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HomeMy WebLinkAbout06-5113UDREN LAW OFFICES, P.C. SY: Nark J, Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 com Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. Q~'~J'/~ COMPLAINT IN MORTGAGE FORECLOSURE e~~~L~r~ 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. YOII SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORNATION ABOUT HIRING A LAWYER. IF YOII CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE NAY BE ABLE TO PROVIDE YOII WITH INFORNATION ABOUT AGENCIES THAT NAY 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 hen demandado a usted en la Corte. Si usted quiere defenderse de ester demander expuestas en las paginas siguientes, usted tiene veinte (20) dies de plazo al partir de la fecha de la demanda y la notification. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defenses o sus objeciones alas demander en contra de su persona. Sea avisado que si usted no se dafiende, la torte tomara medidas y puede continuer la demanda en contra suya sin previo aviso 0 notification. Ademas, la torte 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 pare usted. LLEVB ESTA DSMANDA A IIN ABOGADO INMEDIATAMENTE, SI NO TIENE ASOGADO O SI NO TIENE EL DINERO SIIFICIBNTE DE PAGAR TAL SERVICIO, VAYA 8N PERSONA O LLAMS POR TELEFONO A LA OFICINA CIIYA DIRECCION 3E ENCIIENTRA ESCRITA ASAJO PARR AVSRIGVAR DONDE SE PIIEDB CONSEGVIR 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 Gave mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J• Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856)669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: First Franklin Financial Corporation Assignments of Record to: Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 2427 Rolling Hills Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 2/28/03 DATE RECORDED: 3/7/03 BOOK: 1799 PAGE: 2424 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 8/22/06: Principal of debt due $224,697.01 Unpaid Interest at 9.375 from 6/1/05 to 8/22/06 (the per diem interest accruing on this debt is $57.71 and that sum should be added each day after 8/22/06) 28,909.51 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $406.72 and that sum should be added on the first of each month after 8/22/06) 12,940.95 Late Charges f 5110 13 . (monthlyy late charge o should be added in accordance with the terms of the note each month after 8/22/06) 2,125.00 NSF Fees 20.00 Expense Advances 1,100.00 Property Inspection. 103.35 Attorneys Fees (anticipated and actual to 5~ of principal) 11,234.85 TOTAL $281,735.67 * This interest rate is subject to adjustment ae 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 $281,735.67 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN piece, parcel, and lot of land situate on the east side of Rolling Hills Drive in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, being known as Lot #91 on the Final Subdivision Plan of Bowmans Hill -Phase 3, recorded In the Office of the Recorder of Deeds In and for Cumberland County, Pennsylvania In Plan Book 70, Page 39, being more fully bounded and _ described as follows, to wit: BEGINNING at a point on the eastem dedicated right-of-way line of Roiling Hills Drive at the dividing line of Lot #90 and Lot #91, herein described; thence by said dividing line, south 51 degrees 49 minutes 08 seconds east, a distance of 173.91 feet to a point at Parcel "F"; thence by said Parcel "F", south 12 degrees 40 minutes 23 seconds west, a distance of 50.21 feet to a point at the dividing line of Lot #1D0 and Lot #91, herein described; thence by said div[ding Ilse, south 84 degrees 57 minutes 31 seconds west, a distance Of 88.62 feet to a point at the dividing line of Lot #92 and .Lot #91, herein described; thence by said dividing line, north 49 degrees 32 minutes 28 seconds west, a distance of 125.29 feet to a point on the eastem dedicetetl right-of-way line of Rolling HIIIS Ar1ve; thence by said right- of-way line by a curve ko the left having a radius of 325.00 feet and an arc distance of 69.64 test; the chord of said curve being, North 34 degrees i9 minutes 12 seconds East, a distance of 69.51•teet to a point, the place of BEGINNING, CONTAINING 14,637.3, squal-e feet, more or less. UNDER AND Sl/BJ€CT, NEVERTNELE.~S, to ~ 25 feet slope/vegetation easement along the eastern lo't line and all easements and Pestrictions of record. ~ V.Y V'l GIY • - January 11, 2005 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 INIPORTANCIA, PUES 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 I'IIVANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNER~S EMERGENCY MORTGAGE ASSISTANCE PROGRAMD EL CURL PUEDE SALVAR SU CASA DE LA PERDH)A DEL DERECHO A REDIMIR SU HII'OTECA. EXHIBIT A Page 1 0[ 6 HOMEOWNER'S NAME(S): Mahesh Kumar _ Derry A. Hoffman-Kumar PROPERTY ADDRESS: 2427 Rolling Hills Drive Mechanicsbure, PA 17055 LOAN ACCT. NO.: 1044075319 ORIGINAL LENDER: Fitst Franklin Financial Corporation _ CURRENT LENDER: Wells Fafyo Bank Minnesota, NA HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOTT MAY RF. F.T,TC.TRi.F. FOR FTNANf`TAT, ASSTfiTANCF. WHTCH (`AN CAVF, YOITR HOMF. FROM FORF.C.T.OSTTRF. AND HF.T,P YOTT MAKF. FTTTTTRF. MORTC A(:F. