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Home My WebLink About06-6581UDREN 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon :Cumberland County Mortgage Services, Inc. as its Attorney-in-Fact 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry NO.?(e 2103 Aspen Drive Mechanicsburg, PA 17055 Defendant(s) IeSl? eLU 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: First Franklin Financial Corp., Subsidiary of National City Bank of Indiana Assignments of Record to: Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Recording Date: LODGED FOR RECORDING 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 2103 Aspen Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 6/30/04 DATE RECORDED: 7/22/04 BOOK: 1874 PAGE: 2205 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 10/31/06: Principal of debt due $146,980.23 Unpaid Interest at 8.75% from 3/1/06 to 10/31/06 (the per diem interest accruing on this debt is $35.23 and that sum should be added each day after 10/31/06) 9,901.86 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) is account w s h m h should sum that and $0 is be added on the first of each month after 10/31/06) 1,496.00 Late Charges (monthlyy late charge of $58.60 should be added in accordance with the terms of the note each month after 10/31/06) 454.00 Property Inspection 47.70 Expense Advance 56.00 Attorne s Fees (anticipated and actual to 5% oy principal) 7,349.01 TOTAL $166,859.80 * 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, reasonab le 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 $166,859.80 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. C--Iyu Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN house or lot of ground situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point itz the northeasterly line of the public road leading to U.S. Route 15, TrafF Route 114 (LaR. 416), which said point is in the divisinn ling hi-mrsen Lott P15. 144 a,ul 143 on the nereinatter mentioned Plan of Lots; thence along the division line between Lots 144 and 145 on said Plan, North 30 degrees 26 minutes East, one hundred thirty and fifty four hundredths (130.54) feet to a point in the division line between Lot No. 145 and 143 on said plan; thence along the division line between Lots 145 and 143 and Lots No. 145 and 142, South 59 degrees 34 minutes East, ninety (90) feet to a point in the division line between Lots No. 145 and 146 on said Plan; thence ng the division line between Lots No. 145 and 146, South 30 degrees 26 minutes Wes , one hundred thirty and fifty"tour hundredths (130.54) feet to a point in the northeasterly line of the public road leading to U.S. Route 15, Traffic Route 114 (L..R. 416), aforementioned; thence along the northeasterly line of said road, North 59 degrees 34 minutes West, ninety (90) feet to a point in the division line between Lots No. 144 and 145, at the point and place of M; NING. ` BEING Lot No. 145, Section 2 of the Corrected Subdivision Plan of Spring Run Acres, recorded in Plan Book 19, page 7, Cumberland County'Records. HAVING thereon erected a dwcIling house known as 2103 Aspen Drive. 9+70r 264 NU1402 .r September 6, 2006 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A Page 1 of 1 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Robert D. Hockenberry _.___....__..__. _.._Karen_M._H.... erry__.... _...... _____....... __..... ........ ._.__........ _............. 2103 Aspen Drive _.__... _Mechanicsburg, _PA 17055 ........ _.___.._._.__..... _._....... _..... _..__._....._....... _...... 1044312953__.... First_Franl l n._Financial...Corp......... ...... -.--_---._....--.--..._._._..... .._..__...._._.._......... _....... ---._.-.... --......._.... _...... _._...__.......... __.._........ _...... __.... .... _........ HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RF ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), 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 FORECLOSITRF. -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN D DHOW TO CURE YOUR MORTGAGE DEFAULT RI AGE I TP TO DATE CONSUMER CREDIT 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, nam-es, addresses and telephone numbers of desio ated consumer credit counseling agencies for the county in which the pi:o12eerty is located are get forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatel; 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 Page 2 of 2 , face- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 2103 Aspen Drive Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $1923.02 for August 01,2006 thru September 01,2006 = 3846.04 _.__...... _Monthl_Payments of117219_for_April_01,2006 thru...,?uly_ 01,2006_=__$4688..76-._........... -..--.__.......... Monthly Payments of $73.20 for August 01,2006 _Monthly _Late Charges_of _$58.60_for _April 01,2006 thru_ Iuly_ 01.,2006..._.=-.$234.40 .................... --..... -_-......... ......... Other charges (explain/itemize): Other Fee = $75.00 Expense Advances = $56.00 _Pr .Inspect on =X31.80._._...._..-----.-- ............ ...... -................ --.----.......... ------ ---- . _TOTAL AMOUNT_PAST_DUE:--........... -.... ----......... --------..... -......... ................. ---._............_-...._-.....-........... _-.-........... -.........--..__......$2QQ5.24.... B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not annlicahle): hU HOW TO CIIRF. THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 19.20. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaUmentc mutt he made either hy_s?sh cashier's check certified check or money order made payahle and sent to- Udren Law Offices, P.C. Wooderest Corporate Center 111 Woodcrect Road, S ui 200 Cherry Hill,, NJ 08003-3620 Page 3 of 3 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do net use if not applicable-l: hU IF YOU DO NOT CURE THF. DF,FATILT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend-, to exercise its rights to accelerate the mortgnge debtThis means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose ulloiLyour mortgaged prronertvy, IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable 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 yo j e ure h default within the THIRTY 1301 DAY period. you will not he reuir d to ilayattorney's feec- OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CI1RF THE DEFAULT PRIOR TO SHF.RiFF'S SAi,F -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yens ill have the right to ;,, .uritina by the hurler and by nerformin any ether reo iirem .nts 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. FART TEST POSSiRi F. SHERIFF'S SALE DATE, -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: Saxon Mortgage_Services............. ....... _........ __._._ ........ _...... Address: 4708 Mercantile Drive North Fort-Worth, TX_76137 __.......... _..... -_......... _........... ................... _.......... _._._.... .... ............ _.......... Phone Number: -._8.0-874-9576._._... ----......... _..__.... ....... __........ --------........... --....................................... Fax Number: 871-665-7750-.-...._._....... ------ ---- - ---- ......... --.--_---- .............. -__..-...... --..... _.-..... _............. Contact Person: Loss_Mitigation lossmit@saxonmsi.com............_._.........._........_......___._...___..._........ EFFECT OF SHF,RiEES SAi,F, -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs 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 not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 irtified Mail Provides: A mailing receipt {as -ad) zooe aunt,ooec uua; A unique identifier for your mailpiece A record of delivery kept by the Postal Service for two years 7ortant Reminders: :ertified Mail may ONLY be combined with First-Class Maike, or Priority N certified Mail is not available for any class of international mail. NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. raluabies, please consider Insured or Registered Mail. =or an additional fee, a Return Receipt may be requested to provide proo ielivery. To obtain Return Receipt service, please complete and attach a Ret ieceipt (PS Form 3811) to the article and add applicable postage to cover ee. Endorse mailpiece "Return Receipt Requested". To receive a fee waiver i duplicate return receipt, a USPSO postmark on your Certified Mail receip equired. =or an additional fee, delivery may be restricted to the addressee iddressee's authorized agent. Advise the clerk or mark the mailpiece with indorsement 'Restricted-Delivery°. f a postmark on the Certified Mail receipt is desired, please present the a ;le at the post office for postmarking. If a postmark on the Certified N eceipt is not needed, detach and affix label with postage and mail. 3ORTANT: Save this receipt and present it when making an inquiry ernet access to delivery information is not available on mail tressed to APOs and FPOs. ? N N : C ? d O Q Q O } Z t 2 r M > ? ?? iti ?? - o T a U o s? _ a 9? y a p m ?a) l c k w U x Z m ? ? W` C_ m n m m a v 9 c? m m o C3 c a CL '0 m v > > m r m> O O O C ¢ c in to ? d X of i N m N 4 ? f E a ° } Q U ?N? 0 , L o to 0 U5 ' U) a 0 ¢. NCYE U U Ch ? N N > CD Co CL C C C CO v l Q i C,j :3 0 N O C <`-t7?- ` v N N ` N U N C ~ U co ca V O U) ?I aa) d N a) CC v Q 0 Q? U C ) , o r 0 0 c o r rn rv N S IT, r? 0 O C3 rI C3 m O ...0 O O t~ a m o_ E 3 m N N E 0 t o 0 N N m Ca U N m w D ? f E r ap Z Q co h E u c O a LL N a O C3 O C3 Er U"• sea= v a6elsod MOM O p CP C32 (pannbadluawas?opu3) Lf L_ aad Nani?aO PaloulsOU Q M (pann .8luawas?opu3) O O •?? a?aH aad idieoey wniad O O )ixewlsod n aad P80180 [=I C3 a6elsod E rU ru -?? W W v ,? • ---jjNfW 091=11183 •d a? c a) U a) p M a3 o V1 ?- O H OO U a-- 8 ate- N -? C) C) 2 Z co a) o 0 2 J V O 0 C 6 Q) ` CD 00 r L U) C) LO Q L - Q Q c n L U 0 _ N cp N Q ca CO L ? O (D Yc•,2 O) .ertified Mail Provides: (esjeney)zoozeunr'oosc-a A mailing receipt A unique identifier for your mailpiece E A record of delivery kept by the Postal Service for two years mportant Reminders: i Certified Mail may ONLY be combined with First-Class Mello or Priority h i Certified Mail is not available for any class of international mail. i NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. valuables, please consider Insured or Registered Mail. i For an additional tee, a Return Receipt may be requested to provide pra delivery. To obtain Return Receipt service, please complete and attach a Re Receipt (PS Form 3611) to the article and add applicable postage to cover fee. Endorse mailpiece"Return Receipt Requested". To receive a fee waive. a duplicate return receipt, a USPSO postmark on your Certified Mail receil required. i For an additional fee, delivery may be restricted to the addressee addressee's authorized a ent. Advise the clerk or mark the mailpiece with endorsement 'Restrictedelivery'. i If a postmark on the Certified Mail receipt is desired, please present the cle at the post office for postmarking. If a postmark on the Certified I receipt is not needed, detach and affix label with postage and mail. MPORTANT: Save this receipt and present it when making an inquir nternet access to delivery information is not available on mail addressed to APOs and Ms. d N > .- 41 y '6 O Q Q O ??Io U E Z v CL n m ? D in N 0 } Z 4Ei O N ? 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L LO C) r- a c a O O = C .Q Cl) Q'^ U) Q c6 Q C) U O ?- O y N Z cil N4. ? n V ? 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. Mark J. Udren, E QUIRE UDREN LAW OFFICES, P.C. 1? V C/o 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its € Attorney-in-Fact :NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) 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 Complaint in Mortgage Foreclosure upon Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry by regular mail and certified mail and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant (s) at 2103 Aspen Drive, Mechanicsburg, PA 17055, which is the mortgaged premises. 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(s). 