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
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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
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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
?'
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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
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