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSLSTANCE ACT OF 1983 (THE DACT~), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: 1F YOUR DEFAULT HAS BEEN CAUSED BY CIItCUMSTANCES 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 FORE( T.OCTTRF, __ 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-faceLl meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THTC MF.F.TTN(3 MTTCT O[`C'fiR WTTHTN THF. NEXT (~ nAYC_ 1F VOTT n() N(1T APPT V FnR FMT:T?(:FNf`V MnRTr:ent: CONSTTMF.R CRF.TITT f'OTTNCF.T.TNf: A(IF.N['TF.S __ 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. Thr namrc_ artrlrecarc and trlPnrhnnP. nnmhPrc of decigDaterl cnncnmer cn dit cnnnceling agenriec fnr the rnnntTin ~~hirh the mr~e 'c lnc^trd are cet fnrth at the Pnd of th;c Notice., It is oNy necessary to schedule one face-to-face meeting. Advise your lender immeciiatPlT of your intentions. APPT.iCATTON FOR MORTRAGF, ASSTSTAN('F. __ 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 6 face- taface meeting. YOU MIlaS.T 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. Al_F.N('Y ACTit1N -- 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 requirerrrents 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 PETPITON 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.) NATITRF, nF THE DF.FAili.T -- The MORTGAGE debt held by the above lender on your property located at: 2427 Rolling Hills Drive Mechanicsburg, PA 17055 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 $1624.39 for November 1,2004 Thru Tanuarv 1, 2005 = $4873.17 Monthl~Late Ch es of $51.21 for November 1,_2004 Thru December 1 2004 = $162.42 __ Other charges (expla~temize): Other Fee=$75.00 Procerty Ins_ e~ction- 7.95 - TOTAL AMOUNT PAST DUE: ___ ___ 4571 R 54 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Dn not rtes if not applirahlP): LYLA HnW T<7 i'iTRF. THF, nF.FAiTi.T __ 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 $$118,54, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. >'~ entc mnct ha made either h~•ach rachier'c rhrrk certified the k nr mnne,3+ nrdrr mad p~ahle and cent in• iTdren i.aw CAFfirnq, P.C. WruulcrPCt Cnrnnrate Center 111 Wtw~dcrect Rnwrl. Cnite 2M1 Ch. errv Hill, N7 ORIItI'1-3620 You can cure any other default by taking the following action .within THIRTY (30) DAYS of the date of th1S letter: (Tki not rtes if not ;tppliSahlr_l: ]y(A Page 3 0[ 6 iF VOiT i)O NOT (iTRF. THE DF.FAiTT.T - If you do not cure the default within THIltTY (30) DAYS of the date of this Notice, the lender intends M erereice its ~htc M n[relPra a the mnrt,~gg d~>'~ 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. ff 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 fnrerlnae n*.nn vnnr mn oaae~l nrnnerty_ iF THF, MORTf A(TF. iC FORF.Ci,OSF.D TTPON -- 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 Iender 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. Tf Y9n e..re the defanlt within the THiRTV ('illl DAY n~ri_rl^nn will not he ~gnined to R8y attorney's feet OTHER T.F.NDFR RF.MF.DiF'C _. 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 dischazged in banlauptcy without your having reaffitmed it, then lender cannot pursue this remedy. Ri(:HT TO f`iTRF. TFTF. DF.FAili.T PRIOR TO CHF.RiFF'C SAi.F. -- If you have not cured the default within the THIItTY (30) DAY period and foreclosure proceedings have begun, ;n» still have the rig r m nve the default and prevent the tale at and time ilp to one boor before th 4heriff c Cale Ynn ma~~ An en by ~yi~ the total amnnnt then asp t dnr 1n~n~ late nr other rhargec then dim, reasonable attnmg~' c fe~c and costs rnnneMed with the fnrerlncnre tale and and other costs ennnected with the SherifPe 4ale ac rifted in writino~y the 1 n_ cie~r anti h~ nerfnrmirtg anv other r~i,irementc ender rhr mnrt~ge, Cttrjng youC default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F.ARi.TFST POCCiRi.F. SHF.RiFF'C RAi.F. DA7T ._ It is estimated that the eazliest 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. Name of Lender/Servicer: Saxon Mo age Services, Inc. ____ ~__ Address: P.O. Box 161489 Fort Wo~TX 76161-1489 __ ~_ Phone Number: (50018749516 _ ~ ` Fax Number: N/A _ ____ _ __ ~ ~ Contact Person: Customer Service F.FFF.(T OF SHF.RiFF'R SAi.F. -- 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. ASSiTMPTTON OF MORTf.AAF. __ you may no[ transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, chazges 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 oP 6 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. UNess 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 aot an admission of liability on your part. Also, upon your written reyuest 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 inforfation 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 6 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 THII2D PARTY ACTING ON YOUR BEHALF. TO HAVE. THE MORTGAGE RESTORED TO THE SAME POSTITON 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 LAWSUTT 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 Cazlisle 301 G Street Cazlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams Counry Housing Authority 139-143 Cazlisle St. Gettysburg, PA 17325 (717)334-1518 FAX (717) 334-8326 Page 6 of 6 ~,~ ~.l ~> ~`. ~_ r~ v ~ ^~' r ~~ ~ . '~ ~ _~ ~~ _.', 1 ~ ~`„ (s\ \ i ~6 ('~ ~. m A ..C O p .D .0 ? S m m ay m Fenlags a S .S CertlM1eU Fae p O p [~ paean Reaispt FSa p p (EnEpar~prn AaquMad) ~ ~ ~ ~~~ r ~ r-l 7otai Poafa9e 8 Fep S O O ~ p O o -- r r. 