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HomeMy WebLinkAbout06-5815REN LAW OFFICES P C ATTORNEY FOR PLAINTIFF UD , . . BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee COURT OF COMMON PLEAS 1270 Northland Drive :CIVIL DIVISION Suite 200 Mendota Heights, MN 55120 ;Cumberland County Plaintiff V. Christopher D. Lauver - J d" N 46 Warwick Circle NO.Oto Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: JPMorgan Chase Bank as Trustee 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: 46 Warwick Circle MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 1/27/04 DATE RECORDED: 1/28/04 BOOK: 1852 PAGE: 1619 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 9/22/06: Principal of debt due $145,497.29 Unpaid Interest at 5.750* from 5/1/06 to 9/22/06 (the per diem interest accruing on this debt is $22.92 and that sum should be added each day after 3 323.40 9/22/06) , Title Report 325.00 Court Costs (anticipated, excluding 00 280 Sheriff's Sale costs) . Late Charges (monthly late charge of $43.77 should be added in accordance with the terms of the note each month after 9/22/06) 175.08 F es (anticipated and actual A tot,-o5 r0neof yspri e 7,274.86 ncipal) TOTAL $156,875.63 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff ' s Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $156,875.63 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 or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more paAicularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of-way line of warvdck Circle at the ommon front property comer of Lot No. 20- D and Lot No. 20-E shown on the hereinafter mentioned plan of lots; thence along said warwick Circle North 01 degreed 54 minutes 01 second East, a distance of 20.00 feet to a point at the dividing line between lot no. 20-C and Lot No. 20-1); thence along said dividing line 88 degrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the dividing line between Lot No. 19-A and Lot. No. 20-D; thence along said dividing line South 01 degree 54 minutes 01 second West, a distance of 20.00 feet to a point at the dividing line between. Lot N020 - D and lot No. 20-E; thence along said dividing line North 88 degrees 05 minutes 59 minutes West, a distance of 110.00 feet to +a point, said point being the place of BEGMING. , CONTAINING 2,220.00. sqaure feet. r 1 t t i Homecomings Financial AGMAC Company August 07, 2006 0437491988 Christopher D Lauver 46 Warick Circle Mechanicsburg, PA 17055 Re: Property Address: 46 Warick Circle Mechanicsburg, PA 17055 Certified Mail, Return Receipt Requested Loan Number: 0437491988 A default exists under the above referenced Mortgage/Deed of Trust loan agreement. The action required to cure the default is the payment of all sums due under the Mortgage/Deed of Trust loan agreement. As of the date of this letter the total amount due is $ 2,757.39 . That sum includes the following: 3 payments totaling: $ 2,626.08 Late charges: $ 131.31 Other fees and/or costs N/A Unapplied Funds : N/A The total amount due shown above is subject to further increases for additional monthly payments, late charges, attorney fees, and/or other fees and cost which may become due, after the date of this letter. To obtain an update of the total amount due to cure this default, contact us at 800.799.9250. TO CURE THIS DEFAULT, SEND YOUR CASHIER'S CHECK, MONEY ORDER, OR CERTIFIED CHECK IN THE AMOUNT OF $ 2,757.39 BY September 06, 2006 TO THE FOLLOWING ADDRESS: Homecomings Financial, P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO: 1820 East Sky Harbor Circle South, Suite 100 Phoenix, AZ 85034-9700 If the default is not cured within thirty (30) days of the mailing of this letter, the lender, without further notice or demand, will accelerate the maturity date of the Note and declare all sums secured by the Mortgage/Deed of Trust to be immediately due and payable. The lender then intends to have the property sold at a public foreclosure sale. After acceleration, a curing of the default and reinstatement of the loan will be permitted up to the time of the sale by paying the past due monthly payments and other sums then due under the Mortgage/Deed of Trust loan agreement and by complying with all terms of reinstatement. You have the right to bring a court action to assert the nonexistence of a default or any other defense that may exist to prevent acceleration and sale of the property. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Sincerely, Loan Counseling Department IILH *Homeovn,mWp counseling is available to you through the `Credit Counseling Resource Center' (CCRC), an alliance of consumer credit counseling agencies. The CCRC has been retained by Homecomings Financial to provide advice to you on credit issues, including how to reduce debt and improve cash flow management capabilities. You may contact them at 1.877.806.0775 for assistance at no cost to you, or you may wish to contact a HUD-approved housing counseling agency by calling 1.800.569.4287 for further information Homecomings Financial 2711 North Haskell Avenue Suite 900 Dallas, Texas 75204 800.206.2901 Homecomings.com EXHIBIT \. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. This is an official notice that the mortgage on our home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF TH DATE OF THIS NOTICE Take this notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have an questions. you may call the Pennsylvania Housm Finance A gene toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA 2VTORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IND,4EDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDEvER SU HIPOTECA. Date: August 07, 2006 TO: Christopher D Lauver 46 Warick Circle Mechanicsburg, PA 17055 Premises: 46 Warick Circle Mechanicsburg, PA 17055 Re: Loan Number: 0437491988 FROM: Homecomings Financial HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELPYOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSITANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDPT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting LENDER CONTACT IN REGARDS TO PENNSYLVANIA HOUSING FINANCIAL ASSISTANCE HomeComings Financial Attn: Ryan Ramos 9350 Waxie Way Ste. 100 San Diego, CA. 92123 Fax: 858-514-5516 ALL CORRESPONDENCE REGARDING PHFA ASSISTANCE SHOULD BE FORWARDED TO THE ABOVE REFERENCED ADDRESS. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIM PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your properly located at: 46 Warick Circle, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from 06/01/06 to 08/01/06 totaling: $ 2,626.08 Late Charges: $ 131.31 Other fees and/or costs (including NSF charges and property inspections): N/A LESS: Unapplied Funds: N/A TOTAL $ 2,757.39 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT DUE TO THE LENDER, WHICH IS $ 2,757.39, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Homecomings Financial, P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO: 1820 East Sky Harbor Circle South, Suite 100 Phoenix, AZ 85034-9700. IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender, even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then 12ast due plus an late or other charges then due reasonable attorns fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Homecomings Financial 2711 N. Haskell, Suite 900 Dallas, TX 75204 Attn: Loan Counseling Department Phone: 1.800.206.2901 EFFECT OF THE SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Loan Counseling Department Enclosure(s) List of Counseling Agencies V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ILI Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. -Zz V w _J r-? c- F c- C_I, c? c-? --a N -?- -rt r t r V L . + 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. ':Cumberland County Christopher D. Lauver Defendant (s) 'NO. 06-5815 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. UDREN LAW OFFICES, P.C. DATED: November 28, 2006 A BY: rk J. Udren, Esquire torney for Plaintiff V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: al/3/b? Name : ? "C; l aq ry' '?? Title. ?