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HomeMy WebLinkAbout07-0156UDREN 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 Freemont Investment & Loan SABR 2005-FR1 by: Saxon :Cumberland County Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw NO. '76 V LL e f 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: Wells Fargo Bank National Association, as Trustee for Freemont Investment & Loan SABR 2005-FR1 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: 215-215A North Baltimore Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mt Holly Springs COUNTY: Cumberland DATE EXECUTED: 9/14/04 DATE RECORDED: 9/20/04 BOOK:1881 PAGE:960 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 12/18/06: Principal of debt due $114,115.71 Unpaid Interest at 8.7% from 1/1/06 to 12/18/06 (the per diem interest accruing on this debt is $27.20 and that sum should be added each day after 12/18/06) 10,293.17 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges ( thl mon yy late charge of $54.13 should be added i n accordance with the terms of the note each month after 12/18/06) 679.30 Uncollected Fees 278.55 Attorneys Fees (anticipated and actual to 5% of principal) 5,705.79 TOTAL $131,677.52 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combinPr3 nntirc r. , 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 $131,677.52 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Ud en, RE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 Ali,, ` TilpiO CBRTi!>rF tmas of laat tlrt Jill su the Boni ofhktW Haily 9014M CumbKW Comfy, PeaeWhia* b waded ad O"Mr;t1du falioart: WWG`r a a pcW an Or Vubm Wo e?tBa mnm Avraca At the iummadw of the SaAaea line of the Ind cw Beech ffi9. An=* of Icy A. mffeod im& oow m' fi"MIY Qf'Jmft NOMW and sides AVMW damoe dMW ad A W Forth 3 dgpvm 15 ems Weak, 59-flwt or Itwur,. vft *kneed= of ibe Ind of Berdie E Uxiwy of SbM AL BMOCC SW lwubxtpw or 00 daa J Oiood=d 60 Waco JUlet, t4wom sim g said lend Sao& 97 de 30 uptm East, tbgtt tM tilvWw wd are donna brmk hum armed *&Oo% a dWomw of 133 Em, moron at JaW Ones akog a* 11th cfBWtilt M Avmwo, Salt: 2 degrm 20 pinaw Ego, it fiw, mores or Iasi to a point a to ittamsso M *to* Ind mw of 7aa@6 eat Jaws Breads, of Muth& P. Ev%i etid end bore A"auM t wdd kA NO& 86 dqpM 7 a ima Ww 196 Matt,. more or law w blood r41ipj; w the ltd oE7S*TOOM, AMOG ioalaewad vgth dw &06" of a doable wwk d"aft ham bow a NM ZXl and 215AWartb bd&DM A"mm VNDER AND Rf WIC tdIIlovanaso amificM veedcdW-*jy, eoemertl? aid ?? Oa'?rt, April 11, 2006 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The A(IMFnWNFROS MnRTlTAGE ASSISTAIV(`F PRII[`RAn? ( r?- iiA D) .?.A.. to heln to save yn lr hom This Notice pynlainc how the nrnur?m_warke •••? 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 IM PORTANCIA, 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 0HOMEOWNERDS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDBER SU HIPOTECA. Page 1 of i EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: _LAWanda Am 215-215A N. Baltimore Ave. _ Mt. Ho15pring$ Pa 17065 2000038782 - ------------_..__....__.-_- Fremont Investment Wells Fargo Bank_ HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RF Fi iGIB F FOR FINACiAi ASSISTANCE HF,LP Y011 MAKE rrrr ,E ,. r..,,...., • GF .. 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 FORFC'T OcrroE -- 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-face[ meeting with one of the consumer credit co TITF NEXT (30) DAYS.,. TF Yoli DO NOT APPLY unseling agencies listed at the end of this Notice. TH S MF,F,MG W1ST OCCi1R WI': B1IN FOR FMF.R GrFNC MOR TG A GF ASSISTANCE Y01 1 MT1ST RRTNC; Yn[lR ?rnurr to TF [,"r- TO DATE. THE PART OF THIS NOTICE CALLED OH(1 I TO CTTRF YOUR ?Tno•rn .. DE O, FXPT Antic HOW TO BRING Yn[1R moRTC'TA(TF [,,1P TO DATF C.ONRiTMFR Cu M COTINSFi iNG AGFNCTFS -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and tPlenhone mirnhPrc onsumer credit counseling agencies for the. ronnty in which the. nrin, rty is located are set forth at the end of thic TnricP. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. Page 2 of 6 YOU MUS 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 TIIF, DEFAUI T -- The MORTGAGE debt held by the above lender on your property located at: 215-215A N. Baltimore Ave. Mt. Holly Springs, Pa 17065 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 P-_ axments o_.f $9(12.17 for Febru 1, 2006 through April 1, 2006._=_27(IGSl _- Monthlly to Charges of $5413 for Februa 1 2006 thro -_?__ _ uh__March _l, 2006..-..=_$108.26 Other charges (explainrtemize): Other = $75.00 Property Inspections = $7.95 __Other Und Late Charges =x_13._..-._ --- ---............. --.._........ .._.. __TOTAL_AMOUNT PAST DUE__.,_,.-.. _ $2$51-8-5 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION mn not use if not z lica1 lc): &A AnW TO CURE THE DFFAUI T -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS X2951-$5, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must he made either by rash rachier'c check certified rherl or money order mane pay, hl and sent to: You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (loo not use if not appli able ): ha Page 3 of 6 IF YOU DO NnI r11RE 11HE DRE rTr _ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise i c rights to ace 1 rate the .„or W3gc.det1 t. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to farec_ lie tunnn ynnnr mmajUaged ,t TF THE MORTf_ GE IS FORECLOSED I IPON -- 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 von rare the default within the THIRTY (3Q DAY [mijod. yon will not he to pay a urn y's fees. OTHF,R LENDFR REMEDIFS -- 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 CTIRE THE DEFATTT T PRIOR TO SHERIFF'S SAL F -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon still have the right to cure the default n ca a at anv time itn to one hour before the Sheriffs Sale Ynn mad, 'so by ayi the total amnnnt then past due phis any late or other sharps then dne. reasonahle attorney's fPP.C an costs connected with the d cure sale. and any other costs connected with the Sheriff's Sale ac rified in uniting by the lender and by performing any other re =nirements under the mprinaQP, default in the manner set forth in this notice will restore our mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SAT F DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approAmately_ months from the date of this Notice. A notice of the actual date of the Sheriffs 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 Address: 4708 Mercantile Drive North Fort Worth,,. -T17 6 E 37 Phone Number: --800-874-9516 Fax Number: _. 717-665-7750.-. Contact Person: -__ -- ---...._.......... _.--.........._----..__.-_._.--. Loss Mitigation _ IOSWWOl saxoI!1I1S?,com EFFECT OF SHERIFF'S SAT 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 MORI AGF -- 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 6 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. 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 6 • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY 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 ? iv r cn o Z a) .< ;:L Q C/) ? a) Cal (M to = cc m w 0 =r D cD ?D y < oCD rn? Cn CD 0 "", :_ C N = - O Q N * Q ? A _ O Q (D N C .r z tp C) O C_ O a C) 0 O O O tn O N O. " W Q (D C7 t7 CD 3 CD • Service- MAIL- R CERTIFIED ECEIPT 1n7 r n. (Domestic Only, O O rn 7n -? 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Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. L I ,-?/tt Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. kL r ' ? ? films ? ? ? rf c5=1 f ?J .. t q? ( -7r5 ILI ? 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 Freemont Investment & Loan SABR ::CIVIL DIVISION 2005-FR1 by: Saxon Mtg. Services, 'Cumberland County Inc. as its attorney-in-fact 4708 Mercantile Drive :MORTGAGE FORECLOSURE Fort Worth, TX 76137 Plaintiff V. La Wanda Bragshaw :NO. 2007-00156 P a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 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) La Wanda Bragshaw a/k/a Lawanda Bagshaw 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 $131,677.52 Interest Per Complaint 1,632.00 From 12/19/06 to 2/16/07 Late charges per Complaint 108.26 From 12/19/06 to 2/16/07 TOTAL $133,417.78 I hereby certify that (1) the addresses of the Plaintiff 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 ereto. LAW OFF P.C. *Ark J. ren, ESQUIRE torney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED 2 DATE: I Z PRO P THY Cherry nL?.L, 1.". _, VDREN.LAW OFFICES, P.C. ATTORNEY FOR' PLAINTIFF BY Mar J._Udren, Esquire. ATTY I.b N0. 04302 WOODCRBS CORPORATE CENTER 111 WOOD ST ROAD, SUITE 200. CHTsRRY BILL, NJ 080.03 856-669-400 Wells Forgo Bank National Association, as =COURT OF COMMON PLEAS Trustee for Freemont Investment & Loan E CIVIL DIVISION SABR 2005-.FR1'by: Saxon Mortgage !Cumberland County Servic s; Inc. as its attorney-in-fact Plaintiff V. La Wanda Bragshaw alk/a Lawanda Bagshaw Defendant(s) 12.NO.2007-00156 p TO: L Wanda Bragshaw a/k/a Lawanda Bagshaw 2317 North Baltimore Avenue M Holly Springs., PA 17065 DATE ofj Notice. February 5, 2007 IMPORTANT NOTICE YOU AR? IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE' COURT YOUR DEFENS S OR'OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WI HIN 'TEN DAYS FROM THE DATE. OF THIS NOTICE, A JUDGMENT MAY BE ENTER. 