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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 k~,erein is made subject to the penalties of 18 Pa.C.S. Section- 4904 ,relating to unsworn falsification to ~. authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. (~ t.!nnt V ••.. vl .,,,,, V "~ M V _ N ~ ..^^ 4 , ~ -t~ vJ i,. v'~ ,...} T -tt r~ ~ ~3 -~ ,r 'r -n ..~ ~~> `! W rn Y C r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 0$003-3620 856-669-5400 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06 s--4i~~^? Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: October 24, 2006 UDREN LAW OFFICES, P.C. BY: Ma k ~'. Udren, Esguire At~ orney for Plaintiff .. r / V E R T F I C A T I D 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 f rom 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 authori Date : S~_~' Title : Assistant Vice President Company: Saxon Mortgage Services Inc. as servicer on behalf of Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Mahesh Kumar Dory A. Hoffman-Kumar Loan #1044078319 MJU #04020152 ~ m c _-_ ~Y ~ -ca ~:x ~ ~..,.~ LJ rJ i _° ~- ~ ; c _.,. , .. : r- -r, f ~ ~l ~ ~ ~ } 1'~ C , `..° . ~„ 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its EMORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. s~~3 Mahesh Kumar ENO. 06~5~3 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Mahesh Kumar and Dory A. Hoffman-Kumar 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 $281,735.67 Interest Per Complaint 3,635.73 From 8/23/06 to 10/24/06 Late charges per Complaint 220.26 From 8/23/06 to 10/24/06 Escrow payment per Complaint 813.44 From 8/23/06 to 10/24/06 TOTAL $286,405.10 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN L.ji~ QFFICES , P . C . marx ~. u ren, ESQUIRE Attorn y or Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDI DATE : ~C ~ a({„~vs~ IIDREN LAW OFFICES, P.C. ATTORNEY FOR BY: Mark J. IIdrea, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITS 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFHl by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar Defendant (s ) T0: Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 DATE of Notice: October 12, 2006 IMPORTANT NOTICE PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County st~3 NO. 06-~3-3 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 TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER LISTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI LISTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O 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: PIIRSIIANT TO THE FAIR DEBT COLLECTION PRA ICES ACT, THIS LAW FIRM IS DEEMED TO B$ A DEBT COLLE OR THIS IS AN EMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL II D F THAT P OSE. s ar ren, squire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 IIDREN LAW OFFICES, P.C. ATTORN'SY FOR PLAINTIFF BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCRSST ROAD, SIIITS 200 CHERRY HILL, NJ 08003 856-669-5400 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar Defendant(s) TO: Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 DATE of Notice: October 12, 2006 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Sri 3 NO. 06 X39^ 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 IMPORTANTS 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 TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O 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 PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR 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 1 NOTICE: PURSIIANT TO THE FAIR DEBT COLLECTION PRACTICE ACT, THIS LAW FIRM IS DEEMED TO B8 A DEBT COLLECGTOR THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL 8E IISFOR THAT PIIRPOSE. o crest Corporate~Cen er 11 oodcrest Road, Suite 200 Cherr Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 0302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact C/O Fidelity National Foreclosure and Bankruptcy Solutions 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE sii3 NO. 0633 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: Mahesh Kumar Over 18 As captioned Unknown Dory A. Hoff Over 18 As captioned Unknown TiEle : Assist~nt~Vice President Sworn to and subscribed Company: Saxon or.gage Services, Inc. as servicer on behalf of Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact before me this ~~~ day ;.,:,• VALARIE CRAWFORD ~ P ~ ;, NOTARY PUBLIC • MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 o y u i ~~' `~ ~^ V `~ ~~„ ~ '^ sit:. ~ ( -~~ !_ C-' _ s- STZ ~,(' '~ ~_ ma'r` C:3 ~! ~-.,,: `f `.n u. H 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mort a e Services Inc as its :MORTGAGE FORECLOSURE g 9 Attorney-in-Fact 1270 Northland Drive, Suite 200 € Mendota Heights, MN 55120 Plaintiff v. Mahesh Kumar 5~~3 Dory A. Hoffman-Kumar `_ NO. 06~5~-33 Civil Term 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant(s) To: Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylv nia, u are hereby notified that a Judgment has been entered ai in the above proceeding as indicated below. ,C othonQ,t X Judgment by Default Money Judgment .Judgment in Replevin. 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. UdrenMark J. Udren, Es~ire At this telephone number: 856-669-5400 ,a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 € Mendota Heights, MN 55120 Plaintiff v. 5/13 Mahesh Kumar 5 N0. 