bye n Real Est a Sergeant LE .? d 1 Z AGN g001 s 'A THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY Sworn to and sc bedsore me this 28 X1.0 §9LVAt-M_- S A L E #56 COMM Notarial Seal Terry L. Russell, Notary Public City Of Hards rg, to CoUnty y commi ' n Ex pi ne 6, 2010 -.., -Piation of Notgfies NOT CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 u AU WmtM a p of mmros ip, lard ?e?e m Eat Pb. Peo"jha ' more pftubdy *m* aad de cftd w* ion _e gtF J* of Altaam IM *? of I o? haei araaaeed; atd on ate *kst Road io ftw on AW= .Road oft fat, and ea it1h d oaiforM fiftr, w1oik ?6frfoot (sa?v aha?ilaioa? ?aa the timrt lAft sm 95 sod % on Plm of LOU Iro n its 5Bdy Lane, ';pad Ptah, be* fitly Am the ?cm" Pr 9z sw 10i Ytlitik ? • ' ye ?r td AK ?: at t ,? the Vleaedii` s et Ewa Avmk* *"m 0 titepl of pa of Rudy Lie c of 10I 95 of ft tl* 60me along said 1iU io dd lat Jilt •gvA'ttW-free (45) fay 'd t$aalt Drive " 210S2p, moetrfA) feet, row or ham, to 6o pow of iareram*^of009poop ' of North of QdAirooat Avaxm? lhimaefiNW fom (44) "M)mm (M MwuW &#{ aimg die Aver d to Im Brojb* F, - w lice of tat Na 95 OR dte betrinititce> *gam, d?a Pant ted Puce of B1 WAk *00 a 4ofl Pitt of Iced lying the Mepmt NoWa lAbo m AftW (ems , atdl dale ed101s ?e sf NoAh UN 'AW AM6M fR reswclions, North. Fmola Drive NdL)hk 17025_ Anc I PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 26, February 2 and February 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Co , Editor SWORN TO AND SUBSCRIBED before me this 9 day of F NOTARIAL SEAL ' =. '?NY^ER, Notary Public Sore, Cumberland County N s3 E1111 s March 5, 2099 - .... ..... ... lam. REAL ESTATE SALE NO. 56 Writ No. 2006-4854 Civil Mortgage Electronic Registration Systems, Inc. vs. Eric J. Blaschak and Stacy M. Blaschak Atty.: Mark Udren ALL THOSE CERTAIN lots, par- cel or pieces of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more par- ticularly bounded and described as follows, to wit: TRACT NO. 1:-Situate on the East side of Altoona Road, bounded on the North by Lot No. 97 on Plan of Lots hereinafter mentioned; on the East by the Western side of an alley (now abandoned); on the South by Lot No. 94 on Plan of Lots here- inafter mentioned; and on the West by Altoona Road. CONTAINED in front on Altoona Road one hundred feet, and extend- ing in depth of uniform width throughout Eastwardly one hundred fifty feet to the Western side of a former 15 foot alley (now aban- doned) in the rear. BEING Lots Nos. 95 and 96 on Plan of Lots known as Shady Lane, said Plan being duly recorded in the Cumberland County Recorder's Of- fice in Plan Book No. 1, Page 92. Said lots being improved and now numbered and known as 420 North Enola Drive, Enola, Pennsylvania. THIS DEED is not intended to convey any interest in or to the said abandoned fifteen foot alley to the rear of the lot. TRACT NO. 2-BEGINNING at a point on the Western right-of-way line of Old Altoona Avenue (as shown on the Plan of part of Shady Lane hereinbefore mentioned) where it would intersect with the projected Eastern lot line of Lot No. 95 on the aforesaid Plan; thence along said projected lot Line South forty-five (45) degrees forty-five (45) minutes West twenty-five (25) feet, more or less, to the Eastern right-of-way line of North Enola Drive (L.R. 21052); thence along the Eastern right-of- way line of North Enola Drive in a Northerly direction ninety (90) feet, more or less, to the point of inter- section of the Eastern right-of-way of North Enola Drive with the West- ern right-of-way line of Old Altoona Avenue; thence South forty-four (44) degrees fifteen (15) minutes East, along the Western right-of-way line of Old Altoona Avenue, ninety (90) feet, more or less, to the projected Eastern lot line of Lot No. 95 on the hereinbefore referred to plan, the point and Place of BEGINNING. BEING a triangle shaped Plot of land lying between the Western line of Old Altoona Avenue (now aban- doned) and the Eastern line of North Enola Drive. UNDER AND SUBJECT to all restrictions, reservations and ease- ments of Record. BEING KNOWN AS: 420 NORTH ENOLA DRIVE, (EAST PENNSBORO TOWNSHIP) ENOLA, PA 17025. PROPERTY ID NO.: 09-13-1002- 188. TITLE TO SAID PREMISES IS VESTED IN Eric J. Blaschak and Stacy M. Blaschak, husband and wife by deed from James E. Homer, Jr. and Ester L. Homer, husband and wife dated 09/24/04 recorded 09/29/04 in Deed Book 3727 Page 211. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 9990 Richmond Houston, TX 77042 Plaintiff V. Eric J. Blaschak Stacy M. Blaschak 11 Morari Drive Dillsburg, PA 17019 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-4854-Civil Term PRAECIPE TO MARK SETTLED., DISCONTINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED-AND JUDGMENT SATISFIED, upon payment of your costs only. Mark J. Udren, Esquire UDRE W OFFICES, P. C. Attorney for Plaintiff DATED: November 8, 2007 -n } ( -in _ f c-n is