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 SERVICtkS 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 IMPORT-ANTE USTEDjSE ENCUENTRA EN ESTADO DE REBELDIA PORNO 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 NWESIDAD DE COMPARARECER USTED EN CORRE 0 ESCUCHAR PREUBA ALGUNA, DICTO SENTENCIA EN 'SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDtATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA PIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEJGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 1 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue. Carlisle, PA 17013 717-249-3166 800-990-9108 NOTI' ; PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS D AD TO BE A DEBT COLLECTOR AND TRIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION O VTAINED WILL B E USED FOR TEA PURPOSE. ren, squire. W t Corporate Center 111 Woodcrest Road, Suite 200 .,- "'„ Xf-w Tgrsev 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 Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2007-00156 P 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: La Wanda Bragshaw a/k/a Lawanda Bags aw Age: Over 18 Residence: As captioned abov Employment: Unknown Nam MARK J. UDREN, ESQ. Tit e: ATTORNEY FOR PLAINTIFF Sworn to and subscribed Com any: UDREN LAW OFFICES, P.C. before me this 16t' day of February 2007. Not?gc Y PUBLIC C* NEW JERSEY e01 vf"19 ,? Expl,03 4116120 CASE NO: 2007-00156 P BRAGSHAW LA WANDA ET AL COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS 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 BRAGSHAW LA WANDA AKA LAWANDA BAGSHAW the DEFENDANT , at 1440:00 HOURS, on the 11th day of January , 2007 at 217 NORTH BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 LAWANDA BRAGSHAW by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.28 Affidavit .00 Surcharge 10.00 r% r% SHERIFF'S RETURN - REGULAR J J G I J Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/12/2007 UDREN LAW OFFICES By: t h i f A. D. SHERIFF'S RETURN - REGULAR •` " CASE NO: 2007-00156 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS BRAGSHAW LA WANDA 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 BRAGSHAW LA WANDA AKA LAWANDA BAGSHAW the DEFENDANT , at 1440:00 HOURS, on the 11th day of January , 2007 at 217 NORTH BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 by handing to LAWANDA BRAGSHAW a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.28 Affidavit .00 Surcharge 10.00 .00 33.28 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/12/2007 UDREN LAW OFFICES .By: t h i f A. D. V C-9 ^ v 171 „;? p.? ?, -tYT71 Z "'i -4 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 NA, as =COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw NO. 2007-00156 P a/k/a Lawanda Bagshaw Defendant(s) To: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been enterZo?t ai i n the above proceeding as indicated below. ho ary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, 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 Trustee :COURT OF COMMON PLEAS for Freemont Investment & Loan :CIVIL DIVISION SABR 2005-FR1 by: Saxon :Cumberland County Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff V. La Wanda Bragshaw :NO. 2007-00156 P a/k/a Lawanda Bagshaw Defendant (s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $133,417.78 Interest From 2/17/07 3,182.40 to Date of Sale 6/13/07 Ongoing Per Diem of 27.20 to actual date of sale including if sale is held at a later date (Costs to be added) $ OFFICES, P.C. . Udren, ESQUIRE EY FOR PLAINTIFF tit W, rz? °Q 4 C-3 r ,/?+,_?` w 1 (??/j?/.. Yom' {-.=° c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-156 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 FREEMONT INVESTMENT & LOAN SABR 2005-FR1 BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From LA WANDA BRAGSHAW A/K/A LAWANDA BAGSHAW (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 $133,417.78 L.L. $.50 Interest FROM 2/17/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $27.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,182.40 Atty's Comm % Atty Paid $141.56 Plaintiff Paid Date: FEBRUARY 16, 2007 (Seal) Due Prothy $1.00 Other Costs Cu tis R. Lon onota By: REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Deputy Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee :COURT OF COMMON PLEAS for Freemont Investment & Loan :CIVIL DIVISION SABR 2005-FR1 by: Saxon :Cumberland County Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff V. La Wanda Bragshaw .NO. 2007-00156 P a/k/a Lawanda Bagshaw Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalt'es of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to a/Uthorities. LAW OFFICES, 7.C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF a rn -n .. l ' e 1 ? T ._. ' rr ,? tom' k 1.% 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 :COURT OF COMMON PLEAS for Freemont Investment & Loan :CIVIL DIVISION SABR 2005-FR1 by: Saxon --:Cumberland County Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff V. La Wanda Bragshaw :;NO. 2007-00156 P a/k/a Lawanda Bagshaw Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 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: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed owner(s): Name Address La Wanda Bragshaw 217 North Baltimore Avenue a/k/a Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC Company c/o Joseph Colavecchi, Esquire Address to Follow Borough of Mt. Address to Follow Holly Springs % 4. Name and address of the of record: Name Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mtg. Services, Inc. as its attorney-in-fact last recorded holder of every mortgage Address 4708 Mercantile Drive Fort Worth, TX 76137 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 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. l UDREN LAW OFFICES, P.C. DATED: February 16, 2007 Mark?Udren, ESQ. Attorney for Plaintiff ems' ? ? 1 ` _ _ n c r, cil r w Wells Fargo Bank NA, as Trustee :COURT OF COMMON PLEAS for Freemont Investment & Loan :CIVIL DIVISION SABR 2005-FR1 by: Saxon :Cumberland County Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff V. La Wanda Bragshaw :NO. 2007-00156 P a/k/a Lawanda Bagshaw 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 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Your house (real estate) at 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 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 $133,417.78, 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.) -4t YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ? tM ? ;? p -? v ? -? ?:: _ CTJ r- ?? ?_. ?, a {- ??, a cty SHERIFF'S RETURN - NOT FOUND a CASE NO: 2007-00156 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS BRAGSHAW LA WANDA 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 BRAGSHAW LA WANDA AKA LAWANDA BAGSHAW but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT BAGSHAW 215-215A NORTH BALTIMORE AVE MT HOLLY SPRINGS, PA 17065 NOT FOUND , as to BRAGSHAW LA WANDA AKA LAWANDA DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: So answers: Docketing 6.00 Service 5.28 Not Found 5.00 R. Thomas K tine Surcharge 10.00 Sheriff of Cumberland County .00 26.28 ? UDREN LAW OFFICES 01 01/12/2007 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - REGULAR LASE NO: 2007-00156 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL VS BRAGSHAW LA WANDA 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 BRAGSHAW LA WANDA AKA LAWANDA BAGSHAW was served upon the DEFENDANT , at 1440:00 HOURS, on the 11th day of January-, 2007 at 217 NORTH BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 LAWANDA BRAGSHAW by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18 5.28 .00 .00 10.00 R. Thomas Kline nn 33.28 ? 01/12/2007 Q UDREN LAW OFFICES ' "x'60 By: day t h i f of A. D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw :NO. 2007-00156 P 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 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 subj t ion the penaKities f 18 Pa.C.S. Section 4904 relating to unsworn falsific ion to aut /1 Dated: June 1, 2007 UDREN OFF C S, I.C. BY: Mark J. Udren, Es ire 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 -COURT OF COMMON PLEAS for Freemont Investment & Loan :CIVIL DIVISION SABR 2005-FR1 by: Saxon =Cumberland County Mortgage Services, Inc. as its attorney-in-fact 'MORTGAGE FORECLOSURE Plaintiff V. La Wanda Bragshaw €:NO. 2007-00156 P a/k/a Lawanda Bagshaw Defendant (s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 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: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address La Wanda Bragshaw 217 North Baltimore Avenue a/k/a Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC Company c/o Joseph Colavecchi, Esquire 221 East Market Street, P.O.Box 131 Clearfield, PA 16803-0131 Borough of Mt. Holly Springs 200 Harmon Street Mt. Holly Springs, PA 17065 4. Name and address of of record: Name c/o Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 the last recorded holder of every mortgage Address Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mtg. Services, Inc. as its attorney-in-fact Vicki M. Micholas 5. Name and address of on the property: Name none 4708 Mercantile Drive Fort Worth, TX 76137 2653 Timberglen Drive Wexford, PA 15090 every other person who has any record lien Address 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 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 LAyd1 OEF?CES / IV. C. DATED: June 1, 2007 Mark J. Laren, s re Attorney /for ain iff 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 Freemont Investment & Loan SABR € CIVIL DIVISION 2005-FR1 by: Saxon Mortgage Services, Cumberland County Inc. as its attorney-in-fact Plaintiff € NO. 2007-00156 P V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): La Wanda Bragshaw a/k/a Lawanda Bagshaw PROPERTY: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 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 than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ,i/ EXHIBIT A .r• m y' N 0 ? ? y NLL v. ? d ' ? N LL .O ? N ao ly U- C7 ? d K?v o OU 00 V A d. 7 'O d U ? N a Q Q a vi 7 O a N a o 0 0 s s ' Z ? ? m y C? ' ?? c N U? 2V G 4 G `a ???? rn N 0 a d N 3 O N ? d N V Y o 1 NN CO tom.? 4 Z J Or= i v oc oov I ? N L N r W `t 7 M U. O m p o Q ? 