06-rs~-3-3 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) To: Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pen ylv nia, ou are hereby notified that a Judgment has been entere a' in the above proceeding as indicated below. o how ry /~ X Judgment by Default ' Money Judgment Judgment. in .Replevin. 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, Esciuire At this telephone number: 856-669-5400 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 Wells Fargo Bank National `COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan =Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 € Mendota Heights, MN 55120 Plaintiff v. 5I~3 Mahesh Kumar NO. 06-~3'3" Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $286,405.10 Interest .From 10/25/06 7,733.14 to Date of Sale 3 7 07 Ongoing Per Diem of 57.71 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. rlarx ~ Udren, ESQUIRE ATTORN Y FOR PLAINTIFF (~ ~, ~t-- y .... `bA, {1A ~ _~y ,h ~ o ~c~~~~ '~. ~ o ' d ~ ~ ' ' ~ ' `a ~ 1 ...~'"~ ` r r~ ra ~ ° ~ G. cr- ~ - ' e~a'T` c ~ r~rt~ r-~ ~' ti't e r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5113 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR FIRST FRANKLIN MORTGAGE LOAN TRUST 2003-FFHl BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From MAHESH KUMAR AND DORY A. HOFFMAN-KUMAR (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 GARNISHEES} 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 $286,405.10 L.L. $.50 Interest FROM 10/25/06 TO DATE OF SALE 3/7/07 -ONGOING PER DIEM OF $57.71 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $7,733.14 Atty's Comm Atty Paid $135.68 Plaintiff Paid Due Prothy $1.00 Other Costs Date: OCTOBER 24, 2006 (Seal) Curti's R. Long, P nota By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan =Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its EMORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. S' ~ ~3 Mahesh Kumar NO. 06-3.3- Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s} C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LATE OFFICES, P.C. Mark ATTO .Udren, ESQUIRE 3Y FOR PLAINTIFF - - ,~ ~, `~'` s z .-e ~. Ga ~= :~ " r~ c: : ---~ ..~ , ` ;;> ,~- j ~ , -~-~; ~ ' _~-, .J _ .~ r~'3 ~ -`~ c~ .~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 4 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its =MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. $'i13 Mahesh Kumar € NO. 06-srr3-3 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s } AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact, 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: 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Unemployment 16th Floor, L&I Building Compensation Fund Harrisburg, PA 17121 4. Name and address of of record Name Plaintiff herein. 5. Name and address of on the property: Name none the last recorded holder of every mortgage Address See Caption above. 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 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 2427 Rolling Hills Drive (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: October 24, 2006 Ma Udren, ESQ. At rney for Plaintiff t UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF `1 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. S// 3 Mahesh Kumar €NO. 06-~33 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Your house (real estate) at 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 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 $286,405.10, 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. Xou 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.) 4 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. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THS OFFICE LISTED BELOW TO FIND OIIT WHERE YOII 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 N ~ ~ ~ ~ iy ~ ' ~ ~ " " ~ T 1 - ~ r ~ ~ _ ~~ ... ~.. - ,3 ? _ i _.. _r l..ri , ~ 6 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 ATTORNEY FOR PLAINTIFF 856-669-5400 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for '_CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFHl by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. s~~ Mahesh Kumar € NO. 06-~~-3~ Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Your house (real estate) at 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 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 $286,405.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICg 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. 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. 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 bIAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER ~ RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriffs 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 C ~; ~ c~ _ ~~~ ~ ~~ ~ ' ~r s. +,J = t`r. ~ -,y~ ~ ~1 ~ ~ . ,i E v jam: -i ~_. -^~ ,; ~~ ~` ) i ~:° ._ ~Y.. ,; ~~ -C ~ ~~ ^ . ~ ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-05113 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS KUMAR MAHESH ET AT MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUMAR MAHESH the DEFENDANT at 2045:00 HOURS, on the 19th day of September, 2006 at 2427 ROLLING HILLS DRIVE MECHANICSBURG, PA 17055 MAHESH KUMAR by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.68 Affidavit .00 ~ ~ ~,~ Surcharge 10.00 R. Thomas Kline .00 37.68 / 09/20/2006 !u Jy/UL MARK UDREN ,,f --~ Sworn and Subscibed to By: ~ ~ ~~ ~ C before me this day eputy She 'ff of A.D. SHERIFF'S RETURN - REGULAR ,~ w CASE NO: 2006-05113 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS KUMAR MAHESH ET AT MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon r,r n~nT n r'~/17]t7 T V/'1 L~L~MTTT the DEFENDANT at 2045:00 HOURS, on the 19th day of September, 2006 at 2427 ROLLING HILLS DRIVE MECHANICSBURG, PA 17055 by handing to MAHESH KUMAR, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service So Answers: .