`7 \J Company: Homecomings Financial Network as servicer on behalf of JPMorgan Chase Bank as Trustee Christopher D. Lauver Loan #0437491988 MJU #06090493 Ea 41 G3 d UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 ATTORNEY FOR PLAINTIFF CHERRY HILL, NJ 08003-3620 856-669-5400 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor :CIVIL DIVISION San Diego, CA 92123 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Christopher D. Lauver ::NO. 06-5815 46 Warwick Circle 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) Christopher D. Lauver 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 $156,875.63 Interest Per Complaint 1,535.64 From 9/23/06 to 11/28/06 Late charges per Complaint 87.54 From 9/23/06 to 11/28/06 TOTAL I hereby certify that (1) the addresses of t ye Plaintiff and Defendant are as shown above, ,and (2) that notice h s been given in accordance with Rule 237.1, 4 Opy of which is attac d hereto. OFIVCES, P. Cr. DAMAGES ARE HEREBY ASSESSED AS DATE :? ?gr?l)d fo Attorney for Plaintiff INDICATED PRO PRO?Tff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ATTORNEY FOR PLAINTIFF JPMorgan Chase Bank as Trustee -:COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION € Cumberland County V. Christopher D. Lauver Defendant(s) =NO. 06-5815 TO: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 DATE of Notice: November 13, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 I14PORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A. UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION P CTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION INED WILL BE IISED OR THAT PURPOSE. s ar ren ire W dcrest Corporate Center ill Woodcrest Road, Suite 200 Cherr Hill, New Jersey 08003-3620 i. • f r UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 JPMorgan Chase Bank as Trustee Plaintiff V. Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-5815 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Minnesota SS COUNTY OF Dakota 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: Christopher D. Lauver Age; Over 18 Residence: As captioned above n 0 l? Employment: Unknown Q4 Sworn to and subscribed before this /3?da of c cb? C-- 00,E . L,??1 ?1u AftKUBERLY PAULINE ANOKA NOTARY PUBLIC -.MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2010 ivame Title: a i yf Company: Hom comings Financial Network as servicer on behalf of JPMorgan Chase Bank as Trustee ? SHERIFF'S RETURN - REGULAR CASE NO: 2006-05815 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS LAUVER CHRISTOPHER D 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 LAUVER CHRISTOPHER D the DEFENDANT , at 2102:00 HOURS, on the 20th day of October , 2006 at 46 WARWICK CIRCLE MECHANICSBURG, PA 17055 CHRISTOPHER LAUVER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 7.04 ell 00 10.00 R. Thomas Kline .00 35.04 10/24/2006 UDREN LAW OFFICES By ; day Deputy Sheri A. D. o??ouG? 4Q IR, t. I X7, 1o r ? ?? w ? -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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. ;MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant(s) To: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver :NO. 06-5815 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $158,498.81 Interest From 11/29/06 2,269.08 to Date of Sale 3/7/07 Ongoing Per Diem of 22;92 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.)C. J"JfAiJI. ?J/. V\41 V1J., ??/V li?JJ ATTORNEY FOR PLAINTIFF 7 Cl 9+ %rZ 0 - vZ C3 ro a Iq .. _ ,. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5815 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK AS TRUSTEE, Plaintiff (s) From CHRISTOPHER D. LAUVER (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 $158,498.81 L.L. $.50 Interest FROM 11/29/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $ 22.92 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $2,269.08 Atty's Comm % Atty Paid $117.04 Plaintiff Paid Date: NOVEMBER 29, 2006 (Seal) Due Prothy $1.00 Other Costs Curt' . Long, Protho - 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver :NO. 06-5815 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( } Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. OFFICF,S.,„ P. C. J. Odrdh, ESQUIRE NEY FOR PLAINTIFF rv t wcs; N r -,ft 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 JPMorgan Chase Bank as Trustee "COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank as Trustee, 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: 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Christopher D. Lauver 46 Warwick Circle 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 Silver Spring Township Authority 4. Name and address of of record: Name JPMorgan Chase Bank as Trustee 5. Name and address of on the property: Name 31 East Main Street, P.O. Box 1001 New Kingston, PA 17072 the last recorded holder of every mortgage Address 9275 Sky Park Court, 3rd Floor San Diego, CA 92123 every other person who has any record lien Address none 0 + 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 46 Warwick Circle (Silver Spring 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.O. DATED: November 28, 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 Ark J. 041f'en, ESQ. torney for Plaintiff C"> O E a 5 r t ; C> 1 k '.. 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 JPMorgan Chase Bank as Trustee =COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver :NO. 06-5815 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Your house (real estate) at 46 Warwick Circle, (Silver Spring 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 $158,498.81, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ? . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 - j T e t J 4 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05815 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS LAUVER CHRISTOPHER D MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MnRT FnRF the LAUVER CHRISTOPHER D was served upon DEFENDANT , at 2102:00 HOURS, on the 20th day of October , 2006 at 46 WARWICK CIRCLE MECHANICSBURG, PA 17055 CHRISTOPHER LAUVER 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 7.04 x%y Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 35.04,/ 10/24/2006 UDREN LAW OFFICES Sworn and Subscibed to By: before me this day Delbuty Sheri 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 pleadings@udren.com JPMorgan Chase Bank as Trustee 'COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION ;Cumberland County V. Christopher D. Lauver Defendant :."NO. 06-5815 MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Mark J. Udren, Esquire, moves this Honorable Court for an order directing service of the Notice of Sale upon Defendant, Christopher D. Lauver by regular mail and certified mail and by posting the mortgaged premises in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant at 46 Warwick Circle, Mechanicsburg, PA 17055. A copy of the Return of Service is attached hereto as Exhibit "A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit `%B„ . 3. Said investigation was unable to determine an alternate address for said Defendant. 4. The last known address of Defendant is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale by regular mail and certified mail and by posting the mortgaged premises upon said Defendant, Christopher D. Lauver. UDREN LAW OFFICES, P.C. 1 By: Mark J. Udr n, Esquire a, . __?.. ___....._.W , .?...,,.,....... _ ...y___...._ _. Attorney for Plaintiff _ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF. BY: Mark J. Udren Esquire ATTY I.D. NO 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee =COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County V. Christopher D. Lauver Defendant NO. 06-5815 MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by` an aff idavit stating the' nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made NOTE : A Sheri f f ' s return of "not f ound" or the f act that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976) An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records z As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Notice of Sale. A good faith effort to -discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant by regular mail and certified mail and by posting the mortgaged premises UDREN LAW OFFICES, P.C. By.: Mark J. Udren, Es e Attorney for Plaintiff . Feb. 1, 2007 3:57PM Cumberland Co, Sheriff JP Morgan Chase Bank, as Trustee VS Christopher D. Lauver No. 9885 P. 2 In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2006-581 S Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent starch and inquiry for the within named defendant, to wit: Christopher D. Lauver, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the within named defcndant, Christopher D. Lauver. Twelve attempts at service were made, but no one was home, Gerald Worthington, Deputy Sherif& who being duly sworn according to law, states that on January 19, 2007 at 0945 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 Christopher D. Lauver located at. 46 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania according to law. So Answers: R. Thomas Kline, Sheriff BYJI Rcal Esute Sergeant EXHIBIT A Players National Locator, Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number. 