4 ?? z ? rj z CL. 'oo W U_ N m Z44 N 00 Q G H U ul _ 50 Z Q o mx 7 4 z va d v . I ? 'L N Q Q V U k- D-? CD aty- D ?z 4 ? to D- 0 ° Q N cJi> rn. °c°+ U iavz ? L) a. r o. ?Q0.111N 10 r n -, I? INJ- cL M ui y t O i N M r = W d a. C-1 to g `t `ai Or ?U , N gU o = Uccn W o o t co d .d-or o s.. d o ? ? pp. H t=6 ? L N H 6 N ? N L 4 LID X _ C S d (0 C N ,p s O O ? T N ? C cry m d N d r3T0 , „ N C d G .? wdaTO?£a O m ??oppoey O t d ? S C ? C p N d C? N c a??E c A ? ? d awE??oR O 0-0 L h g1O G v o tll m?dd°.u QQQ 1 Q, e 5 m°% ui 30 d N - Q C N NS W. re G 7 C Td? o ? W? C.N d? > C `O O p r ? V U `d N .°. Ezz ? C O V E w .?? ? m y'ic y Y m 'O s m + w ? r C o ? g o E m z o d LL a d Io ?? ?(Io , 0, 0 R o-? D 0- A O-S Z o ? r co N co W to to 3 to J to co 2 a? 0 ti N a _ m o nN c s' d Ul) N r `EXHtB1T A L N co co co -o c co ?I _U- N s Na 9 . JN c wrn?o ddu. a G? U G O E m ? ? U 0 m $ 0. Q t? 7 o ? ?7 a ?? ioos 0 o.$ a o toap % o E c? a a v Its a Cl. 4DDD o 0 ul o us a.OGaW d E N Yi a 06 3: s .U 1, 0 W- NUJ Q Z d W?3: w O 7- 0-' no t Get ?a 0% R m 06 N J Z ? ? Z 0 ?o mW N N ? d ? ? N d c 2 e) \`t 2 g u3 a cw u$ig ? a x c? c4. ° -0 a+ o eta 8 o Ea V- d m a c O a m O G m 4 T r n 0 v g 0 N d N r ao O o ? a r 1 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY SILL, NJ 08003-3620 856-669-54.00 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005- FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2007-00156 P SUGGESTION OF SANRRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, La Wanda Bragshaw aka Lawanda Bagshaw has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on June 11, 2007, Bankruptcy Case No. #07-01752. I /k?/ ? Mark J. dren, quire UDREN LAW OFFICES, P.C. Attorney for Plaintiff r•a ..t rv fV Wells Fargo Bank NA, as Trustee for Freemont In the Court of Common Pleas of Investment & Loan SABR 2005-FRI by: Cumberland County, Pennsylvania Saxon Mortgage Services, Inc. as its Attorney- Writ No. 2007-156 Civil Term In-Fact VS La Wanda Bragshaw a/k/a Lawanda Bagshaw Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2007 at 1743 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: La Wanda Bragshaw a/k/a Lawanda Bagshaw, by making known unto Tammy Bragshaw, adult daughter of La Wanda Bragshaw a/k/a Lawanda Bagshaw, at 217 N. Baltimore Ave., Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1438 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 La Wanda Bragshaw a/k/a Lawanda Bagshaw, located at 215-215A N. Baltimore Ave., Mt. Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: La Wanda Bragshaw a/k/a Lawanda Bagshaw, by regular mail to her last known address of 217 North Baltimore Ave., Mt. Holly Springs, PA 17065. This letter was mailed under the date of April 4, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriff's Costs: Docketing $30.00 Poundage 18.91 Posting Bills 30.00 Advertising 30.00 Law Library .50 Prothonotary 1.00 Mileage 11.52 Levy 30.00 Surcharge 30.00 Law Journal 395.00 Patriot News 371.45 Share of Bills 16.17 $964.55?4- 91)gjt' 7 1.? if 9/73 So Answers: 9 R. Thomas Kline, Sheriff BY? I p 4A A J Estate S rgeant UDREN LAW OFFICES, P.C. BY: stark 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 Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) NO. 2007-00156 P AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 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: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address La Wanda Bragshaw 217 North Baltimore Avenue a/k/a Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC Company c/o Joseph Colavecchi, Esquire Address to Follow Borough of Mt. Address to Follow Holly Springs i ? ' a 4. Name and address of the of record: Name last recorded holder of every mortgage Address Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mtg. Services, Inc. as its attorney-in-fact 4708 Mercantile Drive. Fort Worth, TX 76137 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 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 16, 2007 Mark'b'-:-'Udren, ESQ. Attorney for Plaintiff .w UDREN LAN OFFICES, P.C. BY: Mark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant (s) NO. 2007-00156 P NOTICE OF SHERIFF'S SALE OF REAL PROPUTY To: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Your house (real estate) at 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 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 $133,417.78, 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 ONNaR'S RIBS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actioa: 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.) YCM MAY STILL BS ABLE TO SAVE YOUR PROPBRTY AI1D YOU HAVE OTHBR RIOHTB 8VSK IF THE SHERIFF'S SALE DOES TARS 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 TEN OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GNT LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-156 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW " TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NA, AS TRUSTEE FOR F'REEMONT INVESTMENT & LOAN SABR 2005-FR1 BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT, Plaintiff (s) From LA WANDA BRAGSHAW A/K/A LAWANDA BAGSHAW (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 $133,417.78 L.L. $30 Interest FROM 2/17/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $27.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,182.40 Atty's Comm % Atty Paid $141.56 Plaintiff Paid Date: FEBRUARY 16, 2007 (Seal) REQUESTING PARTY: Due Prothy $1.00 Other Costs C Long, Pro. By: Deputy Name MARK J. UDREN, ESQUIRE Address: 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 X"A Real Estate Sale # 6Q On March 8, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA Known and numbered as 215-215A N. Baltimore Avenue, Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 8, 2007 By: Real Estate Sergeant ' S .Z d OZ 931 tool 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. Marie Coyne, for SWORN TO AND SUBSCRIBED before me this 4 day of MgL 2007 VIISEAL V Lt"9 c. : d4'QE9, Notary Public Gr q Gui-nberland County u ..:. `. es March 5, 2009 KRAL. WrAXR IAAL 13 NO. 02 Writ No. 2007-156 Civil Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FRI by: Saxon Mortgage Services, Inc. as its attomey-in-fact. vs. La WVA" Br w a/k/a Atty.: Mark Udren ALL THOSE TWO CERTAIN tracks of land with the improve- ments thereon erected, situated in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Western side of Baltimore Avenue at the intersection of the Southern line of the land now or Bertie Shelly, formerly of Harry A. Buttorff and lands now or formerly of James Hoover and said Baltimore Avenue; thence along said alley North 3 de- grees 15 minutes West, 58 feet more or less, to the intersection of the land of Berne Shelly, formerly of ;p Harry A. Buttorff, and lands now or x., formerly of Julia J. Good and said Wood Alley; thence along said land South 87 degrees 30 minutes East, through the division wall of a double brick house erected thereon, a dis- tance of 183 feet, more or less; thence along the line of Baltimore Avenue, South 2 degrees 20 min- utes East, 68 feet, more or less to a point at the intersection of the land now of Joseph and Jennie Brandt, formerly of Martha E. Early, and said i. Baltimore Avenue: thence along said land, North 86 degrees 7 minutes West, 196 feet, more or less to Wood Alley; to the place of BEGINNING. BEING improved with the South- ern half of a double brick dwelling house known as No. 215 and 215A North Baltimore Avenue. UNDER AND SUBJECT to any and all covenants, conditions, re- strictions, rights-of-way, easements and agreements visible or of record. BEING KNOWN AS: 215-215A Xwth DOWNwre Awe, UL IU* Spr4aSiN PA 17065. Vii' K) NO.: 29-32-23W 141. TI"MZ TO SAID PREMISES IS VESTED IN Lawanda Bagshaw, adult individual by Deed from Vicki M. Micholas, widow dated 8/31/ 04 recorded 9/20/04 in Deed Book 265 Page 1507. A A THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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#62 Sworn to and subscribed before me this 18th day of May 2007 A.D. Notarial Seal Terry L Russell, Notary Public /Cily Of HW*Wrg Dauphin County /* 0myr(is)don Expires June 6, 2010 c' io of Notaries 4 NOVARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 I& UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 „ ,-r%c LORRAINE DOYLE, ESQUIRE - ID #34576 ,?.- F,?Y ALAN M. MINATO, ESQUIRE - ID #75860 (,4?' - g CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 4'vk CHERRY HILL, NJ 08003-3620 856-669-5400 rC?w??,'`"?1r11 pleadings!