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16 . 00 ~/' 09/20/20 (\ ~n~~~b4 MARK UDR Sworn and Subscibed to By: before me this day of A.D. '. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan €Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its € Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. Mahesh Kumar ~"113 Dory A. Hoffman-Kumar €NO. ~ Civil Term 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the, time limits set forth by Pa Rule C.P. 3129. This Afgidavit is made subject to the penaltie ~8 Pa.,~.S. Section 4904 relatin to unsworn falsification o authori es. ~~ Dated: February 28, 2007 P.C. By; v Mark J. Udren, squire Attorney for P aintiff .. ~ ~~ aai~ ~ UDREN LAM OFFICES, P.C. ATTORNEY 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 FOR PLAINTIFF ~/~ 67 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for ;CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact €NO. 06-5133 Civil Term 1270 Northland Drive, Suite 200 € Mendota Heights, MN 55120 Plaintiff v. Mahesh Kumar Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Mahesh Kumar Dory A. Hoffman-Kumar PROPERTY: 2427 Rolling Hills Drive (Upper Allen Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING ~ %~1~'~ The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 7, 2007, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ,,~ EXHIBIT A .. ~, I~ im Vj LL O N a rp ~' ca -' ~i ~ ~ °v' acs a~~ N ~ O m ~ ll- ~- N [4 ao $ 6 ~ ~ Ems ~~ m __ ~v~~ ~ fl ~ R Q 7 '~~S Q; ~ 7 c ~ w ~~~~~~ 'OCa~o4V $. oN°- o °a @ ra ~ m a~ ~ ~ w V ~ S o ~'j "a~ d ~.' ~~ a~~ v m?o s~4 ,. ~O y" b J~ ., U a ~. ~ ~ -~ a~' T ~~-~j ~ w N`l~ ~~ ~~~.~ °~~~~ -'~-_ o ~~ ~~ ~,o~ $ c.r,,v~ ~~~~ ~ ~G C W ~ ~ G ~~p ~~E`~.~~ ~mRB,£s ~~ ~X ~~z~ ~a $w: ~ ~~, ~SQ~~tm~ffi ~~~~~~0¢ ~c Q~11 ~5~aa o sgs ~~ ~a 38~~ ~~~~g r D '. 3 . c~ ~ ~, ' . . . „ d=V`" ~ a d Q[]© ~ ~ r- r~ Y ° Q. z o ~ ~ O o 4 ui r 1- J U >- ~ z W ~ O V tom- ~ m ~ Q W ~ ~U N ui t~00~ N ~ U pG W u`.oyz Z ~ ~ pd u. t~ W 1 O p. pG -~ ~ v ~ p N 3WGx `joco~- `` go ~ ~x W Q~ W Z ~~ x ~x ~o 7~°U vL r ~ E~ t, a Z a ~ N ~ N ~ ~ N ~ tO Q ~ ~ ` ~ ~o 0. Q Q m J J QN =~ LL a`'.~ Zm w r N ~~ OZ ~ UaocQ~- co p fl- r- = o O ~ ~ N "" e~, C cn 4 OG m h'~- a ,~,~ ~ ac ~ v ~ m a4. Uv pN NQ ~g'' 1-~- r~ a9 tJJ W W N fl„ m L .J L d' b 7 G d C 8 Q 0 h 'd w Q v a .o a ~A z~ Iy~ Nm 1V I.L~ ~ ~ i og ~N~ as Z c ~ W ~~ a~ = d. r N ~ ~ o ,~ ~ ~ ~ EXh11BIT A a~ r L a~ r= o~a 0 ti N a ,, Wells Fargo Bank National Association, In the Court of Common Pleas of as Trustee for .First Franklin Mortgage Loan Cumberland County, Pennsylvania Trust 2003-FFH1 by: Saxon Mortgage Services Writ No. 2006-5113 Civil Term Inc. as its Attorney-In-Fact VS Mahesh Kumar and Dory A. Hoffinan-Kumar Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 13, 2006 at 2000 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Mahesh Kumar and Dory A. Hoffinan-Kumar, by making known unto Mahesh Kumar personally and husband of Dory A. Hoffman-Kumar, at 2427 Rolling Hills Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 1451 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 Mahesh Kumar and Dory A. Hoffman-Kumar located at 2427 Rolling Hills Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Mahesh Kumar and Dorothy Hoffman-Kumar, by regular mail to their last known address of 2427 Rolling Hills Drive, Mechanicsburg, PA 17055. These letters were mailed under the date of January 12, 2007 and never returned to the Sheriff s Office. So Answers: ~'.sa~~..~ ,~,,.i~~ r R. Thomas Kline, Sheriff BY ~YZ~ Real Estate eputy ~?~h11~31~ ~ N n c'~ ~~" ~ ~t'1 .4: .-G.. tJ !:: t j C....' -F ~~ ~..~{Eye "~1 ~_ ~~ ~~ ~1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Green Ride Leasing LLC is the grantee the same having been sold to said grantee on the 7th day of March A.D., 2007, under and by virtue of a writ Execution issued on the 24th day of Oct, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 5113, at the suit of Wells Fargo Bank N A Tr for First Franklin Mtg Loan Trust 2003-FFH1 by Saxon Mtn Serv Inc aif against Mahesh Kumar & Dory A Hoffman-Kumar is duly recorded in Deed Book No. 279, Page ~. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this , ~ ~ day of A.D. bo1 cc c rder of Deeds rJOO°'~ c Counh Carid~, PA ~ ra Fht 1d~Nn.'If0 Wells Fargo Bank National Association, In the Court of Common Pleas of as Trustee for First Franklin Mortgage Loan Cumberland County, Pennsylvania Trust 2003-FFH1 by: Saxon Mortgage Services Writ No. 2006-5113 Civil Term Inc. as its Attorney-In-Fact VS Mahesh Kumar and Dory A. Hoffinan-Kumar Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 13, 2006 at 2000 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Mahesh Kumaz and Dory A. Hoffman-Kumar, by making. known unto Mahesh Kumaz personally and husband of Dory A. Hoffman-Kumar, at 2427 Rolling Hills Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 1451 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 Mahesh Kumar and Dory A. Hoffman-Kumar located at 2427 Rolling Hills Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Mahesh Kumar and Dorothy Hoffman-Kumar, by regular mail to their last known address of 2427 Rolling Hills Drive, Mechanicsburg, PA 17055. These letters were mailed under the date of January 12, 2007 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Cazlisle, Cumberland County, Pennsylvania on March 07, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $220,000.00 to W. Wade Kelly, on behalf of Green Ridge Leasing LLC. It being the highest bid and best price received for the same, Green Ridge Leasing LLC, of 6375 #8 Basehore Road, Mechanicsburg, PA 17050 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $229,926.54. Sheriffs Costs: Docketing $30.00 Poundage 4,400.