06080483 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number. Subject: Christopher Lauver A.K.A.: Christopher D Lauver Last Known Address: 46 Warwick Circle Mechanicsburg, PA 17050 Last Known Number( ) - Melissa Kozma, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of location Specialist for Players National Locator, Inc. 2. On 01/23/2007, 1 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER(S):184-524650 B. EMPLOYMENT SEARCH: We wens unable to verify current employment for Christopher Lauver. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Christopher Lauver is 46 Warwick Circle, Mechanicsburg, PA 17060 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing for Christopher Lauver. We called (717) 76646461 and spoke with a relative who stated Christopher Lauver is living at 46 Warwick Circle, Mechanicsburg, PA 17050. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of January 22, 2007 the National Change of Address (NCOA) has no change for Christopher Lauver from 46 Warwick Circle, Mechanicsburg, PA 17050. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license Information for Christopher Lauver. OTHER INQUIRIES - A. DEATH RECORDS: As of January 22, 2007 the Social Security Administration has no death record on file for Christopher Lauver and/or A.K.A's under the social security number provided. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. ): None Found. SIZ-1 0£0/VIO* d 9l£-1 8990 0£Z 9£9 EXHIBIT P UDIIE13OSSY s,J8AE1d-=JA W11:90 10-£Z-ar C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters RealaVation Office. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: June 1969 AFFIANT ,MgIIssa Kozma pbefbrepi 1 3/2 7 N4TARY 8 AL Kristine M. Scott, Notw y Public St. Louis County, Stale of Missouri My Commission Expires 9/2/2010 Commission Number 06428685 i.? Players National Locator, Inc. 174 Clarkson Road, Suite 225 St Louis, MO 63011 Phone: (636)230-9922 Fax: (636)230-0558 MHar " s 9lZ-d 0£0/9i0'd 91£-1 8990 OR 9£9 UOII0130SSV s,J8AR1 d-M0ad wdZ1:90 20-£Z-uEr VERIFICATION Mark J. Udren, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing MOTIONFOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Date: February 7 , 2007 Mark J Udren, ire Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren Esquire ATTY I. D. NO. 04 3 0 2 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udrea.com JPMorga:n Chase Bank as Trustee COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County V. Christopher D. Lauver Defendant NO. 06-5815 CERTIFICATE OF SERVICE I, Mark J. Udren, Esquire hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person named herein at their last known address or `their attorney of record by: x Regular First Class Mail Certified Mail Other Date Served: February 7 1 ,2007 TO: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 UDREN LAW OFFICES, P.C. By: Mark J. dren, :quire Attorney for Plaintiff ?? - '--t t -4 ?. - ?_rs i - ? C?? -, ..?;,? - - -?; _ i ? } -- ?,,.? .. ; ,,. ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT 39B 0 9 20RA CIVIL DIVISION JPMorgan Chase Bank as Trustee Plaintiff V. ENO. 06-5815 Christopher D. Lauver Defendant O R D E R AND NOW, this Ilia day of rt-' IIV561Ny , 20 07 , upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055. BY THE COURT: ,w? I ?j A, VINVAIXSNN d 9 o :8 WV C ! 93J LOOZ AdViONCHiOdd :,'Hl JO D- #Cf-Q31ld 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor :CIVIL DIVISION San Diego, CA 92123 :Cumberland County Plaintiff V. Christopher D. Lauver 46 Warwick Circle :NO. 06-5815 Mechanicsburg, PA 17055 Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: February 16, 2007 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 21, 2007 UDREN LAW OFFICES, P.C. 1\ AA Mark J re Esquire ' w cog 0 9 200 P? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION JPMorgan Chase Bank as Trustee :Plaintiff V. ENO. 06-5815 Christopher D. Lauver Defendant O R D E R Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055: BY THE COURT: 4. J. TRUE COPY FROM RECORD in Testimony I hers unto set my hand and a seal of I sa`d t,.irt a lisle, Pa. ......l.lL, da of.. :, . AND NOW, this 12? day of 20 upon consideration of Plaintiff's Motion a the Affidavit of Good LIA a# pa.. ?? 222 b:znas?iueuaatnt ,?s ?? 550LZ at??ta 40.Cpjlet& gti vsOdJO _j`;-a - O ' ?ann??I CIO t zLj,7 ' Q eau , Cf . Er y tr saed'8 eBslsod {eWl ? -------"^?" 02 yew pe ?ASed? 89:1 C3 Q tp?t^be!! wes+a +31 p M es? ? a r_ 0 C3 0 ' 0 1 WSH vrj*od aed t eo L_' II a 0.Va? O ?-' oc ui 8 ?OWZ 00 aWC °o 3 Ln Ln ?4 O ? C r7 rl W v A ?? N U N Q,.? Urt U O H K Certified Mail Provides: r?li? zoo?,? ¦ A mailing receipt ¦ A unique Identifier for your mailpiece - ¦ A record of delivery kept by the Postal Service for two years ft C Mamll NLY be combined with First-Class Mails or Priority Maile. ¦ Certified Mail is not available for any class of International mail ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail ¦ For an additional fee, a Return R trna be requested-1o %de proof of del". To obtain Return Receipt please t?npleta and attach a Return Receipt (PS Form 38111 to the article and Adel, applicable postage to cover the fee. Endorse mailpiece Retum Receipt Requested". To receive a The waiver for a duplkate return receipt, a USPSO postmark on your Certified Mail receipt Is required. ¦ For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mallpiece with the endorsement 'RestricW?e ¦ If a postmark on the Certified Mail receipt Is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and aft label with postage and mail. IMPORTANT: Save this receipt and present it when making an Inquiry. Internet access to delivery information is not available on mail addressed to APOs and FPOs. I I QQ9 p }S Zo L ? }S ? ? ? ? ? N w r ? ? tt v ? ? m v v 0 roc v } ? 05 cc .9 ? ? x d Cd d w v Ln In l`1 0 9 H P4 U Q -ri i31 U S-t 1'a 04 -H U H 4. ) G ril 4 r 4 ?c N s Ud? dr r-1 C3 I r-1 r•a N r•a Q C7 C3 0 r•q go C3 ?n C3 C3 r I Z m rd CV s a E U E a v ? 0 o z N 2 LL T cr) n. Y1 ; i In lt_ N ? y N = fn N ..O- N v y O y ? d ? y c ? d cc d E CL .? t `O cOi - N a ? ?fl c o Cc NO N a U 3 Q V N ? J] 7 7 N N. C (C O CD R ada? cam «_ _ rn? c m Va13 =U .? o a v t6 a°?i N N r l ? v .c W ?) cl m 0 ? a v m? g'jt?ii0d ?GUU N OOOO 4 Cl* Z o0?0 O o U W Cl vtu N ID Ul CL LL 0 1 °N' > LLVW; 10 a 45 W0x a c ?w0?,- o W03o cc 4) cc E J p0?= Z a?<<7 A? 07 p V E QZ m u L1 ppp N y? jy 100ma EC_ C09 O m Q c Q ? .L L m= Q E m u N? q '? 7mw •N ? - L A m ?2uc??fi o ? o E?azEc ,o m y,ap o p A ? C G.L O'?j w EA?p m m? E ? m m m N p rn cc - C m E?Emcc Cm ?? CAW YI C m m L m d ? m Y p ?'3 m??Qou?i' C ? '' Lo- E c`o'oo''Ec pp m:?0 m ?Q T'r E 00 N Q O 6 p> G v' ?O T(A L w CK.C G p ,Zoo >c'Ea c a'R ?N o p V O E p ?p 2 '? rn m c 0o y u ? L ? W p m m?'?.E L ?O ? + rte- tl'? Y y,ry? 0 Q - a i? u? c? Z g C a O aM W O m T r m Q V E nom. u0. t r T ?O IT { T T T N ? J d ? E Ln u9 Co ~ Z4? T N N a m ? ?U co 2 m d U. d ti 0 O ' 00 C? CD 0 L m o f a r? ? o r cr, 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 JPMorgan Chase Bank as Trustee --COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor -:CIVIL DIVISION San Diego, CA 92123 €:Cumberland County Plaintiff V. NO. 06-5815 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. UDREN LAW OFFICES, P.C. Date: February 21, 2007 BY: V U Mar J. Udren, Esquire Att nev for Plaintiff A AFB 0 8 20 ?1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION JPMorgan Chase Bank as Trustee € Plaintiff V. i €NO. 06-5815 Christopher D. Lauver Defendant O R D E R AND NOW, this I dkly\ day of 20 upon consideration of Plaintiff's Motion a (the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055. BY THE COURT: Ai J-A J. TRUE COPY FROM RECORD In Testimony v, i) .x: ^f, 1 here unto set my hand and a seal of s ?`d ,,.,rt a ;isle, Pa: T ...l?.. da of 17 4 ? 4 I %I. JI'MorR3n Chase Bank as trustee, et. al.. Plaintiff(s) VS. Chrisluphor 1). Lauver, et. at, Defendant(s) UDRE.1 LAW OFFICES Ms. Heard Crommarty I I i WnlNlcrest Nil, Suite 200 Cherry Hill, NJ 08003.1620 l Service of Process it) AIM Ar-StNtf:Rhn'rroNgr ? APS International, Ltd. 1-800-328-7171 APS intentationnl Plana l 7800 Ciearoy Rd. Minneapolls, MN 55439-3122 A PS pile #: 091662.0001 AFFIDAVIT OF SFRVICF -- Individual Service of Process on: -Christopher D. Lauver, by posting Court Csae No. 06-5815 Slate of: ?l."f ?i d? ,f,/ ) is, County n Name of Server: za Y / lQ , undersiglned, being duly sworn, deposes anti says that at the time of service, s/hc was of legal age and was not a party to this action; llalell imc of Service: that on the r,?ay of , 20 (, atn'elpCk `?? 