@udren.com Wells Fargo Bank NA, as Trustee for :COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005-FR1 ;CIVIL DIVISION by: Saxon Mortgage Services, Inc. as its :Cumberland County attorney-in-fact Plaintiff :MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda Bagshaw :NO. 2007-00156 P Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $133,417.78 Interest From 2/17/07 37,835.20 to Date of Sale December 8, 2010 Ongoing Per Diem of 27.20 to actual date of sale including if sale is held at a later date (Costs to be added) $ -W op P0, A-"y 33.a$ egg ou. 28 Q(oq.55 56.50 " 4. oo „ f 5 . oo 1,1AIJ. (o1 - PO AIW 4 a.00 Due Co UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ,LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ?-? ! X00845 0.14&3os P-z w UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 FL_ LORRAINE DOYLE, ESQUIRE - ID #34576 (` T'ar ` -` .,' ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER "i CcuN W 111 WOODCREST ROAD, SUITE 200 ?'c?"?P1'l ?VruVl?l CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as Trustee for :COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005- :CIVIL DIVISION FR1 by: Saxon Mortgage Services, Inc. =Cumberland County as its attorney-in-fact Plaintiff :MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda €NO. 2007-00156 P Bagshaw Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X .C. In Mortgage Foreclosure D. on a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. Ii. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): x A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. BY: Attorneys f aint' f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 Cdr, t` r; ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as Trustee for COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005- :CIVIL DIVISION FR1 by: Saxon Mortgage Services, Inc. :Cumberland County as its attorney-in-fact Plaintiff :MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda Bagshaw :NO. 2007-00156 P Defendant(s) C E R T I F I C A T E I hereby state that as 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 unswo_rn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys fc!rintiff " MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. J )MARK J. UDREN, ESQUIRE - ID #04302 ?. STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Wells Fargo Bank NA, as Trustee for :COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005-FR1 :CIVIL DIVISION by: Saxon Mortgage Services, Inc. as its :Cumberland County attorney-in-fact Plaintiff :MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda Bagshaw :NO. 2007-00156 P Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 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: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): C- _L Name Name Address 711 r; - --, La Wanda Bragshaw a/k/a 217 North Baltimore Avenue(,, G.r Lawanda Bagshaw Mt. Holly Springs, PA 1706 -a 2. Name and address of Defendant(s) in the judgment: c :- `'' 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 JMMMPC COMPANY Borough of Mt. Holly Springs 221 East Market Street P.O. Box 83 Clearfield, PA 16830 c/o Joseph Colavecchi Address to follow 200 Harman Street Mt. Holly Springs, PA 17065 c/o Keith O. Brenneman Address to follow 4. Name and address of 4. of record: Name Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vicki M. Nicholas 5. Name and address of on the property: Name None the last recorded holder of every mortgage Address 4708 Mercantile Drive Fort Worth, TX 76137 Address to follow 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 Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq. Carlisle, PA 17013 13 N. Hanover St. 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: September 14, 2010 UDREN LAW OFFICES, P.C. BY Attorneys f Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 ??sr .r rr i LORRAINE DOYLE, ESQUIRE - ID #34576 _ f. _ ~ ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 ?,u•, `r?Vip1 ?? CHERRY HILL, NJ 08003-3620 i t Ciiiv?7 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as Trustee for :COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005- :CIVIL DIVISION FR1 by: Saxon Mortgage Services, Inc. ;Cumberland County as its attorney-in-fact Plaintiff :MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda :NO. 2007-00156 P Bagshaw Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Your house (real estate) at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $133,417.78, 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 r. 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 ALAO TWO CUTAIN'cn M o` lad vft "bPVVctteaas *mum matt in tha barAo ttf i , bacmded tatd dmcj*W au fst: WMG ax a parrot tea RtaVAw= mWo trF'Babmm Avaum at 1)w imumadw of ate SoAma ** a f dw W ww at: iii 3bdIY, ! cf Hwy A. Sww ff t it r& ww cr fiwmsd? e0wft ffo mw ad tam IWenr AmnW t d trial c 3 doSm s 15 taiwk s'w"L 59'fimi == or 1Na,1a titabbnoedmeftba Lard aofs%* MAY, iy of Hsi ? aaci beg6t? m? oa' f ` a??'ie T_ acrd and said tYaaa?d I1lie?'; ?CV_ mid 1"d Sao& 47 da 30 t> Ewt tits wd of a 3r1a book baaae acasand.:b a of 3E3 iiaa? ? ? ? lheamc aiatt? ? 1ic? xtf Tdltititero? Avacuiq Samb 2 dgpvcs 20 vista £w,, 1% feot? mash or kw w a p dw at 'tbe hmxncim aftbe tmd now of Jo atad Sam le Bradt; h awtg 0f' Ma s F. Enly, apd atW 24*a= A><e w1 thaoc?e.,' 0rg tad hod, Net* 06 dorm 7 whom wM 196 Aced. ow-D (' imcs w Wmd +dJW*-. in. tits piece a?`ii IIQl MWG xopmwW vA* the Swt wt W of a dctdA b?Wk dm&w hmn Womm as No. VMMANDJ T1n odd WMWV, =MOW "O*dDW - , wwwo and * Vw-* w ere BEING KNOWN AS: 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 PROPERTY ID NO.: 23-32-2336-141 TITLE TO SAID PREMISES IS VESTED IN LAWANDA BAGSHAW, ADULT INDIVIDUAL BY DEED FROM VICKI M. MICHOLAS DATED 8/31/2004 RECORDED 9/20/2004 IN DEED BOOK 265 PAGE 1507. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-156 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 FREEMONT INVESTMENT & LOAN SABR 2005-FRI by: SAXON MORTGAGE SERVICES, INC. as its attorney-in-fact, Plaintiff (s) From LA WANDA BRAGSHAW a/ka /LAWANDA BAGSHAW (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 $133,417.78 L.L. Interest from 2/17/07 to Date of Sale 12/8/10 ongoing per diem of $27.20 to actual date of sale including if sale is held at a later date -- $37,835.20 Atty's Comm % Due Prothy $2.00 Atty Paid $1,127.61 Plaintiff Paid Date: 9/15/10 Other Costs D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LORRAINE DOYLE, ESQURIE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST RAOD, SUTIE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CH RA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86406 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in- fact Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS C: CIVIL DIVISION -03 ?i ° - € Cumberland County ?t '° o < rn z N ?rn ? r -z --4cv c-n z CD .. C-J am NO. 2007-00156 P -C u1 C AFFIDAVIT OF SERVICE PURSUANT TO P$.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November/f', 2010 UDREN. LAW OFFICES^ P . BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 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 for :COURT OF COMMON PLEAS Freemont Investment & Loan SABR 2005-FR1 =CIVIL DIVISION by: Saxon Mortgage Services, Inc. as its ':-Cumberland County attorney-in-fact Plaintiff !MORTGAGE FORECLOSURE V. La Wanda Bragshaw a/k/a Lawanda Bagshaw :NO. 2007-00156 P Defendant(s) _ AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney- in-fact, Plaintiff in the above action, by its attorney, UDREN LAW OFFICES, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed owner(s): Name Address La Wanda Bragshaw a/k/a 217 North Baltimore Avenue Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC COMPANY c/o Joseph Colavecchi, Esquire 221 E. Market Street, P.O. Box 131 Clearfield, PA 16830-0131 Borough of Mt. Holly Springs 4. Name and address of the of record: Name Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vicki M. Micholas 200 Harman Street Mt. Holly Springs, PA 17065 c/o Keith 0. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 last recorded holder of every mortgage Address 4708 Mercantile Drive Fort Worth, TX 76137 2653 Timberglen Drive Wexford, PA 15090 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 Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq. Carlisle, PA 17013 13 N. Hanover St. 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November / , 2010 UDREN LAW OFFICEwS, P.C. BY A 141 UZ L4(& 14 VA t Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE -1D #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff - v. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2007-00156 P TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): La Wanda Bragshaw a/k/a Lawanda Bagshaw PROPERTY: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 8. 2010, at 10:00 am, at the Commissioners Hearing Room, 2"d Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A . ?S v .D VJ fn o a o ? co 3 ` 3 N cn v C ° W C ° Z c o v ? a N ?Q t N m O 0 a w M ° m 0 V 3 3 a D C 0 ( cr a ? m n o m CL O ? 0 m m ° 0 ° a Q'c C ? `D3°ZSom` m m' M m j N O m C. 3S$c0 n m A C 7 S ? ? m m ? 01 O o j ? m m 3 ? m ma''??