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 19.36 Certified Mail 2.44 Levy 15.00 Surcharge 30.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 479.00 436.16 - 16.83 - 25.00 39.50 $5,582.79 / ~,., yf a ~~d7 ~~~ R. Thomas Kline, Sheriff Real Estat Sergeant ~~`'" ~~'~5~ `' ~ ; aa~4 ~• /9/9 ~~ ' '~ 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 Wells Fargo Bank National 'COURT OF COMMON PLEAS Association, as Trustee for `CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v. 5/13 Mahesh Kumar € NO. 06~3-~ Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-Fact, 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: 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name.. __ _ __ _ Address __ _ _ Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Unemployment 16t'' Floor, LEI Building Compensation Fund Harrisburg, PA 17121 4. Name and address of record: Name Plaintiff herein. 5. Name and address on the property: Name none of the last recorded holder of every mortgage Address See Caption above. of 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 Address 2427 Rolling Hills Drive (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made - - sub3ect to the penalties of-18 Pa.C.S.-sec.--4904--relating.. to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: October 24, 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 Ma Udren, ESQ. At rney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udreri, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2003-FFH1 by: Saxon M t e Services Inc as its :MORTGAGE FORECLOSURE or gag Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v ~ 5l ~3 Mahesh Kumar € NO. 06-~3-3 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) NOTICE OF SHSRIFF'S SALE OF REAL PROPERTY To: Mahesh Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Your house (real estate) at 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 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 $286,405.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is __ postponed, the pr-operty-will-be relsted for-the Next-Available Sale. NOTICE OF OWNSR'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immnediate 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.) YOII MAY STILL BE ABLE TO SAVE YOIIR PROPERTY AND YOII 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. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THS OFFICE LISTED BELOW TO FIND OIIT WHSRS YOII CAN GST 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 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan €Cumberland County Trust 2003-FFH1 by: Saxon Mortgage Services Inc. as its `_MORTGAGE FORECLOSURE Attorney-in-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Plaintiff v . 5'/!.3 Mahesh Kumar € NO. 06-~s-1-33 Civil Term Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Your house (real estate) at 2427 Rolling Hills Drive, (Upper Allen Township) Mechanicsburg, PA 17055 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 $286,405.10, obtained by Plaintiff above (the mortgagee} against you. If the sale is postponed, the property-will be relsted-for--the Next Avail-able Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAYS A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THS 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 THAT CERTAIN piece, parcel, and lot of land situate on the east side of Rolling Hills Drive in the Township of Upper Alien, County of Cumberland, Commonwealth of Pennsylvania, be[ng known as Lot #9i on the Final Subdivision Plan of Bowmans Hill -Phase 3, recorded In the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 70, Page 39, being more fully bounded and described as follows, to wit: BEGINNING at a point on the eastern. dedicated right-of-way line of Rolling Hifis Drive at the dividing line of Lot #90 and Lot #91, herein described; thence by said dividing fine, south 61 degrees 49 minutes 08 seconds east, a distance of 173.91 feet to a point at Parcel "F"; thence by said Parcel "F", south 12 degrees 40 minutes 23 seconds west, a .distance of 50.21 feet to a point at the dividing line of Lot #100 and Lot #91, herein described; thence by said dividing line, south 84 degrees 57 minutes 31 seconds west, a distance of 88,62 feet to a point at the dividing line of Lot #92 and .hot #9i, herein described; thence by said dividing line, north 49 degrees 32 minutes 28 seconds west, a distance of 125.29 feet to a point on the eastern dedicated right-of-way line of Roiling Hills Drive; thence'by said right- of-way fine by a curve to the left having a radius of 325.00 feet