4. The last known address of Defendant(s) 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 Complaint in Mortgage Foreclosure upon said Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY. Mark J. Udren, Esquire' 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 Wells Fargo Bank National ::COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan 'Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its € Attorney-in-Fact NO. 2006-06581 Plaintiff V. Robert. D. Hockenberry Karen M. Hockenberry Defendant(s) 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 affidavit 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 sheriff's return of "not found" or the fact 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. As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage Foreclosure. A good faith effort to discover the whereabouts of the Defendant(s)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 Complaint in Mortgage Foreclosure upon Defendant (s) by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. By: Mark J. U ren, Esquire Attorney for Plaintiff SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06581 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOCKENBERRY ROBERT D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT HOCKENBERRY ROBERT D 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 2103 ASPEN DRIVE APPEARS VACANT. MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: So answers: sue" Docketing 18.00 Service 8.80 =? ... Not Found 5.00 R. Thomas K1 Surcharge 10.00 Sheriff of Cumberland County .00 41.80 UDREN LAW OFFICES 12/05/2006 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06581 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOCKENBERRY KAREN M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE ,. the within named DEFENDANT 2103 ASPEN DRIVE NOT FOUND , as to HOCKENBERRY KAREN M MECHANICSBURG, PA 17055 2103 ASPEN DRIVE APPEARS TO BE VACANT. MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: So answers: Docketing 6.00 Service .00 Not Found 5.00 R. Thomas -ne Surcharge 10.00 Sheriff of Cumberland County .00 21.00 UDREN LAW OFFICES 12/05/2006 Sworn and Subscribed to before me this day of A. D. Players National Locator, Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 05080618 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number. Subject: Robert and Karen Hockenberry A.K.A.: Robert D Hockenberry Karen M Hockenberry, Karen M Walters, Karen M Salter Last Known Address: 2103 Aspen Drive Mechanicsburg, PA 17055 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 11106/2006, 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):163-54-8870 177-62-1110 B. EMPLOYMENT SEARCH: We were unable to verify current employment for Robert D Hockenberry or Karen M Hockenberry. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Robert D Hockenberry and Karen M Hockenberry is 2103 Aspen Drive, Mechanicsburg, PA 17055 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing for Robert D Hockenberry or Karen M Hockenberry. We called (717) 766-2771 and spoke with a relative who stated Robert D Hockenberry and Karen M Hockenberry are living at 2103 Aspen Drive, Mechanicsburg, PA 17055. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of November 03, 2006 the National Change of Address (NCOA) has no change for Robert D Hockenberry or Karen M Hockenberry from 2103 Aspen Drive, Mechanicsburg, PA 17055. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license information for Robert D Hockenberry or Karen M Hockenberry. OTHER INQUIRIES - A. DEATH RECORDS: As of November 03, 2006 the Social Security Administration has no death records on file for Robert D Hockenberry or Karen M Hockenberry and/or A.K.A's under the soriaLsecurity numbers provided. EXHIBIT 9 109-1 800A 116-1 8990 0£Z 9£9 U011U aossy s,J8AB1d-w0aj wd1Z:Z0 90-90-AON B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None Found. C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: Robert - August 1968 Karen - September 1969 1,4 A A, v W AF IANT Melissa Kozma ansy5worn to beyore rpe o)P11 Kristine M. Soott, Notery Public St. Louis County, State of Missouri My Commission Expires 9/2/2010 Commission Number 06428665 PUBLIC Players National Locator, Inc. 174 Clarkson Road, Suite 225 St.Louis, MO 63091 Phone: (636)230-9922 Fax: (636)230-0558 109-1 600 * d 116-1 8550 0£Z 969 u014E POSSY s, J9AE i d-w0a j wd8Z: ZO 90-90-AON 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 MOTION FOR 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: December 15, 2006 Mark J. Udren, Esquire 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 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) 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(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Certified Mail Other Date Served: December 15, 2006 TO: Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 UDREN LAW OFFICES, P.C. By Mark J. Udren, Esquire Attorney for Plaintiff DEC 19 2006p+y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its € Attorney-in-Fact NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) O R D E R AND NOW, this a Ooh day of e-c e-+M ? u- , 2004 , upon consideration of Plaintif f' s Motion and the Af f idavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry at 2103 Aspen Drive, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 2103 Aspen Drive, Mechanicsburg (Upper Allen Township), PA 17055. BY THE COURT: 0j. 7 d t .! ?, t r .,? ., UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact €:NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: January 2, 2007 UDREN LAW OFFICES, P.C. Mark J. ren, ESQUIRE ATTORNEY FOR PLAINTIFF na ° o O A i1E1 a' -n C ' w i'i ©1 CO SHERIFF'S RETURN - NOT FOUND • A CASE NO: 2006-06581 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT uflrv,PNTP7PPv PnPWRT T) but was unable to locate Him in his bailiwick. He therefore returns the /' RffT T T TATT Afff1T-) T L/-INn T7 NOT FOUND , as to the within named DEFENDANT HOCKENBERRY ROBERT D 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 2103 ASPEN DRIVE APPEARS VACANT. MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: Docketing 18.00 Service 8.80 Not Found 5.00 Surcharge 10.00 .00 ? 41.80 -G'7 pig So answers: .. ----??? R. Thomas Kl e Sheriff of Cumberland County UDREN LAW OFFICES 12/05/2006 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06581 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOCKENBERRY KAREN M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT NOT FOUND , as to HOCKENBERRY KAREN M 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 2103 ASPEN DRIVE APPEARS TO BE VACANT. MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: So answers: Docketing 6.00 ` Service .00 Not Found 5.00 R. Thomas line Surcharge 10.00 Sheriff of Cumberland County .00 21.00 UDREN LAW OFFICES -4-07 ckV6 12/05/2006 Sworn and Subscribed to before me this day of A.D. ' 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF Wells Fargo Bank National :COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan :Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its : Attorney-in-Fact :NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry 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 Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED: 1 \ (0o Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive 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 relating to unsworn falsification to authorities. I UDREN LAW OFFICES, P.C. Dated: ?