•?3 m y 05 CL0 000 Znm v 3 ° v c 0 w-m? o S. t m a 6, ?mpp m j m 5 C z i ??ym( Ca O m ?? m N m 7 W a m w irw ff m j .or o E? a z ? m m m ? o ?I AI wl Nl ?I a W N r a ro m °- O c 4 y 00 c lD N J cil ai k' 4 AO g p QW 0KNC_<D-1 w- n?i ?RibDm 3 K0?' ? om m?zZ ? 0a o ao?i nm-4 ?o ?wic Iao,M- -u Rn3pp? y 7 z Dzrngv =C r- 3c p no goo -?2 O ?? fC ?Ow?flJ 7 7 N lA N ^? ... a N $ K cn b < D Z D 0 gym. o N Cl m o m m w i• L •J t'?.16H2b5 ,9216 $``03.3'^6 Q 10112 572010 0 C.) c 3 mad-4 o o ?Om cc --I m m>nn p? Q z mpm z0 m mo CD Win= r°-4IrN-> AD m _?? cNipmp cc w ? FEZq -'-0 Z n r?p0 DmD? m < -4 11 o Z0 M 01 `I ?mwO;D o m oyy c D Z (0 0, C4 O C w nD ? Rfn O Z -v -' m N DQ = DDS a o 2 o X °' 0 C) D m Wm co Z M ? ? ?? Q y (off C (fJ . n a ? ° a m CD ? C] m m CD (D D? Q _ 3 N f ?p N R. a fD 0 Z D i f3? ??;v ? fD ? .C < r? ?p c G [S c' ? 3 S ? ° ^ O n n •f7 m ;o O1 ? 07 j ? Dj N j c f Q C j ag > N x n C fD 0 N n9 D az ? ? =' x m f n o CL N ? O M? CD CD ,? W Or T O ' ? y O C c 0 0. N 0 d fD 2 m ^. x ° N CD fD SHERIFF'S OFFICE OF CUMBERLAND COUNTY -- Ronny R Anderson Sheriff of Cumbar144 Jody S Smith Chief Deputy ; Richard W Stewart Solicitor OFFICE (J ; ahERIFF Wells Fargo Bank, N.A., vs. La Wanda Bragshaw Case Number 2007-156 SHERIFF'S RETURN OF SERVICE 10/11/2010 03:38 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on 10-11-10 at 1530 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 La Wanda Bragshaw, located at, 215 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 10/11/2010 03:37 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on 10-11-10 at 1532 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: La Wanda Bragshaw, by making known unto, La Wanda Bragshaw, personally, at 217 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $898.42 October 26, 2010 SO ANSWERS, Z RON R ANDERSON, SHERIFF EXHIBIT B (c) GountYSUite Shenff. Teleosoft. Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as €,COURT OF COMMON PLEAS Trustee for Freemont =CIVIL DIVISION Investment & Loan SABR 2005- 'Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact NO. 2007-00156 P Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE . r-- Fri Plaintiff, by its counsel, petitions the Court for a (1) one month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriffs sale of the mortgaged property involved herein, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 was originally scheduled for December 8, 2010, then postponed to February 2, 2011, then postponed to March 2, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale (1) one month to allow time to further complete mortgage loan document review. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. No Judge has been assigned to this matter. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the April 6, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: OTIali Attorney for Plaintiff CAit M. Arkema, Esquire. PA 10 203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- ':Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact NO. 2007-00156 P Plaintiff. V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to further complete mortgage loan account review. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, to the April 6, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, Local UDREN LAW OFFICES, P.C. BY: Attorney for intiff C:hWWN MA* m, F *Q 040 7 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingsoudren.com Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005- FR1 by: Saxon Mortgage Services, Inc. as its ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County attorney-in-fact ::NO. 2007-00156 P Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Def endant (s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served 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: March 1, 2011 TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 UDREN LAW OFFICES, P.C. BY: athan olf, Esquire Attorney for Plain iff Local Counsel Chandra M. Arkema, Esquire OA W 203+437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005- FR1 by: Saxon Mortgage NO. Services, Inc. as its attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) O R D E R 2007-00156 P AND NOW, this 15? day of March, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, it is hereby ORDERED that the said Sale currently scheduled for March 2, 2011, is extended (1) one month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for April 6, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 2, 2011 Sheriff's Sale. TO: ?La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 ? Udren Law Offices, P.C. 112 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department ? Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 CDpit5 fKA. l e( 44/1/ C rrf ? u,r =C:) --t -C tJ -v tv O Z co -r, =F C) BY THE COURT: UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact NO. 2007-00156 P Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) rn rn 0 Z ? to Cj ? ul?. Gn ? o a PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a (2) two month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 was originally scheduled for December 8, 2010, then postponed to February 2, 2011, then postponed to March 2, 2011, then postponed to April 6, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale (2) two month(s) to allow time to further complete mortgage loan document review. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable M.L. Ebert, Jr., was assigned to this matter and granted Plaintiff's order to Postpone Sheriff's sale to April 6, 2011. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the June 1, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY Nath C. olf, Esquire A r a ntiff Locall C nsel Alan M. Minato, Esquire PA ID 75860 TJDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- ::Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact NO. 2007--00156 P Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to further complete mortgage loan account review. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(x) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, to the June 1, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Nathan olf, Esquire _._ ore - 1 'ff Local o sel Alan M. Minato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as €:COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its attorney-in--fact ::NO. 2007-00156 P Plaintiff v. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: April 5, 2011 TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 UDREN LAW OFFICES, P.C. Nathan/C. olf, Esquire Local o sel BY: orney for Pla.int,177 Alan M. Minato, Esquire PA ID 75860 .,I.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005- FR1 by: Saxon Mortgage NO Services, Inc. as its attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant(s) O R D E R AND NOW, this 51h consideration of Plaintiff's 2007-00156 P day of April, 2011, after Petition for Postponement of C C::n i ? ? rn ca n D C7 X, :L -r) - n X =C n ° ' ?rj Sheriff's Sale of the mortgaged property located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, it is hereby ORDERED that the said Sale currently scheduled for April 6, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for June 1, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the April 6, 2011 Sheriff's Sale. BY THE COURT: M.L. Ebert Jr. TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 " Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 KI6I Attn: Sale Department 4K6 Office of the Sheriff hudMcWAd &( Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 VI/ 2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-156 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 FREEMONT INVESTMENT & LOAN SABR 2005-FRI BY SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT Plaintiff (s) From LA WANDA BRAGSHAW A/K/A LAWANDA BAGSHAW (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Yoware 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: $133,417.78 L.L.: Interest from 2/17/07 to date of sale 12/7/11 ongoing per diem of $27.20 - $47,736.00 Atty's Comm: % Atty Paid: $A,pl a, g$ Plaintiff Paid: Date: 8/11/11 (Seal) REQUESTING PARTY: Due Prothy: $2.00 Other Costs: Deputy Name: PAIGE M. PRONOVOST, ESQUIRE Address: UDREN LAW OFFICE, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 7856-669-5400 Supreme Court ID No. 309091 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- ,Cumberland County FR1 by: Saxon Mortgag e Services, Inc. as its :MORTGAGE FORECLOSURE -' -- -a; attorney-in-fact Plaintiff rn v . C:), La Wanda Bragshaw a/k/a -:NO. 2007-00156 P C7 Lawanda Bagshaw r-*C n De f endant (s) K -C3 © CD C PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $133,417.78 Interest From 2/17/07 47,736.00 to Date of Sale December 7, 2011 Ongoing Per Diem of 27.20 to actual date of sale including if sale is held at a later date (Costs to be added) Rv* P 4. by P4 "I 93.9? cbr- a(C.Rk «<< 4-1 %"ti SS. So " " ?. O C> l? q C?y' a a -w! of a -Pd al? C/I, Ar la0U a rz# OX go? q UDREN LAW OFFICES, P.C. BY: Attorne s for Plaintiff kJnJ c?,p b-, lss?l UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont =CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its ;MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a ::NO. 2007-00156 P Lawanda Bagshaw Defendant(s) CERTIFICATE TO THE SHERIFF d are Z rn C -C I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: __4 C_D -n C-1) --tom 4 UDREN LAW OFFICES, P .C. ?,J BY CJ?'" Attorn s for Plaintiff ?o p? ?a oSA ' E.; 9? (kA C- 7, TO '36 01 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as =COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a ::NO. 2007-00156 P Lawanda Bagshaw Defendant (s) C E R T I F I C A T E r Y ' rrr 70 - .. -0 ' G ) ..