and an arc distance of 69.b4 feet; the chord of said curve being, North 34 degrees 19 minutes 12 seconds East, a distance of 69.51•feet to a point, the place of BEGINNING. CONTAINING 14,637.3, square feet, more or less. UNDER AND SUBJfCT~ NEVERTHFLFSS, to ~~ 25 feat slope/vegetation ea'sem`ent along the eastern lo't line and all easements and a-estnctions of record. ~ BEING KNOWN AS: 2427 ROLLING HILLS DRIVE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 42-30-2112-066 TITLE TO SAID PREMISES IS VESTED IN MAHESH KUMAR AND DORY A. HOFFMAN-KUMAR, HUSBAND AND WIFE BY DEED FROM K. NEILL FOSTER AND MARILYNNE E. FOSTER, HUSBAND AND WIFE DATED 02/13/03 RECORDED 03/07/03 IN DEED BOOK 256 PAGE 41. • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-5113 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR FIRST FRANKLIN MORTGAGE LOAN TRUST 2003-FFHl BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From MAHESH KUMAR AND DORY A. HOFFMAN-KUMAR (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 $286,405.10 L.L. $.50 Interest FROM 10/25/06 TO DATE OF SALE 3/7/07 -ONGOING PER DIEM OF $57.71 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $7,733.14 Atty's Comm Due Prothy $1.00 Atty Paid $135.68 Other Costs Plaintiff Paid Date: OCTOBER 24, 2006 (Seal) C is R. Long,., onot 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 # 31 On November 6, 2006 the Sheriff levied upon the defendant's interest in the real. property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 2427 Rolling Hills Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. v Date: November 6, 2006 By: Real Estate ergeant 8 Z ~ 11 b` I - 1lON 9~~1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND 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. Marie SWORN TO AND SUBSCRIBED before me this 9 day of February, 2007 NOTARIAL SEAL LOTS E. SNYQER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 gam, $9TATE SALE NO. 31 Writ No. 2006-5113 Civil Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH1 by: Saxon Mortgage Services, Inc. as its Attorney-in-fact vs. Mahesh Kumar and Dory A. Hoffman-Kumar Atty.: Mazk Udren ALL THAT CERTAIN piece, paz- cel, and lot of land situate on the east side of Rollin e ~~ County the Township of Upp of Cumberland, Commonwealth of Pennsylvania, being known as Lot #91 on the Final Subdivision Plan of gow1nans Hill Phase 3, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 70, Page 39, being as follows. bounded and described to wit: BEGINNING at a point on the eastern dedicated right-of-way line of Rolling Hills Drive at the dividing line of Lot #90 and Lot #91, herein described; thence by said dividing line, south 61 degrees 49 minutes 08 seconds east, a distance of 173.91 feet to a point at Parcel "F"; thence by said Parcel "F", south 12 degrees 40 minutes 23 seconds west, a distance of 50.21 feet to a point at the dividing line of Lot # 100 and Lot #91, herein described; thence by said dividing line, south 84 degrees 57 minutes 31 seconds west, a distance of 88.62 feet to a point at the dividing line of Lot #92 and Lot #91, herein described; thence by said dividing line, north 49 degrees 32 minutes 28 seconds west, a distance of 125.29 feet to a point on the eastern dedicated right- of-way line of Rolling Hills Drive; thence by said right-of--way line by a curve to the left having a radius of 325.00 feet and an arc distance of 69.64 feet; the chord of said curve being, North 34 degrees 19 minutes 12 seconds East, a distance of 69.51 feet to a point, the place of BEGINNING. CONTAINING 14,637.3 square feet, more or less. UNDER AND SUBJECT, NEVER- THELESS, to a 25 feet slope/veg- etation easement along the eastern lot line and all easements and re- strictions of record. BEING KNOWN AS: 2427 ROLL- ING HILLS DRIVE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055. PROPERTY ID NO.: 42-30-2112- 066. TITLE TO SAID PREMISES IS VESTED IN Mahesh Kumar and Dory A. Ho#l'man-Kumar, husband and wife by deed from K. Neill Fos- ter and Marllynne E. Foster, hus- band and wife dated 02/13/03 re- corded 03/07/03 in Deed Book 256 Page 41. '~ 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 ................. . .. ,~7~'4./......~.,.n.,.~..~..................... COPY Sworn to and bs ri e efore me thisCOMM01~V1~E/~LTNt7F'~'~~~'~~NIF SALE #31 Notarial Seal Terry L. Russell, Notary Public City OI Harrisburg, phin County My Comr)~sion i June 6, 2010 NOT/(RY CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 1 • . REAL ESTATE SALE NU. ~1 Writ No. 2006-5113 Civil Wells Fazgo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003-FFH 1 by: Saxon Mortgage Services, Inc. as its Attorney-in-fact vs. Mahesh Kumar and Dory A. Hoffman-Kumar Atty.: Mark Udren ALL THAT CERTAIN- piece, paz- cel, and lot of land situate on the east side of Rolling Hills Drive in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, being known as Lot #91 on the Final Subdivision Plan of Bowmans Hill-Phase 3, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania In Plan Book 70, Page 39, being more fully bounded and described as follows, to wit: BEGINNING at a point on the . eastern dedicated right-of--way line of Rolling Hills Drive at the dividing line of Lot #90 and Lot #91, herein described; thence by said dividtng line, south 61 degrees 49 minutes 08 seconds east, a distance of 173.91 feet to a point at Parcel "F"; thence by