-4 JA Mark J. Udre , Esq ire Attorney for Plaintiff • 1 \? V i J 9 ESNs ? O o?Lo m C7 'tl ?mn Y? 14 s fi .. a ?1P K ' h k1 7°?P r•?. ?`? 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I!gW pelllu80 ¦ t tGIMW AIUOM JO ®IRW ssel0-;silk 4;uw peu!gwoo eq A-INO heal I!vW pe4wao ¦ mopu;umbf jusliodw; sigeR omi io; eolnieS Msod e4; Aq;deM fjenllep;o piooel v ¦ eoe!dllew inoA io; ieRRuspl enblun y ¦ ;dleosi BuIllew y ¦ :SBPIAOad IIeW P6I1I1183 i S" N1KYQ y ?..} ? , 4" .++ RJ ??{ 1 +r.l ! , '41 ?? ,, ;. . ? ,.. ... _ -ri -G ....± UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Wells Fargo Bank NA, as Trustee :COURT OF COMMON PLEAS for First Franklin Mortgage :CIVIL DIVISION Loan Trust 2004-FFH3 By: Saxon :Cumberland County Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. Robert D. Hockenberry :NO. 06-6581-CIVIL TERM Karen M. Hockenberry - 2103 Aspen Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Robert D. Hockenberry and Karen M. Hockenberry 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 $166,859.80 Interest Per Complaint 3,699.15 From 11/1/06 to 2/13/07 Late charges per Complaint 175.80 From 11/1/06 to 2/13/07 TOTAL $170,734.75 I hereby certify that (1) the addresses of the laintiff and Defendant are as shown above, and (2) that notice has een given in accordance with Rule 237.1, a copy of which is attached 1reto. LAW OF?ZES, P.C. -.- -..-, ..w ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE :ES `, ,- azQ7 PRO P HY UDREN LAW OFFICES, P.C. ATTORNEY FOR 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 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) TO: Robert D. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 DATE of Notice: February 2, 2007 IMPORTANT NOTICE PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-6581 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR T COLLECTION PRACTI S ACT, THIS LAW FIRM IS _0 Z DEEMED TO BE A DEBT COLLE THIS IS AN ATE T TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL USED OR THWP?gURPOSE odcrest Corporate Center ll Woodcrest Road, Suite 200 Cher Hill, New Jersey 08003-3620 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 856-669-5400 Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) TO: Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 DATE of Notice: February 2, 2007 IMPORTANT NOTICE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO.06-6581 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 t 800-990-9108 / NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES A , THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTO AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE US D FOR THAT PURPOSE. odcrest Corporate?Center 1111 Woodcrest Road, Suite 200 Chertty Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-6581-CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age. Residence: Employment: Defendant: Age. Residence: Employment: Robert D. Hockenberry Over 18 As captioned above Unknown Karen M. Hockenberry Over 18 As captioned Unknown Sworn to and subscribed before me this 13th day of February, 2007. Nt?tl?t ` Pub'1'Yc " abo MARK UDREN, ESQ. Namel: Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. SHERIFF'S RETURN - REGULAR CASE NO: 2006-06581 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOCKENBERRY KAREN M DEFENDANT the at 1330:00 HOURS, on the 10th day of January , 2007 at 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 2103 ASPEN DRIVE MECHANICSBURG 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 6.00 Service .00 Posting 6.00 Surcharge 10.00 R. Thomas Kline .00 22.00 01/11/2007 UDREN LAW OFFICES Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. CASE NO: 2006-06581 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOCKENBERRY ROBERT D the DEFENDANT at 1330:00 HOURS, on the 10th day of January , 2007 at 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 2103 ASPEN DRIVE MECHANICSBURG 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 Posting Surcharge Sworn and Subscibed to before me this So Answers: 18.00 10.56 6.00 10.00 R. Thomas Kline .00 44.56 01/11/2007 UDREN LAW OFFICES By : day Deputy Sheriff of A. D. V d °cz W s c ? -36 c-n 4 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 :Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry =NO. 06-6581-CIVIL TERM Defendant(s) To: Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, ou are hereby notified that a Judgment has been entered ai in the _ above proceeding as indicated below. rotho ry X Judgment by Default Money Judgment Judgment in Replevin l / Judgment for Possession ?f??r ?7 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. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust. 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff v. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) To: Robert D. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-6581-CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania you are hereby notified that a Judgment has been entere ga' u in the above proceeding as indicated below. of ary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession .211 -1161 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 Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 €:Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE Plaintiff V. Robert D. Hockenberry ::NO. 06-6581-CIVIL TERM Karen M. Hockenberry Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in.the above matter: Amount due $170,734.75 Interest From 2/14/07 4,227.60 to Date of Sale 6/13/07 ongoing Per Diem of 35.23 to actual date of sale including if sale is held at a la.ter date (Costs to be added) $ LAW OFFICES, P.C. EY FOR PLAINTIFF lw Tt) ?. ? o ?