114 )'lace of Service: at 46 Warwick Circle (Silver Sprint Twp) - in Mechanicsbut'& I'A 17055 Documents Served: the undcrsibned staved the documents described as: Nolite of Sheriff's Sale of Real Property w/ Order Service of Process on: A true and correct copy of the aforesaid doeumcnt.(s) was served on: Christopher 1), (.,saver, by posting Person Served, anti Method of Service: By personally delivering them into the hands of the person u) be served. By delivering them into the hand, of a person of suitable age, who verified, or who upon questioning stated. that he/she resides with t"hrisfopher D. Lauver, by posting at the place orservicc, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex `; Skin Color : Flair Color Facial Flair Approx. Age : Approx. flcight Approx. Weight I'o the best of my knowledge and belief, said per_• m was not engaged in the- WS Military at the Limc of service. Signature of Server: Undersigned declares under pen ily of perjury Su scribed an sworn ti before me this that the foregoing is true d c{?rrt:ct. day o 20 ,?' . ignatarvcr Notary Public (C'onuniss?uu liz acs) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Nofsrisl Seal EIMVY Trlrn 9. Notary pubic zo, CuvI*C-d rd Cowvey ion EVA-- SW. 11. 2010 Mamtwr, ParMSylvan:a Asea:luti0n of Notaries C. May, N t c p 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor ::CIVIL DIVISION San Diego, CA 92123 :Cumberland County Plaintiff V. 6 Christopher D. Lauver 46 Warwick Circle :NO. 06-5815 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 Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authoritigg? /) n Dated: March 1, 2007 \ UD_,REN LJ,W/OF/F/1CES, P.C. BY: (/ Mark J Udren, squire Attorney for Plaintiff 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 JPMorgan Chase Bank as Trustee =COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor €CIVIL DIVISION San Diego, CA 92123 :Cumberland County Plaintiff v. Christopher D. Lauver NO. 06-5815 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Christopher D. Lauver PROPERTY: 46 Warwick Circle (Silver Spring Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING 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. IN EXHIBIT A volui au- m 6LL 5 ?O O 0 (LLL :a = 5B ? o Iso C'o 0) vi -to nom. ( xU Cj CN N m WE 0's ) i $ a m m 3?' to rU o ? v m ?y?°1 ?i , uU Mv [3 [313 0 N_ O O O G O U r- a W J 00 C3 ° w 0 7 O Z C W C'. ° r p Q W ?O Z .u T o j Q r N co [t V J 4 Q " W' W N C cr. Q-Z a Q L6 Z O += . L 0 ' O J w W W N ? Z p w of O = Z 4 W 1- tl o to [L pOt? a ? ?p< ?7/ Z U U i Y r Y w GC p [ N m Q7 fl m m 8? a ?p m V 15 1t1 N m mt ? NN m O M'?m W ?9 Npp cc m m _ ?'? ?'oE m m r me_ m? m Ly C S- N m Oq m 0 m G L N pg ~ $"° ?i .o€ tit 7 of aON1 D •" ?p? O G 1 w' ?ymECL ., y so.9z7?a `?' 0 U ? = I I Q m yn 6 UN c N •? rn i(? l1J ?y t"n dW ~ N N ? •o Q t° o? 3: CL CJ- 4 Qz? _ ? mU _ Q Q N o NUS_ ?o 0cc o,Y U C N ill N Q x t- rt N z 15 U- rLm Z .? ? $ p„E p O W N <N '' ``? c?aF--' Q 0 m Z Io a a c 'o a W 0 C C O. r d 61 E V a 3 g 0 ? N lA % O a_$ o? ?n G 9 Am 'SO, ?`mL N r r O Y Y Y d Qz Go Q Y G y D 1` 02 CN CD CO d' to E?G? O Y N 7 J rn LL I o LL Ui Cf) 4) CT O O O J 4 N O 31-T A v 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 JPMorgan Chase Bank as Trustee 9275 Sky Park Court, 3rd Floor San Diego, CA 92123 Plaintiff V. Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5815 VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: February 16, 2007 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 21, 2007 UDREN LAW OFFICES, P.C. 1\ AA Mark J re , Esquire EXHIBIT 8 ??e o 9 2007 A? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION JPMorgan Chase Bank as Trustee :Plaintiff V. NO. 06-5815 Christopher D. Lauver Defendant O RID E R AND NOW, this 'AJ31 day of 20 , upon consideration of Plaintiff's Motion a (the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail. to the last known address of Defendant-, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055: BY THE COURT: J. TRUE COPY FROM RECORD In Testimony ??i:r ^f, I hero unto set my hand and + seal of s2i ,urt s lisle, Pa. ......?.?[ . da of.. N EXHIBIT Z SSOGT `dd '5zngs?zitu?ay1,?,? G ta:Tt? }(?tMZ 'M 9i7 08Odm '' zaansZ 'II aaudo?szzu? C3 1C:j C3 ,? ?.... o i C3 ? Er 1 [C' . ....?.r?? ...?...,?..?.. se6?'8 eBB?cod 1301 p CI EP W .??+.?.?..? eed NeMlea p as O : C3 .??..?? (pealnbea ?UamesaapU3} eed u§eoea wntea CI O C3 ' C3 -? Mid '99:1 powoo Im b, { Y •` $ C3 C3 pU,•,U4m fJd?? o oo? gr$? 0 in W O ?4 ° w N i a U 0 W pU U H A N.? E-4 O U fi''rU-1' x g • 0 ri 0 , .] O H t Certified Mail receipt iProvides: A (--ou) zoz QW 'ooas vu)?j ed ¦ A unique idengfier for your maiipiece ¦ A record of delivery kept by the Postal Service for two years Important Reminmders: ¦ CertlFed Mail MN ONLY be combined with First-Class Malls, or Priority Mail. ¦ Certified Mail Is notavailable for any class; of International mail. ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider insured or Registered Mail. , I. ¦ For an additional fee a Return Rat may be requested4a pirdvide proof of delivery. To obtain R;6N Receipt service please complete and attach a Return Receipt (PS Form 981,1) to the article and add applicable postage to cover the fee. Endorse mailpiece Return Recut Requested". To receive a fee waiver f a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is required. ¦ For an additional fee, delivery may be restricted to the addressee or addressee's authorized . Advise the clerk or mark the malipiece with the endorsement 'Restricts livery'. ¦ If a poehnark on the Certified Mail receipt is desired, please present the aRl- ' de at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Sava this receipt and present it when making an inquiry'. Internet access to delivery information is not available on mail addressed to APOs and FPOs. 1 1 -1 ?? ? ?" 2 1 f. ?? ?? 5 ? c ? ? ? ? ? l d x m Ci a l L_ Ln ?4 O m a = 0 $ -r -- m r-I P4 U a s ri m 0-2 Y € C6 Z' s A U ?i CL ?4 r E?00 U to 0? $ O 3-? m m S4 U ?v 0o?? w'o Ud?? £c c rd O EXHI4IT B rq 13 r? ra tr r-? O D 17 O r-a ICU O .A 0 0 r- I z GV W a % N m d N TO m mq ? en TO CSC LL wL m='i£ N In a? ya D E q m °_c uE ucu m C c- E W?m•°aZ NNtl7iEw •QcNCmo ? Eo0g3-r-m CA LL CLUS W C. = S 0) LL l m m°Do O o ei mm? V ?a W § 3 O w y' ??c c N y ?' LL a •ay W c .W c_? W o ts a> ? ?E?o, L q b no V $ •OO E? E d o cammmc E °r m a = NO Btoc uSE"-m and U c N ? a m? K te•G h 7'? Cm.O--?' .o ° C t Cp 'N Q y' E C ? oo W W(p y a m w v C] d ovmm?o amaaoA W S r a+ _ W O N C : a rno amc t `0 p C N^ 7 ? N m m L`u? c N ? w c o 0. ? c' d l6 °rn _ !6 o TS w o o E in L. G a•o07 rot ?C;6 NL+ G ?NOXR:G u ? y a C OI V e§§ N C1 p W m ? ? dNFG W ?. UOC?? U = w D m ? a •o . • ? u **?a? ?b'htk 'Ia la? m F- .a . SY N u C d _ 'I? @ 2""? O m ??00 o ? V ? d a i v y m ? rn ? er.: to yp o C I 0000 ' co E u, a 9 U. ? W o U C) r w P y. a V W L U 2 `i z .19 uj ?y ~ v 00 in w CD L o V U ONZ N v 0 0 . O??J m Q mn a E- J ?woi a a ? Z' r" g?or ? d ? o uj d o 0= Z G LL T ?p?'V L N d ? O . N a _ th W d - M0 Z o z N O = aN M E 4 = c CD Lo Ul o Dg 0 U_ 2 (D Z Ev e a 5 co M N M to `' HIBIT B z EX 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 JPMorgan Chase Bank as Trustee 'COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor 'CIVIL DIVISION San Diego, CA 92123 'Cumberland County Plaintiff V. NO. 06-5815 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: February 21, 2007 UDREN LAW OFFICES, P.C. BY: V U Mar} J. Udren, Esquire Att ney for Plaintiff EXHIBIT 8 JPMorgan Chase Bank as Trustee Plaintiff V. NO. 06-5815 11 Christopher D. Lauver Defendant O R D E R AND NOW, this 2DA_ day of Fc? 20 , upon consideration of Plaintiff's Motion a (the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055: BY THE COURT: A/ J. TRUE COPY FROM RECORD In Testimony I here unto set my hand ;ande seal r urt a lisle, Pa. .....?.. da of (.... . Y th EXHIBI JI'Mor•gut Chase Ban: as trustee, et. aL. Plait tiff(s) VS. Chrlstuphter 1). Lauver, et. al., Defendant(s) UDREN LAW OFFICES Ms. Read Crotumarty (I 1 NVanlCreSt Rd. Suite 200 Cherry Hill, NJ 08003-:1620 I _ Service of Procum by APS International, Ltd. r ' 1-800-328-7171 _ ._¢v ' rr(11M1. ? Am IN'tKRnA APS lll(eruatinaal Playa : t `= 7800 GItnray Rd. \, Mhuteapolis, MN 5,439-3122 r APS M1e#: 091662.0001 AFFIDAVIT OF SFRVICF -- Individual Service or Process on: -Christopher D. Lauver, by posting Court Caw No. 06-5815 State of: ) ss, County nf;-y'? r?7!