said Pazcel "F", south 12 degrees 40 minutes 23 seconds west, a distance of 50.21 feet to a point at the dividing line of Lot # 100 and Lot #91, herein described: thence by said dividing line, south 84 degrees 57 minutes 31 seconds west, a distance of 88.62 feet to a point at the dividing line of Lot #92 and Lot #91, .herein described; thence by said dividing line, north 49 degrees 32 minutes 28 seconds west, a distance of 125.29 feet to a pointon the eastern dedicated right- of-way line of Rolling Hills Drive; thence by said right-of--way line by a curve to the left having a radius of 325.00- feet and an arc distance of 69.64 feet; the chord of said curve being, North 34 degrees 19 minutes '12 seconds East, a distance of 69.51 feet to a point, the place of BEGINNING. CONTAINING 14,637.3 square feet, more or less. UNDER AND SUBJECT, NEVER- THELESS, to a 25 feet slope/veg- etation easement along the eastern lot line and all easements and re- strictions of record. BEING KNOWN AS: 2427 ROLL- ING HILLS DRIVE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055. ' PROPERTY ID NO.: 42-30-2112- 066. TITLE TO SAID PREMISES IS ' VESTED IN Mahesh Kumar and Dory A. Hoffman-Kumar, husband and wife by deed from K. Neill Fos- ter and Marilynne E. Foster, hus- band and wife dated 02/ 13/03 re- corded 03/07/03 In Deed Book 256 Pace 41 . SCHEDULE Off' DISTRIBUTION ~' SA~.E N0.31 Date Filed: Apri105, 2007 Writ No. 2006-5113 Civil Term Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2003- FFH1 by: Saxon Mortgage Services, Inc., as its Attorney-In-Fact VS Mahesh Kumar and Dory A. Hoffman-Kumar 2427 Rolling Hills Drive Mechanicsburg, PA 17055 Sale Date: Buyer: Bid Price: Real Debt: Interest: Attorney C March 07, 2007 Green Ridge Leasing LLC $220,000.00 $286,405.10 7,733.14 osts: 135.68 Total: $294,273.92 DISTRIBUTION: Receipts: Cash on account (11/06/2006): $ 1,500.00 Cash on account (03/07/2007): 22,000.00 Cash on account (03/23/2007) 207,926.54 Total Receipts: $231,426.54 Disbursements: Sheriffs Costs $5,582.79 Legal Search 200.00 Local Transfer Tax 2,663.27 State Transfer Tax 2,663.27 Marlin A. Yohn, Sr. Tax Collector 870.45 Upper Allen Township, Sewer 100.00 Attorney Mark J. Udren 1,500.00 Altegra Credit Company 217,846.76 Total Disbursements: ($231,426.54) Balance for distribution: 0.00 So Answers: ~.,~!~.~ R. Thomas Kline Sheriff ~• TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE N0.31 Held: Wednesday, March 7, 2007 Date: March 7, 2007 TAXES: Receipts for all taxes for the years 2004 to 2006 inclusive. Taxes for the current year 2007. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2007, and recorded 2007, in Cumberland County Deed Book ,Page RECITAL: Being the same premises which K Neill Foster and Marilynne E. Foster, his wife, by deed dated February 13, 2003 and recorded March 7, 2003, in the Office of the Recorder of Deeds in and for Cumberland County, in Carlisle, Pennsylvania, in Deed Book 256, Page 41, granted and conveyed Mahesh Kumar and Dory A. Hoffman-Kumar, husband and wife. OTHER EXCEPTIONS: The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. i t~ 5. Public and private rights in the roadbed of Rolling Hills Drive. 6. Building conditions, easements and restrictions as shown on or recorded with the Final Subdivision Plan of Bowmans Hill -Phase 3, recorded in Plan Book 70, Page 39. Building and use restrictions as imposed by instrument recorded in Miscellaneous Record Book 440, Page 818. 7. Mortgage in the amount of $229,500 given by Mahesh Kumar and Dory A. Hoffman-Kumar to First Franklin Financial Corporation dated February 28, 2003 and recorded March 7, 2003 in Mortgage Book 1799, Page 2424. Complaint in mortgage foreclosure filed by Wells Fargo Bank, N.A. as Trustee for First Franklin Mortgage Loan Trust as Plaintiff against Mahesh Kumar and Dory A. Hoffman-Kumar as Defendants, in the Office of the Prothonotary of Cumberland County, on August 31, 2006 to File No. 2006-5113. Judgment in the amount of $286,405.10 entered October 24, 2006. 8. Certified copy of lien filed by the Unemployment Compensation Fund of the Commonwealth of Pennsylvania, as Plaintiff against Mahesh Kumar as Defendant on December 27, 2004 to File No. 20046475. Said judgment may be a lien on the subject premises in the event of the divorce or death of Dory A. Hoffman-Kumar. 9. Rights granted to Sammons Communications of Pennsylvania, Inc., by instrument recorded March 17, 1993 in Miscellaneous Record Book 440, Page 2. 10. Rights granted to Sammons Communications of Pennsylvania, Inc., by instrument recorded October 6, 1993 in Miscellaneous Record Book 455, Page 1090. 11. Rights granted to Pennsylvania Power and Light Company and Bell Telephone Company of Pennsylvania, by instrument recorded January 31, 1994 in Miscellaneous Record Book 465, Page 14. 12. Rights granted to Sammons Communications of Pennsylvania, Inc., by instrument recorded April 17, 1995 in Miscellaneous Record Book 494, Page 150. 13. Rights granted to Pennsylvania Power and Light Company by instrument recorded May 21,1996 in Miscellaneous Record Book 520, Page 679. ~4 14. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 15. Real estate taxes accruing on and after July 1, 2007 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. ~.../~l`~~ . R ert G. Frey, Agent Note: This Title Report shall not be valid until countersigned by an authorized sign