- cccc ? d CIQ QQ _ 4.A ? SFr>> ? , -? , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NA, AS TRUSTEE FOR FIRST FRANKLIN MORTGAGE LOAN TRUST 2004-FFH3 BY: SAXON MORTGAGE SERVICES, INC, AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From ROBERT D. HOCKENBERRY AND KAREN M. HOCKENBERRY (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 $170,734.75 L.L. $.50 Interest FROM 2/14/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $35.23 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $4,227.60 Atty's Comm % Atty Paid $211.36 Plaintiff Paid Date: FEBRUARY 13, 2007 (Seal) Due Prothy $1.00 Other Costs Cur s R. Lon o o to 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. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE ENO. 06-6581-CIVIL TERM 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. LAW OFFICES,/P.C. rk J. Udren, ESQUIRE TORNEY FOR PLAINTIFF Q C v '? Y r r1l r Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 ::Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE Plaintiff V. Robert D. Hockenberry :NO. 06-6581-CIVIL TERM Karen M. Hockenberry Defendant(s) 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 AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 2103 Aspen Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Donald R. Miller, Jr. 222 Market Street P.O. Box 348, Halifax, PA 17032 i 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank NA, as 4708 Mercantile Drive Trustee for First Franklin Fort Worth, TX 76137 Mtg. Loan Trust 2004-FFH3 By: Saxon Mtg. Services, Inc. as its Attorney-in-Fact PHFA 211 North Front St., P.O. Box 15628 Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department 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 2103 Aspen Drive (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 13, 2007 'Mark J. Udren, ESQ. Attorney for Plaintiff ? 5 ? }: ? ? : . a? ,, rrRCc ?) a w C3 a f Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 :Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE 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 V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) NO. 06-6581-CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert D. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 Your house (real estate) at 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,734.75, 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.) 1 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 C`? a d ra ' -n -vt"tt ^^ 3 C7 rt7 `` ? - TI } ?} w c-n -.,3 Aft UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as ;COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 :Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE Plaintiff V. Robert D. Hockenberry ::NO. 06-6581-CIVIL TERM Karen M. Hockenberry Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 Your house (real estate) at 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,734.75, 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.) 1' 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 fl ,- -? .? ?., "'? txa ? r ?'?? ? ; c.a , r ?::; ? -r ??= .° , ? n ?::, ?---; ?- c-c? ---i -? c? =? -.,..3 SHERIFF'S RETURN - REGULAR r CASE NO: 2006-06581 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL MARK CONKLIN Sheriff or Deputy Sheriff 'f Cumberland County,Pennsylvania, who being duly sworn acco i says, the within COMPLAINT - MORT FORE was served upon HOCKENBERRY KAREN M DEFENDANT , at 1330:00 HOURS, on the 10th day of Jan z at 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 by handing to a true and attested copy of COMPLAINT - MORT FORE ng to law, the 2007 tog6ther with and at the same time directing His attention to the conte4s thereof. Sheriff's Costs: So Answers: Docketing 6.00 ,r Service .00 Posting 6.00 Surcharge 10.00 R. Thomas Kline .00 22 00 01/11/2007 UDREN LAW OFFICES 117 before me this day of A.D. Sworn and Subscibed to By: L Deputy Sheri SHERIFF'S RETURN - REGULAR • A CASE NO: 2006-06581 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS HOCKENBERRY ROBERT D ET AL MARK CONKLIN , Sheriff or Deputy Sheriff f Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOCKENBERRY ROBERT D the DEFENDANT , at 1330:00 HOURS, on the 10th day of January 2007 at 2103 ASPEN DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 2103 ASPEN DRIVE MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE tog' her with and at the same time directing His attention to the conte4s thereof. Sheriff's Costs: Docketing 18.00 Service 10.56 Posting 6.00 Surcharge 10.00 .00 44.56 Sworn and Subscibed to before me this day of , So Answers:: R. Thomas Kline 01/11/2007 UDREN LAW OFFICES By: Z Deputy Sheri A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as ::COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 :Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry NO. 06-6581-CIVIL TERM 2103 Aspen Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penaltie f a. .S Section 4904 relating to unsworn falsification w authori es. Dated: June 1, 2007 N?, F2EN LAW/OFFICRS, PEC. BY: Y I Mark J. Udren, Esquire 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 Wells Fargo Bank NA, as Trustee for COURT OF COMMON PLEAS First Franklin Mortgage Loan Trust 2004- CIVIL DIVISION FFH3 By: Saxon Mortgage Services, Inc. Cumberland County as its Attorney-in-Fact Plaintiff NO. 06-6581-CIVIL TERM V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Robert D. Hockenberry Karen M. Hockenberry PROPERTY: 2103 Aspen Drive (Upper Allen Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 13, 2007, at 10:00 am, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A U _m mL ?N . Y ?OOCmo rNp?s C E ao? E U) CC 0 ir E$.-OG) ?ML?mm (D Cvl? Ca m=g,l? N ? C m m 2 W FALL EmEm-v m N ??_ W m V D0) d fALL 2 0 0 1 ?W F-?m?•r.m EP ? w o Vl O- O 41 a EW m Y .0.2 C O C O a __0) QS 01 Q.LL Nm.O.m2` aW?c ` c ? mo? mE o Lo g W mE a U ° E c a E°'m Y a p TO m oa'c£O'" ' v N o E c ino ? E m???`L dv o ?? `m??drp Q 0107 a r)_ °c 3Em uu77 N N C m U? V mE m CL mC O N d 0) N m m m E> L N m• V v f"p? m m Y ? C D N ? V C E 0= m?u'm c ? O N ? oE °o?° d N C N a LpE O T S 7, j D o ?mpuiCc C 16 a 4) ., O jO 2 . pp?? Od 4 N Q j? £ m m?a Ec c R. a 0-,o O ? f y 0 gmo- O I = C mccQ c L N E311 ? m??mmo U c W lOL ._. -_ _ • m 2WC?rjU 2U rl\? gErn dc ? O U Of/I w N "e a E E? a v_ a' dl a H E c x co a? W _ a a? LL m a. o c w i d ? c v U N m L 0 O U d ?? ? ? y w Z N 0 ? ¢ > M to a o C'i L a L X O W C4 O LL co O N c m co co v to W ° T o z ? O X E O.?o W a a p a F- ? U a - P O m o a y c E m w LU F ¢ Wp E W qV ` ¢ W ?w w w O 60 Z ?j U-< 0 F- ? z? w' ?