^ ) Name of Server. X14' rin! Z5 . undcmigned, hcing duly sworn, depoics anti says that at the time of Service. Ac was of legal age and was not a party to this action; DutJTime of Service: that on the ?1'!`aay of? , 20 1, 3ln'clc?Ckh4 place of Service: Documents Served: at 46 War»iek CirCle(SllvcrS(jrint •1'wp) ._ • in Mechanicsburg, PA 17055 the undcrxigned staved the documents described as: Notice of Sherift's Sale of Real Property w! Order Service of Process on: A true and correct copy of the aforesaid document(s) was surved on: Chrtctopher 1), ianuver, by posting Person Served. and "" .. _. - .... _. Method of Service: 'ley 1lersonally delivering them into the hands of the person to be served. x BY delivering them into the hand, of , a person of'suitable age, who vcrilicd, or who upon qucstinning stated, that he/she residcs with Christopher D. Lauver, by posting at the place of .service, and whose relationship to the person is: Dmeription of Person The person receiving documents is described as follows: Receiving Documents: Sex ; Skin Color ; i•iair Color Facial Hair Approx. Age-, Approx. Auibht Approx. Weight l' i the best of my knowledge anti belief, said per.-)n was not engaged in the. US Military at the time of service. Signature of Server: Undersigned declares under penal:), of perjury Su ecribcd an sworn tr bcibrc me this that the foregoing is true pd cormet. ` daFel- y is 20 ignaturc of 5arve/ Notary Public (CommisstuIe Cx tres) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal ro. Cutmeeland t;aurl y ECixm"M46ma.r. . TMibfe, Notary Pubk on Eq);rsW. 11, 2010 Pwwaylverra Assorjuuon of Notarlos EXHIBIT B n r-1-1) O _ {_-_- ni r- :AJ t ,' LI I `'` l (} r .? ! t} r - W _1 ?..? az JP Morgan Chase Bank, as Trustee VS Christopher D. Lauver In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5815 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Christopher D. Lauver, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the within named defendant, Christopher D. Lauver. Twelve attempts at service were made, but no one was home. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 0945 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 Christopher D. Lauver located at 46 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriffs Costs: Docketing 30.00 Poundage 17.89 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 39.60 Certified Mail 5.34 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 331.10 Postpone Sale 40.00 Share of Bills 16.83 17,6 ? ? - 7/ $ 912.26 So Answer R. Thomas Kline, Sheriff BYG Real Estate rgeant (s y33"7 jwO y i 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 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver €N0. 06-5815 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank as Trustee, 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: 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Christopher D. Lauver 46 Warwick Circle 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 Silver Spring Township Authority 4. Name and address of of record: Name JPMorgan Chase Bank as Trustee 5. Name and address of on the property: Name 31 East Main Street, P.O. Box 1001 New Kingston, PA 17072 the last recorded holder of every mortgage Address 9275 Sky Park Court, 3rd Floor San Diego, CA 92123 every other person who has any record lien Address none r 4? 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 46 Warwick Circle (Silver Spring 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. DATED: November 28, 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 UDREN LAW OFFICES, P. Gtt kJ. en, ESQ. orney for Plaintiff 0 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 JPMorgan Chase Bank as Trustee €COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County v. :MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Your house (real estate) at 46 Warwick Circle, (Silver Spring 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 $158,498.81, 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 Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you'contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of-way line of warwick Circle at the ommon front property comer of Lot No. 20- 0 and Lot No. 20-E shown on the hereinafter mentioned plan of lots; thence along said •warwick Circle North 01 degreed 54 minutes 01 second East. a distance of 20.00 feet to a point at the dividing line between lot no. 20-C and Lot No. 20-D; thence along said dividing line B8 degrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the dividing line between Lot No. 19-A and Lot. No. 20-0; thence along said dividing line South 01 degree 54 minutes 01 second West, a distance of 20.00 feet to a point at the dividing line between Lot N020 - D and lot No. 20-E; thence along said dividing line North 88 degrees 05 minutes 59 minutes West, a distance of t 10.00 feet to #a point, said point being the place of BEGINING. CONTAINING 2,220.00. sgaure feet. BEING KNOWN AS: 46 WARWICK CIRCLE, (SILVER SPRING TOWNSHIP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 38-19-1621-183 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER D. LAUVER, A MARRIED MAN BY DEED FROM FINE LINE HOMES, INC. DATED 1/21/04 RECORDED 1/28/04 IN DEED BOOK 261 PAGE 2131. . r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-5815 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK AS TRUSTEE, Plaintiff (s) From CHRISTOPHER D. LAUVER (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 $158,498.81 L.L. $.50 Interest FROM 11/29/06 TO DATE OF SALE 3/7/07 - ONGOING PER DIEM OF $ 22.92 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $2,269.08 Atty's Comm % Due Prothy $1.00 `Atty Paid $117.04 Other Costs ° Plaintiff Paid Date: NOVEMBER 29, 2006 Curtis V Long, Prothon (Seal) 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 # 72 On December 4, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 46 Warwick Circle, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. GB Co dwyp" Date: December 4, 2006 By: GiD U © L t=V--a Real Esta e Sergeant THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin; ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ................... .......................................... COPY Sworn to and s sc i d ore me this 26th day of February 2007 A.D. S A L E #72 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Terry L. Russell, Notary Public City Of Har 'sburg, D hin County My CommiZrlEx ' June 6, 2010 Y CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Sil?_ . 1 .i y " .,?" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 26, February 2 and February 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 21 ?a- 41?- iMarie Coyn ditor SWORN TO AND SUBSCRIBED before me this 9 day of February, 2007 I\0 1 Vrl 1G,+ SEAL LOIS E. S'NY[TR, Nofarv Puhllc Carlls!c Boro, Gurnberlari Cousz_v V.,y CoIP:n-, iss ioi, I- f e s I'Liarc4l RLAL ESTATE BALE NO. 72 Writ No. 2006-5815 Civil JP Morgan Chase Bank, as Trustee VS. Christopher D. Lauver Atty.: Mark Udren ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of-way line of Warwick Circle at the common front prop- erty corner of Lot No. 20-D and Lot No. 20-E shown on the hereinafter mentioned plan of lots: thence along said Warwick Circle North 01 degreed 54 minutes 01 second East, a distance of 20.00 feet to a point at the dividing line between lot no. 20-C and Lot No. 20-1); thence along said dividing line 88 degrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the di- viding line between Lot No. 19-A and Lot. No. 20-1); thence along said dividing line South 01 degree 54 minutes 01 second West, a distance of 20.00 feet to a point at the divid- ing line between Lot No. 20-D and lot No. 20-E; thence along said di- viding line North 88 degrees 05 min- utes 59 minutes West, a distance of 110.00 feet to a point, said point being the place of BEGINNING. CONTAINING 2,220.00 square feet. BEING KNOWN AS: 46 WAR- WICK CIRCLE, (SILVER SPRING TOWNSHIP) MECHANICSBURG, PA 17055. PROPERTY ID NO.: 38-19-1621- 183. TITLE TO SAID PREMISES IS VESTED IN Christopher D. Lauver, a married man by deed from Fine Line Homes, Inc. dated 1/21/04 recorded 1/28/04 in Deed Book 261 Page 2131. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF r MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION ::Cumberland County V. ,MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $158,498.81 Interest From 11/29/06 12,858.12 to Date of Sale 6/11/08 Ongoing Per Diem of 22.92 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDRPA, EN LAW OFF C . BY a frlL?l i,, Attorneys-for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE J O' tl? -tJ _ Gu SLR b co v v - _ d ; _ . e IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CHRISTOPHER D. LAUVER Debtor Bk. No. 1:07-bk-00636 RNO HOMECOMINGS FINANCIAL, LLC, AS Chapter No. 13 SERVICER FOR THE MORTGAGEE OF RECORD Movant v. 11 U.S.C.§362 CHRISTOPHER D. LAUVER Respondent ORDER MODIFYING SECTION 362 AUTOMATIC STAY Upon Consideration of the Motion of HOMECOMINGS FINANCIAL, LLC, AS SERVICER FOR THE MORTGAGEE OF RECORD (Movant), and after Notice of Default and the filing of a Certification of Default, it is: ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided by 11 U.S.C. 362 is modified with respect to premises, 46 WARICK CIRCLE, MECHANICSBURG, PA 17055, as more fully set forth in the legal description attached to said mortgage, as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal or consensual action for enforcement of its right to possession of, or title to, said premises. Rdot N. Opd, A Bank *q JV* This document is ekLftr icaUy sgned and JiW on the same date. PQ Dated: December 28, 2007 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver :NO. 06-5815 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) x C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: x A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): x A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES\ P.C. BY L/V UAA VA ^ Gl Attorneys for- Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r ,? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver :NO. 06-5815 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is. ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFI,(;ZS, P.C. BY ?1???,ktn???v Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODC.REST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION :Cumberland County V. ;MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank as Trustee, 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: 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Christopher D. Lauver 46 Warwick Circle 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 none 4. Name and address of of record: Name JPMorgan Chase Bank as Trustee the last recorded holder of every mortgage Address 9275 Sky Park Court, 3rd Floor San Diego, CA 92123 5. Name and address of every other person who has any record lien on the property: Name Address Silver Spring Twp. Authority 31 East Main Street, P.O. Box 1001 New Kingston, PA 17072 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 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 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 46 Warwick Circle (Silver Spring 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. DATED: January 21, 2008 UDREN LAW OFFIC , P.C. BPM kAA? JAttorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r Or y • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee !COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Christopher D. Lauver NO. 06-5815 Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Your house (real estate) at 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $158,498.81, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 4r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5815 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK as Trustee, Plaintiff (s) From CHRISTOPHER D. LAUVER (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 $158,498.81 L.L. Interest from 11/29/06 to Date of Sale 6/11/08 ongoing per diem of $22.92 to actual date of sale including if sale is held at a later date -- $$12,858.12 Atty's Comm % Due Prothy $2.00 Atty Paid $1,050.80 Other Costs Plaintiff Paid Date: 1/25/08 Prothonota (Seal) By: REQUESTING PARTY: Name CHANDRA M. ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Deputy Supreme Court ID No. 203437 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadinas@udren.com JPMorgan Chase 9275 Sky Park San Diego, CA v. Bank as Trustee Court, 3rd Floor 92123 Plaintiff Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5815 VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: February 4, 2008 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 5, 2008 UDREN LAW OFFICES, P.C. L-- BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE JPMorgan Chase Bank as Trustee Plaintiff V. Christopher D. Lauver Defendant ,NO. 06-5815 O R D E R AND NOW, this f A'-Tu-ir\ day of Fe?ru-ax 20 upon consideration of Plaintiff's Motion a the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055. BY THE COURT: ell. A J. 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Z m W ? 9 9 mm E w Z J ? N m zm Z5 'J T N C N m m 88I m N i p g 1 M m N?VI? ? ccmi Eu ?Ti E :RQ.E a c?v Ec cm Jr Nln? As o c a ID m m ? ??WmmCOC C m'51! = m m ?? 0 §0 m c m y mm m ? c m Q a io mN? o c ma 7 C D 'W 2'i O E ` .m ?po Z??E c ®a•?- Cr T Ir I,o I-m lo IT IT IT V, Lf) 00 ?O d 09 07 N .0 to c ? V F J c m C m O c m .3 C. a m 0 v n z. O L6 rn rn LL ti ti O LL C? ° n c?_ '" ? : °', ? r'? -r?a rx'r;-? ;; cxa .?., ?r _ -, % . .?°- , ri . , -? . - -? > } `; UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 JPMorgan Chase Bank as Trustee COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Christopher D. Lauver . Defendant(s) :NO. 06-5815 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 Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May 16, 2008 UDREN LAW OFFICES, P.C. BY: ---t Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 JPMorgan Chase Bank as Trustee Plaintiff V. Christopher D. Lauver Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5815 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Christopher D. Lauver PROPERTY: 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 11. 2008, at 10:00 am, in 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 than 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 LL - o mac. y, W ma N E nQ m'2 E c a' o E" on' v w a m m` c:+2m0cop =W FALL E?omm E.m m c .O m - . Om tM $mw s0 °09 ` 0 oa L w IX fAli m W £ E L b O 1? d 80:$ !__ m 40 W OW i LL LL o m 10 r W mE o °° s= a v MOB W BBC ?Y B C ` d a t ? ; ?, nnE a m y o p m m 0v wpU E B SE e a o q ry W 0 ?U m m m` m5 a E9 ac?cc fL Ow v ? r -- ?? cm E v m v a °m m C 7 m O t ?- Ew C1 T E O LID dJ + r -„tF y"q b $ 'm O O EA - =13 0 0 1) IL 1 O. ` C d ?? o ? to m 0 It, I =U ° m Em y E 2 m:F,R 0. m " 41 4) mm E L W _ d LL m ?z o ?? w N ` ? 7 y U U W U U ?? ? ? `' a W QO ? a> O It w Or ° o Z tL 2 Wa a a a 00 O U c o 4 ?_ W¢ N ILL TO W a o F-a ? O N CV W O H- co z ?a C_>U - wo r LLJ it 146 ." ," ~ ?' C d wJ J 9 c" c? ?Z c+?Q a V , Q U O m> > 'C O I -A d W 'O E C W 'V W? ? m (0W o ° p t Ix r n L , 0 OZ z? za ti? wa a PS., O LL 0?? » Ow ol zV rY $ cax m w c°) v?i -j gcn ao ca z ay e? a Z?, W. C-4 Z Ir Z y 5 C ) C R Q 'L S C E W GDU Q mX w J 00 ZW to Z.- ? i 09 ;o 0 z m o0 P L ? ? o m d 01 N E OD N c ? W a?iv ? QZ c T .0 U ?dc E ? E?i c' zQ0 J N M 'W W co ti ao 0) ° r 04 L O H w 41 V V W m V d C LL 'p C .? U .. rn ?O rn ? o y ? J M O N d O CL w LL. EX HIB IT A v UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udx-en.com ATTORNEY FOR PLAINTIFF 1.0 JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS 9275 Sky Park Court, 3rd Floor :CIVIL DIVISION San Diego, CA 92123 : Cumberland County Plaintiff = . V. Christopher D. Lauver; 46 Warwick Circle ENO. 06-5815 Mechanicsburg, PA 17055 Def endant (s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER _ P,a m 3 The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: February 4, 2008 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 5, 2008 UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE EXHIBIT B UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU: - ID #04302 - ID #45362 - ID #34576 - ID #75860 rRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee 9275 Sky Park Court, 3rd Floor € San Diego, CA 92123 Plaintiff V. Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-5815 VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: February 4, 2008 Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 5, 2008 UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE EXHIBIT g EB 0 9 2007 P? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION JPMorgan Chase Bank as Trustee :Plaintiff V. NO. 06-5815 Christopher D. Lauver Defendant O R D E R AND NOW, this Xl day of Fc? 20 , upon consideration of Plaintiff's Motion a (the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant, Christopher D. Lauver, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant, Christopher D. Lauver, at 46 Warwick Circle, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 46 Warwick Circle, (Silver Spring Township)Mechanicsburg, PA 17055: BY THE COURT: J. EXHIBIT $ -4 TRICE COPY FROM RECORD In Testimony f here unto set my hand 4' Y H O x14?-. n (D of ::r ? K P) 0) N ?j n rt ?::E O c? 1 - ro w n ? tY P ? w ?n'- d n 'V (D P 1 ' 4 J (D O Ul 1^ VI Q Q? J vQ? Q C 0Q C 1'-Q3lQ Z ,mom o ? D m 0 C to 30, o:8 ?DM 0 Z' -i M M (Domestic Mail Only: No Insurarice Co verage Provided) m, - a a For delivery information visit our vjebsitF- a t wwvd us s com L, in OFFICI AL . p . ., USE I cc CO a a ? Postage $ 0 0 n ? Certified Fee O( a;a Postmark O O O r Return Receipt Fee (Endorsement Required) / er Here H O a Restricted Delivery Fee im r-3 (Endorsement Required) Lr7 I U7 _r _I- Total Postage & Fees ,$ M m -?' -D to Christopher D. Lauver C3 C3 C3 n - ----- ? `N` 46 Warwick Circ P ----------- le O BoxNa or --- - cnr srere.z? Mechanicsburg, PA 17055 ...------ 1 R Y i 0 W -LK I 0 ?_1 O 3 z :3' ::E: N- 7 0 =RE cp Gi m P) A) ErI 3 ? N- E O ? V P' !D r- FI IS ua F'- q ? m a IF m OZ b F-? r w ^? ? Q• Q ? (D ¢J =r m c o-' J N $ C) Fj w to m 1.n O C3 A k A O ? m• co L-j 03 F CL Ln ? ? a L-i w O 02 1 og 3 ? ? ?? ?? o? ?i 008-00- 0 oesa wed (-U) WO Wdinv ODW -0:1 sd •Ailubul ne 8upew uegA?11 lueseid pue 1dlesei slgl BARS '1NV1!lOdWl IteW PeBlt119 a ug GBMBod EMM fegel XWO pue 4"WP `pepeeu iou sl idleow -!i.ie ay;;uese?d saes gwisod ell 15uppoupod io; soWo isod e4; ie a lo Id 'pei!eep sl idiom ugW pe!pueo eta uo )peugsod 811 • ffl pe;pll;OB}j. wewswopue eta yilM aoa!dl!ew 84l mew jo e o e k&Aj et sw o )pI 4i es!npV •lue a Pezuo4ine s'eftwuppe PPe e4i of peiolmoj eq Aew Aienllep `ea; leuoMPPe us and . s! idiom IIeW poWoo moA uo ®Sdsn a Idiom wnpu pw!nbw sido X4 Jen!eM 99; aenpM-of lldnP e e4i,enai of eBeisod.e H i d wniea BOeldllew eaiopu3 •e e; wryeb a 40Ile pug I mieeeeppe pue GPM e4i of 11186 uuoJ Sd) id! 091:1 sioldwoo ;o;oo?d eplnad of peisen eq ?Cew;dn?et{?wed a of Aien!leP ;1UuopIPPe uU joj ¦ Jod -IIeW P94RJOO 141! WW a C)bd si swumoo 3oN dnSNl ON 6 TOW leuogeweiul;O SOUP Am X1 elgUuene;OU O! IM" PeW03 ¦ 's'IIeW Mmd ao 6119h SMlO-Wjl=l 4pm peulquroo eq IINO AUw IM Pe!}AieO . mopu;uipa lueuodw; WOA oMi JO; aolaeS Iereod 9W Aq idoM AieMlep;o pjooei y ¦ eoa!dllew JnoA ao; jewepl enblun d ¦ idlsm &41mw d ¦ :SBPIAOUd HOW Pe!!!IJ93 m LL E a m u W G m g W Co m m' O o m E m c q m- c IY ?yr n Eedgiy E Q m. S W C6 LL. . .c c Em=c E . R c:.o N ? m m T6 m " ID n m ._ ??}} wamv '0 O? fn LL I T 7 N m a Z c`o y LLd \ m? i ID ? A Yl .E •p Q s m c m on ° n Ew?'m Sm_ ,+.. a c m np R . .d OM o -at v o f ?. E c EaiE?.cc W-8 Q U W n ?r ', i ?. c n m« m c E m Wm m . . ., L 0 CD C ` LL m 7 E f c cy O C Cam. . !.? c 7 C E _C a 5 -.m ovoymfo C m . ? .2 Lo m <'m ? m m maoo 1' ° m E n W tp •? Qao mm N m rn a,m c a'o o-- Q ma s 'o c 0 a '-"`c n Ea. 0 ? o m `W o W ,.;CD .cc . + . N >. y -r m=? m o>33 °fm ?.rn L? 6 E_ d ae?E ;?.?? L to 0'6 o E c.? _. U S - y a m m 2°i m c m E c m o 7 m R a n 2, m e rag - II .fl_ m m Ir y In LL V E:6 ff m . W_. 21 W Sul ami ? 0? a W d 0 lp "a y ?0 d firSUC? m X100 m m a m UJ m Z v a LU O ai ai m b U m G ' W W t- c v E b a;w co a -4 w 0 ? V to p w U IL w W c ?0j-W LL '"? U N ?? my V.. •EE ,Uj ? J co < I - L 2 ?to0- CL w ? Q o O a o ?a m Co Lli 0, m c o ? ? r C1 'O? a? L . U? Go n M - Z C D c c o o c 6 c m y o o L) a S o to E C c ? n d Q D J N M V, L CD c 1 - C D 01 - 7 r M r . -- F m- J EXHIBIT 13 L1 a_ C n a_ m O AV L L H sC m D .Q 1 -2 O LL J ? _rn m O d LL A co vn E O LL a JP Morgan Chase Bank as Trustee Vs Christopher D. Lauver In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5815 Civil Term Ronald E. Hoover, who being duly sworn according to law, states that on March 31, 2008 at 2048 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Christopher D. Lauver by posting the premises pursuant to a Court Order, at 46 Warwick Circle, Mechanicsburg, PA 17055, Cumberland County, Pennsylvania. Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 0910'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 Christopher D. Lauver located at 46 Warwick Circle, 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 defendant, to wit: Christopher D. Lauver by regular mail to his last known address of 46 Warwick Circle, Mechanicsburg, PA 17055. This letter was mailed under the date of April 01, 2008 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff B Real Estate geant 4&1e,;?- JP Morgan Chase Bank as Trustee Vs Christopher D. Lauver In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5815 Civil Term Ronald E. Hoover, who being duly sworn according to law, states that on March 31, 2008 at 2048 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit; Christopher D. Lauver by posting the premises pursuant to a Court Order, at 46 Warwick Circle, Mechanicsburg, PA 17055, Cumberland County, Pennsylvania. Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 0910 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 hristopher D. Lauver located at 46 Warwick Circle, 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 defendant, to wit: Christopher D. Lauver by regular mail to his last known address of 46 Warwick Circle, Mechanicsburg, PA 17055. This letter was mailed under the date of April 01, 2008 and ne er returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Arkemal Sheriff s Costs: Docketing 30.00 Poundage 17.39 Posting Handbills 15.00 Advertising 15.00 Posting 6.00 Prothonotary 2.00 Mileage 17.28 Levy 15.00 Surcharge 20.00 Postpone Sale 40.00 Law Journal 355.00 Patriot News 339.38 Share of Bills 14.73 $ 886.78 t% So Ans r' r R: Thomas Kline, Sheriff BY Real Estate rgeant ??/D p f a p J.0-0 1,;? q3 d i5'e, 30 V J UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee ;COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County V. MORTGAGE'FORECLOSURE Christopher D. Lauver NO. 06-5$15 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank as Trustee, 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. 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Christopher D. Lauver 46 Warwick Circle 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 slold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: i Name Address JPMorgan Chase 9275 Sky Pa k Court, 3rd Floor Bank as Trustee San Diego, 92123 I ? y 5. Name and address of every other person who has any record lien on the property: Name Address Silver Spring Twp. Authority 31 East Main Street, P.O. Box 1001 New Kingston, PA 17072 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 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of.Revenue 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 46 Warwick Circle (Silver Spring 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. DATED: January 21, 2008 UDREN LAW OFFIC , P.C. BV? )2 YJAhd I ?01 Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAI E DOYLE, ESQUIRE ALAN M MINATO, ESQUIRE CHAND M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODC.REST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee 'COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION :Cumberland County V. !MORTGAGE FORECLOSURE Christopher D. Lauver ';NO. 06-5815 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank as Trustee, 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: 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed owner(s): Name Address Christopher D. Lauver 46 Warwick Circle 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 none 4. Name and address of the of record: Name JPMorgan Chase Bank as Trustee last recorded holder of Address 9275 Sky Pa Court, San Diego, 92123 every mortgage 3rd Floor r 5. Name and address of every other person 'who has any record lien on the property: Name Address Silver Spring Twp. Authority 31 East Main; Street, P.O. Box 1001 New Kingston, PA 17072 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 46 Warwick Circle (Silver Sprung 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. DATED: January 21, 2008 UDREN LAW OFFICK, P. C. Bid : Ni lA N U-4 AbgLl A 1 N/ U.? KJ.