+? rri CD ? o_n Zo ? o E5 ..{r' I hereby state that as 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 statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: ti-' Attorney's for Plaintiff f gyn. ?????o, eS??• rj? --t 0 *-- --?0101( ' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF - WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont -CIVIL DIVISION Investment & Loan SABR 2005- :.Cumberland County FRl by: Saxon Mortgage e? Services, Inc. as its MORTGAGE FORECLOSURE attorney-in-fact Y Plaintiff ter- _- v . c? , --4ci La Wanda Bragshaw a/k/a :NO. 2007-00156 P = =;F3 Lawanda Bagshaw -C:) yc ? ?s Defendant (s) D AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney- in-fact, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address La Wanda Bragshaw a/k/a 217 North Baltimore Avenue Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC Company C/O Joseph Colavecchi, Esq 221 E. Market Street, P.O. Box 131 Clearfield, PA 16830-0131 Borough of Mt. Holly Springs 200 Harman Street Mt. Holly Springs, PA 17065 C/O Keith 0. Brenneman, Esq 44 West Main Street Mechanicsburg, PA 17055 4. Name and address of of record: Name Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vicki M. Micholas Address 4708 Mercantile Drive Fort Worth, TX 76137 2653 Timberglen Drive Wexford, PA 15090 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 Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 29, 2011 UDREN LAW OFFICES, , P.C. / BY: a In C?DUOP ,„mil AttorneyV for Plaintiff the last recorded holder of every mortgage ` UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- =Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a ::NO. 2007-00156 P Lawanda Bagshaw Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 G rnco 2rn 270 r-'= to 'PP 2 0 ?C-- w cc.s Your house (real estate) at 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $133,417.78, 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: ca := -n c:)-n o ---tom' 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ¦ , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - Jody S Smith Chief Deputy ? Richard W Stewart Solicitor LEN IN ic r^ Wells Fargo Bank, N.A. Case Number vs. La Wanda Bragshaw 2007-156 SHERIFF'S RETURN OF SERVICE 09/29/2011 02:00 PM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 215-215A North Baltimore Avenue, Mount Holly Springs, PA 17065, Cumberland County. 09/29/2011 02:00 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be steven wert son in law -aic, who accepted as "Adult Person in Charge" for La Wanda Bragshaw at 217 North Baltimore Avenue, Mount Holly Springs, PA 17065, Cumberland County. 12/05/2011 As directed by Lorraine Doyle, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/1/2012 01/31/2012 As directed by Lorraine Doyle, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2012 04/02/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $835.75 April 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF UDREN.LAW*OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- :Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a -NO. 2007-00156 P Lawanda Bagshaw Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney- in-fact, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner(s): Name Address La Wanda Bragshaw a/k/a 217 North Baltimore Avenue Lawanda Bagshaw Mt. Holly Springs, PA 17065 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 JMMMPC Company C/O Joseph Colavecchi, Esq 221 E. Market Street, P.O. Box 131 Clearfield, PA 16830-0131 Borough of Mt. Holly Springs 200 Harman Street Mt. Holly Springs, PA 17065 C/O Keith 0. Brenneman, Esq 44 West Main Street Mechanicsburg, PA 17055 4. Name and address of of record: Name the last recorded holder of every mortgage Address Wells Fargo Bank NA, as Trustee for Freemont Investment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vicki M. Micholas 5. Name and address of on the property: Name None 4708 Mercantile Drive Fort Worth, TX 76137 2653 Timberglen Drive Wexford, PA 15090 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 Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 29, 2011 UDREN LAW OFFICES, P.C. BY: 14A Attorney for Plaintiff VI ?? ?,, ? JL" 1 Cs C C UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF W0 DCREST CORPORATE CENTER 12.1 W06DCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as :COURT OF COMMON PLEAS Trustee for Freemont :CIVIL DIVISION Investment & Loan SABR 2005- ::Cumberland County FR1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff V. La Wanda Bragshaw a/k/a ':NO. 2007-00156 P Lawanda Bagshaw Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Your house (real estate) at 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $133,417.78, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THOSE TWO CERTAIN TRACTS OF LAND WITH THE IMPROVEMENTS THEREON ERECTEf SITUATED IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WESTERN SIDE OF BALTIMORE AVENUE AT THE INTERSECTION OF THE SOUTHERN LINE OF THE LAND NOW OR BERNIE SHELLY, FORMERLY OF HARRY A. BUTTORFF AND LANDS NOW OR FORMERLY OF JAMES HOOVER AND SAID BALTIMORE AVENUE; THENCE ALONG SAID ALLEY NORTH 3 DEGREES 15 MINUTES WEST, 58 FEET MORE OR LESS, TO THE INTERSECTION OF THE LAND OF BERNIE SHELLY, FORMERLY OF HARRY A. BUTTORFF, AND LANDS NOW OR FORMERLY OF JULIA J. GOOD AND SAID WOOD ALLEY; THENCE ALONG SAID LAND SOUTH 87 DEGREES 30 MINUTES EAST, THROUGH THE DIVISION WALL OF A DOUBLE BRICK HOUSE ERECTED THERE, A DISTANCE OF 183 FEET, MORE OR LESS; THENCE ALONG THE LINE OF BALTIMORE AVENUE, SOUTH 2 DEGREES 20 MINUTES EAST, 68 FEET MORE OR LESS TO A POINT AT THE INTERSECTION OF THE LAND NOW OF JOSEPH AND JENNIE BRANDS, FORMERLY OF MARTHA E. EARLY, AND SAID BALTIMORE AVENUE; THENCE ALONG SAID LAND, NORTH 86 DEGREES 7 MINUTES WEST, 196 FEET MORE OR LESS TO WOOD ALLEY; TO THE PLACE OF BEGINNING. BEING IMPROVED WITH THE SOUTHERN HALF OF A DOUBLE BRICK DWELLING HOUSE KNOWN AS NO. 215 AND 215A NORTH BALTIMORE AVENUE. UNDER AND SUBJECT TO ANY AND ALL COVENANTS, CONDITIONS, RESTRICTIONS, RIGHT-OF-WAY, EASEMENTS AND AGREEMENTS VISIBLE OR OF RECORD. BEING KNOWN AS: 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 PROPERTY ID NO.: 23-32-2336-141 TITLE TO SAID PREMISES IS VESTED IN LAWANDA BAGSHAW, ADULT INDIVIDUAL BY DEED FROM VICKI M. MICHOLAS, WIDOW DATED 8/31/2004 RECORDED 9/20/2004 IN DEED BOOK 265 PAGE 1507. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-156 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 FREEMONT INVESTMENT & LOAN SABR 2005-FRI BY SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT Plaintiff (s) From LA WANDA BRAGSHAW A/K/A LAWANDA BAGSHAW (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: $133,417.78 L.L.: Interest from 2/17/07 to date of sale 12/7/11 ongoing per diem of $27.20 - $47,736.00 Atty's Comm: % Arty Paid: $Dj, a D. Plaintiff Paid: Date: 8/11 /11 (Seal) REQUESTING PARTY: Due Prothy: $2.00 Other Costs: avid D. VBUIII. Prothonotary By: Name: PAIGE M. PRONOVOST, ESQUIRE Address: UDREN LAW OFFICE, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Deputy TRUE COPY FROM R;rCORI] In Testimony whereof, I here unto set my hand and they seal of said court at Carlisle, 0 a. Thi-.--daliOf Prothonotary Telephone: 7856-669-5400 Supreme Court ID No. 309091 On August 19, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Mount Holly Borough, Cumberland County, PA, Known and numbered as, 215-215A North Baltimore Avenue, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2011 By: 01 mob C-A Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2007-156 Civil Wells Fargo Bank, N.A. vs. La Wanda Bragshaw, a/k/a Lawanda Bagshaw Atty.: Mark Udren ALL those two certain tracts of land with the improvements thereon erected situated in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western side of Baltimore Avenue at the intersection of the southern line of the land now or Bernie Shelly, for- merly of Harry A. Buttorff and lands now or formerly of James Hoover and said Baltimore Avenue; thence along said alley North 3 degrees 15 minutes West, 58 feet more or less, to the intersection of the land of Bernie Shelly, formerly of Harry A. Buttorff, and lands now or formerly of Julia J. Good and said Wood Alley; thence along said land South 87 degrees 30 minutes East, through the division wall of a double brick house erected there, a distance of 183 feet, more or less; thence along the line of Bal- timore Avenue, South 2 degrees 20 minutes East, 68 feet more or less to a point at the intersection of the land now of Joseph and Jennie Brands, formerly of Martha E. Early, and said Baltimore Avenue; thence along said land, North 86 degrees 7 minutes West, 196 feet more or less to Wood Alley; to the place of beginning. BEING IMPROVED with the southern half of a double brick dwelling house known as No. 215 and 215A North Baltimore Avenue. UNDER AND SUBJECT to any and all covenants, conditions, restric- tions, right-of-way, easements and agreements visible or of record. BEING KNOWN AS: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065. PROPERTY ID NO.: 23-32-2336- 141. TITLE TO SAID PREMISES IS VESTED IN Lawanda Bagshaw, adult individual by deed from Vicki M. Micholas, widow dated 8/31/2004 recorded 9/20/2004 in Deed Book 265 Page 1507. 