° Y?? 0) O Z ¢ w Oe C7? m zm? w F-J ai =a = jK n 1->o X QCAO ZQ ¢wX WwcN> a? 3W= m ?' _ g a) _,p Qv o > >a V ` IF 5Z? w ¢ F-?? w ¢ Oa ml? ?z= J?o m? 0 0 a ? Vlz ? , ?LLC o?a Q w =a = QOa _(r LLCM ?¢F- g F-¢ a? W WOW Z WO= Q O Z=)- X O U) n? v! C F-F-J (ALLfA fAhJ u) am (n LLCCO W;t &Ye OQX =ID Z -• 000 Q N Q gWm Z QML wOJ J'J Q QZCC ? JMF- Q Q?LL > ffi U 53: E MO zo U MZQ QOM LL LY JOoX Z J HZ r 03 z OHO C)ma w? d F-Nr OM¢ 13-U wUQ Cr -U =?¢ aN= wOO ?'TLL ON¢ ?N= T T % V a? ma `o? ?vyi?O v QZ (D CD m2aa E ?n ) p j c I ? ? z C, cy, v L, co LC, EXHIBIT A C d a C a° m Y C V w 3 d Q. T F- .Q V w d a O v m O LL d' O) it, m i LL ti M L° co a r.- 0 co r O fa a) E U O CO O O O Ul) W C CU N Y Y U U O O xY 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 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 06-6581-CIVIL TERM 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 28, 2007 Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive 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: June 1, 2007 UDREN LA I CES, P.C. Mark J Udren Esquire EXHIBIT B -- DEC 192006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank National ":COURT OF COMMON PLEAS Association, as Trustee for :CIVIL DIVISION First Franklin Mortgage Loan Cumberland County Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its € Attorney-in-Fact NO. 2006-06581 Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) O R D E R AND NOW, this JoA day of ern 20(3?, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry at 2103 Aspen Drive, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 2103 Aspen Drive, Mechanicsburg (Upper Allen Township), PA 17055. BY THE COURT: J. EXHIBIT B i U v. tau v bN cep u` t ? Ul J d v 3 D G 0 o C 0 i= ?'m rn ? U, ma Q ? (fy -i 9 rf =mow ?- ?' ? rfee 7Pz.,, POSUV Pool" rn m lout Posts®e & Fees v I Karen M HT ° C3 2103 Aspe y yyr. F,XHIBIT 3 _0 N T o D TL WD 00 198 0 W Z m 8 ? A O_ m 0 m D ? ? H C D _ .art g - j 2 . C CD Q,Oro ? C ?? ? $mm0. G. o ocw ? 1 a a n o ?o? mom $ cr Q 3 Q _ m 27 L^ D m W a w ??1?D ? P -w m s x v, R a ? g C3 8 3 a ru IS' (j 13 ' a O p3 m ? 3+ ?? ?? y .. 'd pus todw of PUMP" Iteut 60 $14211tAe PO s! notlewioplt uolitp a; st"Ill Nwelut iii •lilebul me Gutgew uegw 11 luesese put Idtaoa:ltp wS :1NYAIOdM11 'PW pug eBeasod t W PM xjP PUB *NM'Pepeeu Wu sl 40M MOM B uo u4sod g A 'Buell w4wd Joy MW aeod eta pop -aarB ato weae d eseeid `AM s! IdPM IMM PGMGO No uo 4gugsod a d ¦ seat MM egeldlRW etg *MW Jo steep W4 Bl? )v Pga m asom ppe " cq pWMw eq zU d+B1eIIBP 'eB1 WuocnamPa.e??t? ¦ g! ad om QBn Pgwoo mod uo wsugsod °Sdsn s Wpm ulmoi vP9 a X4 Aqm 9%a a"m RL LPBOBBtebeu adlB?ga eoeldpsw eseopu3 6% 04 JeAOO (3 eala,sod oReap??PPpedP?euo?uee eUl oa L&SC uLIoj Sd) 49ed wnfey aB dawJO! s W Wad epY.wa at Peaseabsu ey a?i ¦ 1lBW PaeielftH jo Pemsul ism = avow %opv w JO-,A liew Pomwo 4w Q3ciAOud SI 3JVd3A00 3ONVunSN1 ON ¦ IRtu IBUOPLUOR W ssalg dua A4 eIQBII M PU el Pn POW93 ¦ G'ePn ftoPd .to Gip" wmo-Pjl-$ tm peuq= eq AINO d' P N+ uq sea t df q M4 WWeS P"d M dq 91" kW-M P a V ¦ • eABldlIBW mod ?o) ?ttepl aebiun Y ¦ PS Form 3WO. June 20M (Berates) 4ww &41Ku V ¦ :SDPYkwd 119H POUPJ93 Z l? Y EXHIBIT B i o t N ? 1 n O t b o m (D _1 d o b. n `Q m o . r n v? . tt+?i O M O O? T-ti Q ? 71 -7-71 rn C) co0m- w®m x 0 Cl ? -U A-k rr D' 7 nia FOO O Q 0 :' C3 aw (EndwasnWd A0*d e) p C7 . t3estrk?ed D~ Fes Gent FleG? ? ? m m Total Posftr & Fees C3; C3 C7 C3 rd D. H Robert ?" r ? -w n'2 AalnPT erz? N 71 1? O N ° O .?O 1m o Om '" 33 W Z W m , :r 0 Si OD Da a m m -,wm~m S CD v TI S CD p01 o 7 . fApC7?1 m w 0 < w CD :3 7E ?mwm?' . a xcc t' O . w ? I? w o?mo ? N p m,< Sy 8 g i cy '3C_ m OR zi - . m m 0 D Ui H w A co c n v m X? L-i 37 - A CL. 6 0 $ ' O a C3 ? V.- ?n+ ? t 13 m a Y 0 a C3 - 1 8 £ Er N to ? ? ? C 1 'apdd pus 2odv e3 posseippe Ilew uo 0149119AI Iou 91nol smioj-I WISP 0I230908Iouisjul -A,Inbul ue dulllew ueylb it Iuesoll put Idles 61 $ips ones ?1NY1dOdWl flew Pue 96mod LMM 10CM >4P Pug 4MOP 'POPee114011 at Omw I W e OLP eat d eseeld `pailssop el id! W Peo eJ uo Wed 09.11 ¦ ;den self Awu?oP11o 04 GOWN PSIZIlot" daw menu ' es'ea s ? 0 „a smPm n a PeOwpw 81949091 PR P99M AW uo Wswpod % an a'Klam wmM 61"Tw • COI M eel 8 eeleaw ol'.Pe4a&d" s epp?e 4d? ueooldow 3 '9{ GM JQ= 04 e6e1s0d O de ppe Pu 041(4 488 eUJ Scl) AMU a 4asue pue epeldwoa esse?d e? 4dlaoe?l verged MW 01 JON1eP JO jowd of JO loa ePu?O,tl pepsenbe? eq iCew tl +? ! a 'eel IeuaNIPPe us JOj ¦ jod 'IP" PeNM 4Vm Q3a 0 d S 3?ovum0J ?3 ?(4SM o • clew IeUOBmowl to saw Aue ml elQm" m el now Powigo • *m AWoM jo e148W ssa*-psp poulgwoo sq A1No Am p" v4t e 44AM"Is Food 044 Aq Wq Aj&W So P+o?+ V • ?eldl!•u+ moA ml jewom" wftm V • Ps r«.,, seoo,.mrre 1 :NPI~ ad118W P Ile RJa9 x EXHIBIT 13 d w D °S I? a S m U1 U- ? d ? 3 t1. a N ? N a ° ? Y c ca O ?° E N d . . m mm t7 3 x ? m c 5 `6 . o ? .N n Cv. 7 0 a ? o. o to y 0 ? ° ° U ? 2 U Q O d d N V N ? @ m C ? °g° CJ %1 N O a d ? H m ? .? C O 7 ? C) N U M M O 4 Z O? J U a 7- S us O 0v t r N d Q d O y T O a ? C E o ? U_ in 4 0 a ? Z N ? N y D 0 N ZQ? n ? n 0 D a °- ?3?a m -25 O L N ? Q 4 4) Cc) ?? Oa N ? N Gy? fi r? ? C v „o ?mro? mQ?co a u m 4 m m [? ? m Cx6 N ? m ..0. dot Rya mm?m O O m m J T m m ? N S c w c ? m m E aaE?°a' Top E 0 W V m NJm N 4 01 E o _ m c ?me t m E m o a m V ?,.? N Q¢ O ?N m m V7 m O E yl a J m¢ ° ss m ? J 1Cl ? p ? t 6N m > C W 01 g N m 0-0-- m ? G z 9 m °- O ? Gm ?N a ?2mcai v o ? E ? v a O Q M? W O C i d T r .ri 'CS d1 E to 4 U ?i a o N d ? E ? Z' U. N 0 E o r 4 Z co m r tD T- i J r AN co Ir ? n u so o00 Iz N. a? a o ? D T ?XH?I31T B c -a , a r G [6 .0 U. co T cc) ol t0 i L L U.^ ?? ?" m ty b LL a ? ? CIO r-t r' cn a > 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 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 NO. 06-6581-CIVIL TERM 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 28, 2007 Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive 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. UDREN LA OF CES, P.C. Dated: June 1, 2007 Mark J Udren Esquire DEC 19 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2006-06581 V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) O R D E R AND NOW, this JDA day of 200 ?, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Robert D. Hockenberry and Karen M. Hockenberry at 2103 Aspen Drive, Mechanicsburg, PA 17055 and by posting the mortgaged premises located at 2103 Aspen Drive, Mechanicsburg (Upper Allen Township), PA 17055. BY THE COURT: J. i 7 h o i n ?o .. o tn (D n v ro m ?'" M D a K t ' J 3 .. ? a d N v i ? C O OC ©O r ? ?? C M wozc m ' s C3 C:3 - Q' cr r r4 ru 7 o tC33 103 Fee tE?Fse O Q om " m m t Toth P~ & Fens o 13 Karen M. He C3 ° _ 2103 AsPer_ ?rC S-t. Cl) m? N o 0 T. ? CO) Z CA) S .