^ Atforndys for Plaintiff MARK J., UDREN, ESQUIRE STUART'WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHAND M. ARKEMA, ESQUIRE 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 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. MORTGAGE'FORECLOSURE Christopher D. Lauver NO. 06-5015 Defendant (s) C E R T I F I C A T ''E Mark J. Udren, Esquire, hereby stated 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. OFFWgS, P.C. BY Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ' LORRAI E DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHAND M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com JPMorgan Chase Bank as Trustee :COURT OFII',COMMON PLEAS Plaintiff CIVIL DIVISION ,Cumberland County V. :"MORTGAGE FORECLOSURE Christopher D. Lauver ::NO. 06-5$15 Defendant(s) To: Christopher D. Lauver 46 Warwick Circle Mechanicsburg, PA 17055 Your house (real estate) at 46 Warwick Circle, (Silver Spring Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 11, 2008, at 10:00 'am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carli le, PA, to enforce the court judgment of $158,498.81, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Salle. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALP To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to thelmortgagee the back payment, late charges, costs and reasonable attorney' fees. To find out how much you must pay, you may call: 856 669-5 00. 2. You may be able to stop the sale by filing alpetition asking the Court to strike or open the judgment, if the judgm nt was improperly entered. You may also ask the Court to postpone the s le 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 stoppi g the sale. (See notice on page two on how to obtain an attorney.) 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a'deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIPADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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. ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more paRicularly bounded and describled as follows, to wit: BEGINNING at a point on the eastern right-of-way line ofwarwick Circle t the mmon front property corner of Lot No. 20- 0 and Lot No. 20-E shown on the hereinafter mentioned pi n oflots; thence along said warwick Circle North 01 degreed 54 minutes 01 second East, a distance of 20. feet to a point at the dividing line between lot no. 20-C and Lot No. 20-D; thence along said dividing line 88 agrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the dividing line between Lot No. 9-A and Lot. No. 20-D; thence along said dividing line South 01 degree 54 minutes 01 second West, a distan of 20.00 feet to a point at the dividing line between Lot No20 - D and lot No. 20-E; thence along said dividing line North 88 degrees 05 minutes 59 minutes West, a distance of 110.00 feet to a point, said point being the place of BEGJNING. ' CONTAINING 2,220.00. sqaure feet. BEING KNOWN AS: 46 WARWICK CIRCLE, (SILVER MECHANICSBURG, PA 170,5 PROPERTY ID NO.: 38-19-1621-183 TITLE TO SAID PREMISES IS VESTED FROM FINE LINE HOMES, INC. DATED BOOK 261 PAGE 2131. SPRING TWP) IN CHRISTOPHER D. 1/21/04 RECORDED LAUVER BY DEED 1/28/04 IN DEED WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5815 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK as Trustee, Plaintiff (s) From CHRISTOPHER D. LAUVER (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 de ivering 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 $158,498.81 L.L. Interest from 11/29/06 to Date of Sale 6/11/08 ongoing per diem o? $22.92 to actual date of sale including if sale is held at a later date -- $$12,858.12 Atty's Comm % Due Prothy $2.00 Atty Paid $1,050.80 Plaintiff Paid Date: 1/25/08 (Seal) REQUESTING PARTY: Name CHANDRA M. ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 By: Deputy Supreme Court ID No. 203437 l'?rJ Real Estate Sale # 32 On February 21, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 46 Warwick Circle, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 21, 2008 By:, ;,rYL Real Estate ergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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 -arid 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 c urts as the official legal periodical for the publication of all legal notices, and has, sinc 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 issu s of the said Cumberland Law Journal on the following dates, and Mav 16.2008 Affiant further deposes that he is authorized to verify tl Law Journal, a legal periodical of general circulation, and that matter of the aforesaid notice or advertisement, and that all all statements as to time, place and character of publication are tr SWORN TO AND 16 day of _ statement by the Cumberland is not interested in the subject itions in the foregoing e' ,O ,Editor JBSCRIBED before me this 2008 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28.2010 i? ONVAM NASD 1o. as Writ No. 2006-5815 Civil JP Morgan Chase Bank as Trustee vs. Christopher D. Lauver Atty.: Chandra Arkema ALL THAT CERTAIN piece or par- cel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of-way line of warwick Circle at the common front property comer of Lot No. 20-D and Lot No. 20-E shown on the hereinafter men- tioned plan of lots; thence along said warwick Circle North 01 degreed 54 minutes 01 second East, a distance of 20.00 feet to a point at the dividing line between lot no. 20-C and Lot No. 20-D; thence along said dividing line 88 degrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the dividing line between Lot No. 19-A and Lot. No. 20-1); thence along said dividing line South 01 degree 54 minutes 01 second West, a distance of 20.00 feet to a point at the dividing line between Lot No20-D and lot No. 20-E; thence along said dividing line North 88 degrees 05 minutes 59 minutes West, a distance of 110.00 feet to a paint, avid point being the pkwe of BEGINNING. CONTAINING 2,220.00 sgaure feet. BEING KNOWN AS. 46 WARWICK CIRGIL? VXR SFFMG TW", ME- CHANICOWNG, FA 17055. PROPERTY ID NO.: 38-19-1621- 183. TITLE TO SAID PREMISES IS VESTED IN Christopher D. Lauver by deed from Fine Line Homes, Inc. Dated 1/21/04 recorded 1/28/04 in Deed Book 261 Page 2131. Athe Patriot-News Co. . ' 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the Patriot News Now you know CARLISLE PA 17013 i THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 1 , 1929 Commonwealth of Pennsylvania, County of auphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and sa?s: That he is the Assistant Controller of The Patriot News Co., a corporatio 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 St eet, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 18 4, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto i exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated bel w. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all f 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 autho ized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution u animously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly ecorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 17. PUBLICATION COPY This ad ran on the date(s) shown below: 04/23/08 04/30/08 05/07/08 To)'Iwi?;7. .......... Sworn to a(id subscribed before me this 27 day of May, 2008 A.D. Notary Pu81ic COMMONWEALT OF PENNSYLVANIA Notai.al sea] Chyle L. S rd, Notary Public ( y Of Harrisbu ,Dauphin County MY Commission res May 29, 2mo Member, Pennsylvania Association of Notaries Real Estate Sale #32 Writ No. 2006-5815 Civil Tenn JP Morgan Chase Bank as Trustee VS Christopher D. Lauver Attorney: Chandra Arkema DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of- way line of warwick Circle at the' common front property corner of Lot too. 20-D and Lot No. 20- E shown on the hereinafter mentioned plan of lots; thence along said warwick Circle North 01 degreed 54 minutes 01 second East, a distance of 20.00 feet to a point at the dividing line between lot no. 20-C and Lvt No. 20-1); thence along said dividing line 88 degrees 05 minutes 59 seconds East, a distance of 110.00 feet to a point at the dividing line between Lot No. 19-A and Lot. No. 20-1); thence along said dividing line South 01 degree 54 minutes 01 second West, a distance of 20.00 feet to a point at the dividing lice between Lot No20-D and lot No. 20-E; thence along said dividing line North 88 degrees 05 minutes 59 minutes West, a distance of 110.00 feet to a point, said point being the place of BEGINNING. CONTAINING 2,220.00 sgaw feet. BEINGKNOWNAS: 46 WARWICK CIRCLE (SILVER SPRING TWP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 38-19-1621-183 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER D. LAUVER BY DEED FROM FINE LINE HOMES, INC. DATED 1/ 21/04 RECORDED 1t28/04 IN DEED BOOK 261 PAGE 2131.