+ C 0? (A co H = 0 p G,+ CL N m N in ma C. to) 3 ? 3 °C3 m w "RO N 0 to w D L-j ??? C) M 0 fg -? ryJ E-' A Er ? @ lb C3 - 9 ? 3 v P3 x p cn a ^ Z? c. 2 0 a 0 F it 004i Poe sodll of P""JPPe flew uo olgelleee ps s1 uolteuuolul AJOellep of "cost leuJelel 'AJlebul us 6ul>Isw uegm 11 juste pus lAlesw slgl ong :1NVIVodnl •p LU pus eftPod 44M PCM XIP pus 4=p `Pepseu 40u Of 4ww I.BYY POLWOO, e44 uo wpW s m -WOA wod col 90wo 19od ma 48 ep -am e44 weae d e8aet?pwW $I WPM NCI Peamo a# uO WGUO d a a a 'A WOWSWOPUO m e?eeeo4vee wS at peppy eq law e 0 sI 4dlem imn pmao jwA uo watq@W •Sdan a uxow x4 env ewow of .pe4wnbeu ldleoeu wgdllew ?pte 'eel ew jwm eP= 04 eepp w 9"m -oft Pampa PesoteleeloR+s «R o ttle6 ? 8dI? of Pals eq =u x i le 9pe us god ¦ ioj 'Ilen peawoo 4w aaamud Si avvga wwuml OONm ¦ 'llevl lauol48we4W)O 8=P fAm J(4 ewB PW+vu 81 IlM PGVM ¦ vO8W AWOPd Jo GM 88a10-IWW 411 4 PeuMm eq AINO Pn W/ sit ml e?+e81Erleod ma Aq IdwA "mop to prom v ¦ ep Olau most x4 jqWeq enblun y • PS Form 8800, Jura 2;M (Revem) :?PMad IINW P 91111M Z ?? x ,*,A=, c Sst?, Y H 4 O ? ?Npd m F-' O m i :' w ? ? ct S. 0.0 ty V? H w d n ca 0 ro m r m . a r? ' ? i r C O In H Ul 1 N O r:. O O C ivo M r7l m 0 F? C. M 0 b7oO C5 D C-) 7- W 0 M m Ln -0 0 Cl . ??? . information For delivery . Er- -0 ' _ i Ir Fr rq i Postage 5 • 3°i ru ru .r C3 C3 CerMd Fee -? - A M i O C3, C3 Retum Reaso Fee (E:ndomemerd RewWad) r-I j ra ( dorsement Required) rl r- m m Total Postage 3 Fees I $.,%-A :. u7 Ln ,rte C3 O C3: C3 r%- , r%- .V ` 4c 4 ti ft_ r. is Postrnaik Here Sew To Robert D. Hockenberfy or 2103 Aspen Drive Mechanicsburg, PA 17055 I x o J N O Z CA) (D 00 ya. j yv -n '_ 0 0 C? C3, O Ln m 3 w L-i m 0 O C3 O iU LJ Q' -0 a 0' Ln 0 N N ? O I1 - ? n m `m ? n g? f? 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N a ?cp-Eci mu£v'0i A?mcri m o E rn 7?aAM g a c 0 co 0 G m fl. T F' T m A 'II V m E W ? CL e • ? ? U Ix m o ? N 0 y U a. °a a m ?m m 0u o? r- N CL 010 -0 Cl) 3a c .a ? J .Q C U ao TI, co co rn ? ?T N ? L LL ?Q r m ? E=2 O fly.. 0 03 C(- Y r-> ? Q Cy ._.+ ? - c? n ;;.. ? _ _ a? =c? °7 , ? , ..?.., " ", ; -_ - c? ?? :? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which First Franklin Mtg_Loan Trust 2004-FFH3 Tr is the grantee the same having been sold to said grantee on the 13th day of June A.D., 2007, under and by virtue of a writ Execution issued on the 13th day of Feb, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 6581, at the suit of First Franklin mtg Loan Trust 2004-FFH3 Tr Aif against Robert D Hockenberry & Karen M is duly recorded in Deed Book No. 281, Page 56. IN TESTIMONY WHEREOF, I have hereunto set my hand and Dj' said office this day of A.D. 07 y 4 _ n Of 0"ft CanbnMno Comfy, CaMb. PA *Cb*MNE*nthe A*MV48yofJm.2010 Wells Fargo Bank NA, as Trustee for First In The Court of Common Pleas of Franklin Mortgage Loan Trust 2004-FFH3 by: Cumberland County, Pennsylvania Saxon Mortgage Services, Inc., as its Attorney- Writ No. 2006-6581 Civil Term In-Fact VS Robert D. Hockenberry and Karen M. Hockenberry Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2007 at 1400 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Robert D. Hockenberry and Karen M. Hockenberry, by posting the premises located at 2103 Aspen Drive, Mechanicsburg, Cumberland County, Pennsylvania, pursuant to order of court, with the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2007 at 1407 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 Robert D. Hockenberry and Karen M. Hockenberry, at 2103 Aspen Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Robert D. Hockenberry and Karen M. Hockenberry, by regular mail to their last known address of 2103 Aspen Drive, Mechanicsburg, PA 17055. These letters were mailed under the date of April 04, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 13, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren, on behalf of Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 by: Saxon Mortgage Services Inc., as its attorney-in-fact. It being the highest bid and best price received for the same, Wells Fargo Bank National Association, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 by: Saxon Mortgage Services Inc., as its attorney-in- fact, of 4708 Mercantile Drive, Fort Worth, TX 76137, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,149.39. Sheriff s Costs: Docketing $30.00 Poundage 22.54 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 19.20 Levy 15.00 Surcharge 30.00 Law Journal 437.00 Patriot News 413.48 Posting 12.00 Share of Bills Distribution of Proceeds Sheriffs Deed 16.17 25.00 39.50 $ 1149.39 So e? ?? R. Thomas Kline, Sheriff BY J &SNAL Real Estate ergeant n__ g)Vvla-) fie, . l94 544 BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for First Franklin :CIVIL DIVISION Mortgage Loan Trust 2004-FFH3 :Cumberland County By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact :MORTGAGE FORECLOSURE Plaintiff V. Robert D. Hockenberry -NO. 06-6581-CIVIL TERM Karen M. Hockenberry Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert D. Hockenberry Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 2103 Aspen Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Donald R. Miller, Jr. 222 Market Street P.O. Box 348, Halifax, PA 17032 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank NA, as 4708 Mercantile Drive Trustee for First Franklin Fort Worth, TX 76137 Mtg. Loan Trust 2004-FFH3 By: Saxon Mtg. Services, Inc. as its Attorney-in-Fact PHFA 5. Name and address of on the property: Name none 211 North Front St., P.O. Box 15628 Harrisburg, PA 17101 every other person who has any record lien Address 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants 2103 Aspen Drive (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: February 13, 2007 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be Address Mark J. Udren, ESQ. Attorney for Plaintiff a UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HELL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-6581-CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert D. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 Your house (real estate) at 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,734.75, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD 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 . .R UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact Plaintiff V. Robert D. Hockenberry Karen M. Hockenberry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 06-6581-CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Karen M. Hockenberry 2103 Aspen Drive Mechanicsburg, PA 17055 Your house (real estate) at 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $170,734.75, 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.) i 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 house or lot of ground situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, bounded and described as foIlows, to wit: BEGINNING at a point is the northeasterly line of the public road leading to U.S. Roue 15, Tmffkc Route 114 (LjP- 416), which said point is in d= divisinn linr h-hirsen Low n!., 144 uul 143 on the acreinaner mentioned Plan of Lots; thence along the division line between Lots 144 and 145 on said Plan, North 30 degrees 26 minutes East, one hundred thirty and fifty four hundredths ,(130.54) .feet to a point in the division line between Lot No. 145 and 143 on said plan; theacc along the division line between Lots 145 and 143 and Lots No. 145 and 142, South 59 degrees,34 minutes East, ninety (90) feet to a point in the division line between Lots No. 145 and 146 on said Plan; thence al "ng the division line between Lots No. 145 and 146, South 30 degrees 26 minutes West, one hundred thirty and fiftyNbur hundredths (130.54) feet to a point in the northeasterly line of the public road leading to U.S. Route 15, Traffic Route 114 (L.-R. 416), aforementioned; thence along the northeasterly line of said road, North 59 degrees 34 minutes West, ninety (90) feet to a point in the division line between Lots No. 144 and 145, at the point and place of BEGNNINCs. ` BEING Lot No. 145, Section 2 of the Corrected S&division Plan of Spring Run Acres, recorded in Plan Book 19, page 7, Cumberland County'Rocords. HAVING thereon erected a dwolling house known as 2103 Aspen Drive, BEING KNOWN AS: , 2103 ASPEN DRIVE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 42-28-2421-125 TITLE TO SAID PREMISES IS VESTED IN ROBERT D. HOCKENBERRY AND KAREN M. HOCKENBERRY, HUSBAND AND WIFE BY DEED FROM JACK M. SPROCH, AN ADULT INDIVIDUAL DATED 6/30/04 RECORDED 7/22/04 IN DEED BOOK 264 PAGE 1402. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NA, AS TRUSTEE FOR FIRST FRANKLIN MORTGAGE LOAN TRUST 2004-FFH3 BY: SAXON MORTGAGE SERVICES, INC, AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From ROBERT D. HOCKENBERRY AND KAREN M. HOCKENBERRY (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 $170,734.75 L.L. $.50 Interest FROM 2/14/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $35.23 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $4,227.60 Atty's Comm % Atty Paid $211.36 Plaintiff Paid Due Prothy $1.00 Other Costs Date: FEBRUARY 13, 2007 (Seal) Curti R. Lon of on to 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 bse AM MN 0 Real Estate Sale # 63 On March 8, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 2103 Aspen Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 8, 2007 By: jaf Real Estate Sergeant 0-3-i Lh0Z 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 Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with 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 18th and 25th day(s) of April and the 2nd day(s) of May 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 SALE#63 Sworn to and subscribed before me this 18th day of May 2007 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal i erry L. Russell, Notary Public ity Of H 'burg, Dauphin Courtly Expires June 6, 2010 r e n Iv i t' of Notaries NO RY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ?, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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: April 20, 27 & May 4, 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. '0a Marie Coyne, SWORN TO AND SUBSCRIBED before me this 4 day of May, 2007 REAL ESTATE SALE NO. 63 Writ No. 2006-6581 Civil Wells Fargo Bank NA, as Trustee for First Franklin Mortgage Loan Trust 2004-FFH3 By: Saxon Mortgage Services, Inc. as its Attorney-in-Fact VS. Robert D. Hockenberry and Karen M. Hockenberry Atty.: Mark Udren ALL THAT CERTAIN house or lot of ground situate in the Township of Upper Allen, County of Cumber- land and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the northeasterly line of the public road leading to U.S. Route 15, Traffic Route 114 (L.R. 416), which said point is in division line between Lots No. 144 and 145 on the hereinafter mentioned Plan of Lots; thence along the division line between Lots 144 and 145 on said Plan, North 30 de- grees 26 minutes East, one hun- dred thirty and fifty four hundredths (130.54) feet to a point in the divi- sion line between Lot No. 145 and 143 on said plan; thence along the division line between Lots 145 and 143 and Lots No. 145 and 142, South 59 degrees 34 minutes East, ninety (90) feet to a point in the di- vision line betwwri Lots No. 145 and 146 on said Plan; thence along the division line between Lots No. 145 and 146, South 30 degrees 26 min- utes West, one hundred thirty and fifty four hundredths (130.54) feet to a point in the northeasterly line of the public road leading to U.S. Route 15, Traffic Route 114 (L.R. 416), aforementioned; thence along the northeasterly line of said road, North 59 degrees 34 minutes West, ninety (90) feet to a point in the di- vision line between Lots No. 144 and 145, at the point and place of BE- GINNING. BEING Lot No. 145, Section 2 of the Corrected Subdivision Plan of Spring Run Acres, recorded in Plan Book 19, page 7, Cumberland County Records. HAVING thereon erected a dwell- ing house known as 2103 Aspen Drive. BEING KNOWN AS 2103 Aspen Drive, (Upper Allen Township) Mechanicsburg, PA 17055. PROPERTY ID NO.: 42-28-2421- 125. TITLE TO SAID PREMISES IS VESTED IN Robert D. Hockenberry and Karen M. Hockenberry, hus- band and wife by deed from Jack M. Sproch, an adult individual dated 6/30/04 recorded 7/22/04 in Deed Book 264 Page 1402.