21 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes 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: Ov.tnher 21. October 28. and November 4, 2011 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. sa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this da of November. 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My commission Expires Apr 28, 2014 4 2007-156 Clvil Term Wells Fargo Bank, N.A. Vs La Wanda Bragshaw, a/k/a Lawanda Bagshaw Atty: Mark Udren All Those Two Certain Tracts Of Land With The Improvements Thereon Erected Situated In The Borough Of Mount Holly Springs, Cumberland County, Pennsylvania, Bounded And Described As Follows: Beginning At A Point On The Western Side Of Baltimore Avenue At The Intersection Of The Southern Line Of The Land Now Or Bernie Shelly, Formerly Of Harry A. Buttorff And Lands Now Or Formerly Of James Hoover And Said Baltimore Avenue; Thence Along Said Alley North 3 Degrees 15 Minutes West, 58 Feet More • Or Less, To The Intersection Of The Land Of Bernie Shelly, Formerly Of Harry A- Buttorff, And Lands Now Or Formerly l Of Julia J. Good And Said Wood Alley; Thence Along Said Land South 87 Degrees 30 Minutes East, Through The Division Wall Of A Double Brick House Erected There, A Distance Of 183 Feet, More Or Less; Thence Along The Line Of Baltimore Avenue, South 2 Degrees 20 Minutes East, 68 Feet More Or Less To A Point At The Intersection Of The Land Now Of Joseph And Jennie Brands, Formerly Of Martha E. Early. And Said Baltimore Avenue; Thence Along Said Land, North 86 Degrees 7 Minutes West, 1% Feet More Or Less To r w .. Wood Alley; To The Place Of Beginning. Being Improved With The Southern Half Of A Double Brick Dwelling House Known As No. 215 And 215A North Baltimore Avenue. Under And Subject To Any And All Covenants, Conditions, Restrictions, Right- Of-Way, Easements And Agreements Visible Or Of Record. Being Known As: 215-215A North Baltimore Avenue Mt. Holly Springs, Pa 17065 Property Id No.: 23-32-2336-141 Title To Said Premises Is Vested In I awanda Bagshaw, Adult Individual By O-ed From Vicki M. Micholas, Widow Dated 8/31/2004 Recorded 9/20/2004 In Deed Book 265 Page 1507. 2007-156 CMI Term :'dells Fargo Bank, N.A. Vs La Wanda Bragshaw, a/k/a Lawanda Bagshaw Atty: Mark Udren All Those Two Certain Tracts Of Land With The Improvements Thereon Erected Situated In The Borough Of Mount Holly Springs, Cumberland County, Pennsylvania, Bounded And Described As Follows: Beginning At A Point On The Western Side Of Baltimore Avenue At The Intersection Of The Southern Line Of The Land Now Or Bernie Shelly, Formerly Of Harry A. Buttorff And Lands Now Or Formerly Of James Hoover And Said Baltimore Avenue; Thence Along Said Alley North 3 Degrees 15 Minutes West, 58 Feet More Or Less, To The Intersection Of The Land Of Bernie Shelly, Formerly Of Harry A. Bottorff. And Lands Now Or Formerly Of Julia J. Good And Said Wood Alley; Thence Along Said Land South 87 Degrees 30 Minutes East, Through The Division Wall Of A Double Brick House Erected There, A Distance Of 183 Feet, More Or Less; Thence Along The Line Of Baltimore Avenue, South 2 Degrees 20 Minutes East, 68 Feet More Or Less To A Point At The Intersection Of The Land Now Of Joseph And Jennie Brands, Formerly Of Martha E. Early. And Said Baltimore Avenue; Thence Along Said Land, North 86 Degrees 7 Minutes West, 196 Feet More Or Less to Wood Alley; To The Place Of Beginning. Being Improved With The Southern Half Of A Double Brick Dwelling House Known As No. 215 And 215A North Baltimore Avenue. Under And Subject To Any And All Covenants, Conditions, Restrictions, Right- Of-Way, Easements And Agreements Visible Or Of Record. Being Known As: 215-215A North Baltimore Avenue Mt. Holly Springs, Pa 17065 Property Id No.: 23-32-2336-141 Title To Said Premises Is Vested In I a,,vanda Bagshaw, Adult Individual By Jeed From Vicki M. Mieholas, Widow Dated 8/31/2004 Recorded 9/20/2004 In Deed Book 265 Pagc 1507. The Patriot-Mews Co. 2020 Technology Pkwy/ S..Iite 3o o Mechanicsburg-, PIA 17050 Inquiries 71:1_255-8213 CUMEERL `.ND CO. SHERIFFS OFFICE CUMFERL ' ND COUNTY COURT HOUSE CARLISLE PA 17013 ?e ?latriot-?'ews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587. Approved May 16, 1929 Commonwealth of Pennsylvania, Courty of Dauphin} ss Holly Blain being duly sworn according to law, deposes and says: That sne is a Sta Accountant of The Patriot News Co.. a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newsoapers of general circulation, printed and published at 1900 Patriot Drive, 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 printer and pub )shed in their regular daily and/or Sundave Corr munity Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in 'he 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 she has per,;onal knowledge of the facts aforesaid and is duly authorized and empowered :o verify this statement on behaif of Tie Patriot-News Co. aforesaid by virtue and pursuant to a iesoiudon unanimously passed anc adopied severally by the stockholders and board o` directors of the said Company and subsequently duly recorded in the offce fc:, the Recording of Deeds in and for said County of F;,auohin in Miscellaneous Book "M", Volume 1-1--, Page 317. PUBLICATION COI 'e This ad ran on the date(s) shown below: 10121/11 10/28111 11/04/11 Sworn to and subscribed before me this 16 day of November A.D. Notary Public __g0MMQNWEALTH OF PENNSYLVANIA Notarial Seal ??_ Sherrie Owens, Notary Public Luwer dagcrn rwp., Dauphin County My Commission Expires Nov. 2b, 2015 MEM6ER: PENN( YWANITAgSCIATY? 0' NOTARIES UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Wells Fargo Bank NA, as Trustee for Freemont :: COURT OF COMMON PLEAS Investment & Loan SABR 2005-FR1 by: Saxon : CIVIL DIVISION ' Mortgage Services, Inc. as its attorney-in- : Cumberland County fact r Zf— (:D Plaintiff V. La Wanda Bragshaw a/k/a Lawanda Bagshaw : NO. 2007-00156 P Defendant (s) AMENDED ,AFFIDA VIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney 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 11B11 . 3 . If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B" . 4 . If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B" . All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May 2013 UDREN LAW OFFICES, P.C. BY Attorneys for Plaintiff SALVATORE CAROLLO, ESQUIRE PA 1D 311050 UDREN LAW OFFICES, .P.C. ATTORNEY FOR PLAINTIFF WOODCAEST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com C= Wells Fargd Bank NA, as Trustee COURT OF COMMON PLEAS. for Freemont Investment & Loan :: CIVIL DIVISION =MCD M rn SABR 2005-FR1 by& Saxon : Cumberland County Z::;u r- -VM Mortgage Services, Inc. as its CD attorney-in-fact ci Plaintiff BNO. 2007-,00156 P )> CD V. CD C-) La Wanda Bragshaw a/k/a Lawanda > 8agshaw Defendant (s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, .by its counsel, petitions the Court for a 2 (two) month postponement of the Sheriff ' s sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff ' s Pale of the mortgaged property involved herein, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 was originally scheduled for March 6, 2.013, then postponed to April 3, 2013 due to an unresolved assignment issue, then postponed to July 10., 2013. 2 . The Plaintiff seeks the postponement of the Sheriff' s sale 2 (two) month(s) to allow Plaintiff time to resolve the pending assignment issue. 3 . Pursuant to local rule the defendant is unrepresehted by counsel and plaintiff has no manner in which to seek concurrence except by mail . 4 . No. judge has been assigned to this matter. WHEREFORE, Plaintl:ff respectfully preys and .reques.ts that the .Sheriff's sale of the mottc}a:ged property be postponed to the September 4; 2013 Sheriff"s sale Respectfully s:ubm tted, CJDREN LAW OFFTGESr P".0 Nathan cO f, Esquire AtU�o�xn' for �/Saintiff Local nsel a1RR 8.I .E, iltE FA ID�10501 U1)RzN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-669-5400, pleadings@udren.com a Wells Fargo Bank NA, as Trustee 1111COURT OF COMMON PLEAS for Freemont Investment & Loan iCIVIL DIVISION SABR 2005-FRI by: Saxon sCumberland County Mortgage Services, Inc. as its j attorney-in-fact Plaintiff INO. 2007-00156 P V. La Wanda Bragshaw a/k/a Lawanda -1 Bagshav Defendant {s} IS MANOR—A)MU—N O bit Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court, Accordingly, for the. reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 215-215A Worth Baltimore Avenue, Mt. Holly Springs, PA 17065, to the September 4, 2013 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDR EN LAW OFFICES, P.C. BY: athap` . Wolf, Esquire AttUne' .7/fr'7VI intiff ocaX.,-Counsel HARRY 4. it: eswm PA W310SCI UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY SILL, NJ 08003-3620 856-669-5400, pleadings @udren.Com Wells Fargo Bank NA, as : COURT OF COMMON PLEAS Trustee for Freemont . CIVIL DIVISION Investment & Loan SABR 2005- : Cumberland County FR1 by: Saxon Mortgage r Services, Inc. as its attorney-in-fact = NO. 2007-00156 P ''Plaintiff V. La Wanda -Bragshaw a/k/a Lawanda Bagshaw Defendant (s) i 4 C ERTIFICA OF SERVXC R The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the- following person(s) named herein at their last known address or their attorney of record. by: xxxx Regular First Class Mail Certified Mail Other Date Served.: July 8, .2013 TO: La Wanda Bragshaw a/.k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt: Holly Springs, PA 17065 IUDREN LAW OFFICES, P .0. BY: � f\ Nathan. Wolf, Esquire •Att me for aintiff Local 66unsel MARRY a»}t£ , €SWYRtE + ►311001 IN THE COMT OF COMON PLEAS OF CMMPJAM COUNTY CIVIL DIVISION Wells Fargo Bank NA, as Trustee for Freemont, Investment & Loan SABR 2005- M FRI by: Saxon Mortgage iWo. 2007-00156 P XM Services, Inc. as its attorney-in-fact c) Plaintiff v La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant (s) 0 R D 19 R AAD NOW, this day of July, -2013, after consideration of plaintiff's Petition for Postponement ,of Sheriff's Sale ,of the mortgaged property located at 215-:215A North Baltimore Avenue Mt. Rol I ly Springs, PA 17065, it is hereby ORDERED that the said Sale currently scheduled for July 10, 2013, is extended 2 (two) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for September 4, 2013-. No further advertising or additional notice to lietholders or Defendant(s) is required provided the postponement is announced at the July 10, 2013 Sheriff's Sale. BY T1,1E COURT- TO: clfa- Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Sheriff of Cumberland County One Courthouse Square Carlisle, PA 17013-330 ren Law Offices, P.C. Ill. Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Q?,ivr A/fj UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com C-) Wells Fargo Bank NA, as Trustee COURT OF COMMON PLEAS rnW = cn for Freemont Investment & Loan ! CIVIL DIVISION M rn r; SABR 2005-FR1 by; Saxon = Cumberland County 4cnf- Mortgage Services, Inc. as its -<> W attorney-in-fact Plaintiff '* NO. 2007-00156 P V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendants) PETITION FOR POSTPONEMENT OF AffAj-FF'S SALE Plaintiff, by its counsel, petitions the Court for a 2 (two) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff' s sale of the mortgaged property involved herein, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 was originally scheduled for March 6, 2013, then postponed to April 3, 2013 due to an unresolved assignment issue, then postponed to July 10, 2013, then postponed to September 41 2011-1 2. The Plaintiff seeks the postponement of the Sheriff' s sale 2 (two) month(s) to allow Plaintiff time to resolve the pending assignment issue,,,,, 3. Pursuant to local rule the defendant is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4.,, The Honorable M.L.-4. Ebert, Jr., was assigned to this matter and granted Plaintiff's prior petition to postpone sheriff sale,. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the November 6, 2013 Sheriff's sale. Respectfully submitted, UDREN LAW. OFFICES, P.C_a BY. _ Nath C olf, Esquire Ad o ey or laintiff Local sel BARRY S. R SE,M QUM PA ID awsft UDREN LAN OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, Ni 08003-3620 856-669-5400, pleadings@udren.com Wells Fargo Bank NA, as Trustee COURT OF COMMON PLEAS for Freemont Investment & Loan ECIVIL DIVISION SABR 2005-FR1 by: Saxon * Cumberland County Mortgage Services, Inc. as its I attorney-in-fact Plaintiff iNO. 2007-00156 P V. La Wanda Bragshaw a/k/a Law' anda Bagshaw Defendant (s) PLAINTIFF'S bMMRANDML.-OF LAW Pennsylvania R.C.P. 3129.3 (b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, to the November 6, 2013 Sheriff' s sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C.,- BY: aEhan ,Xolf, Esquire At ,ornVy for aintif Local Cu6sel HARRY EL ftL. #SWIRE PA 7D 3105OI UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com- Wells Fargo Bank NA, as = COURT OF COMMON PLEAS Trustee for Freemont - CIVIL DIVISION Investment & Loan SABR 2005- - Cumberland County FRI by: Saxon Mortgage Services, Inc. as its attorney-in-fact * NO. 2007-00156 P Plaintiff 1 V. La Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant (s) CERTIFICILTE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following pprson (s) named herein at their last known address or their attorney of record by: -xxxx_ Regular First Class Mail Certified Mail Other Date Served; September 3, 2013 TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly S ngs, PA 17065 UDREN :LAW OFFICES, P.,C,, BY: Nathan C/WX] f, Esquire Attu*/far�Pl Intiff Local 4u py's e 1 HARRY B.REF-SE,,ESQU1ft PA ID 310SOI t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Wells Fargo Bank NA, as t`) C Trustee for Freemont 3 Investment & Loan SABR 2005- MM FR1 by: Saxon Mortgage INO. 2007-00156 P - Services, Inc. as its a ��, c attorney-in-fact < ` Ctom; Plaintiff V. CD Wanda Bragshaw a/k/a Lawanda Bagshaw Defendant (s) O R D E R AND NOW, this gno�,_day of September, 2013, after consideration of Plaintiff' s Petition for Postponement of Sheriff's Sale of the mortgaged property located at 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065, it is hereby ORDERED that the said Sale currently scheduled for September 4, 2013, is extended 2 (two) month(s) to the regularly scheduled Cumberland County Sheriff' s Sale scheduled for November 6, 2013. No further advertising or additional notice to lienholders or Defendant (s) is required provided the postponement is announced at the September 4, 2013 Sheriff's S BY THE CO. R 4�A_ TO: ,X'a Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Sheriff of Cumberland County - 6cccLl,J Vt One Courthouse Square Car isle, PA 17013-3387 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department 4� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff I ff ��k}qtr nt �"um ,r, Jody S Smith Chief Deputy t r A11 1 : Richard W Stewart Solicitor OFFICE OF THE$t4ER1FF :.'v r D R L r 3i V J..J;1 6..I. Wells Fargo Bank, N.A. Case Number vs. La Wanda Bragshaw 2007-156 SHERIFF'S RETURN OF SERVICE 01/02/2013 11:59 AM - Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 215-215A North Baltimore Avenue, Mt Holly Springs, PA 17065, Cumberland County. 01/02/2013 11:59 AM -Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: La Wanda Bragshaw at 217 North Baltimore Avenue, Mount Holly Springs, PA 17065, Cumberland County. 02/22/2013 As directed by Lorraine Doyle,Attorney for the Plaintiff, Sheriff's Sale Continued to 4/3/2013 04/01/2013 As directed by Lorraine Doyle, Attorney for the Plaintiff, Sheriff's Sale Continued to 7/10/2013 07/09/2013 As directed by Lorraine Doyle, Attorney for the Plaintiff, Sheriff's Sale Continued to 9/4/2013 09/03/2013 As directed by Lorraine Doyle, Attorney for the Plaintiff, Sheriff's Sale Continued to 11/6/2013 11/06/2013 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, PA on November 06, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Lorraine Doyle, on behalf of Wells Fargo Bank, National Association, as Trustee for Securitized Asset Backed Receivables, LLC Trust 2005-FR1, Mortgage Pass-Through Certificates, Series 2005-FR1, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,328.36 SO ANSWERS, November 21, 2013 RONNK ANDERSON, SHERIFF z/f.0o ia !- dd. 'd £; Al 'Wog,2 is CountySuite Sheriff,Teleesott,Inc. UDREN LiiA'! OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as COURT OF COMMON PLEAS Trustee for Freemont CIVIL DIVISION Investment & Loan SABR 2005- Cumberland County FR1 by: Saxon Mortgage Services, Inc . as its MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. La Wanda Bragshaw a/k/a NO. 2007-00156 P Lawanda Bagshaw Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129 . 1 AND RULE 76 Wells Fargo Bank NA, as Trustee for Freemont Inlvestment & Loan SABR 2005-FR1 by: Saxon Mortgage Services, Inc . as its attorney- in-fact, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P. C. , sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 215-215A North Baltimore Avenue, Mt. Holly Springs, PA 17065 1. Name and address of Owner(s) or reputed Owner (s) : Name Address • La Wanda Bragshaw a/k/a 217 North Baltimore Avenue Lawanda Bagshaw Mt . Holly Springs, PA 17065 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 JMMPC Company C/O Joseph Cikavecchi, Esq 221 E. Market Street, P.O. Box 131 Clearfield, PA 16830-0131 Borough of Mt Holly Springs 200 Harman Street Mt . Holly Springs, PA 17065 C/O Keith 0. Brenneman, Esq 44 West Main Street Mechanicsburg, PA 17055 4 . Name s and address of the last recorded holder of every mortgage of .record: Name Address Wells Fargo Bank NA, as Trustee 4708 Mercantile Drive for Freemont Investment & Loan Fort Worth, TX 76137 SABR 2005-FR1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vicki M. Micholas 2653 Timberglen Drive Wexford, PA 15090 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 Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 • Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue 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 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 I verify that the statements made in this affidavit . are true and correct to the best of my information and belief . I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. sec . 4904 relating to unsworn falsification to authorities . • DATED: September 28 , 2012 UDRE LAW OFFICES, P.C. BY ` y At aintiff HARRY B. REESE, ESQUIRE PA ID 310501 UDREN ,LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Wells Fargo Bank NA, as COURT OF COMMON PLEAS Trustee for Freemont CIVIL DIVISION Investment & Loan SABR 2005- Cumberland County FRi by: Saxon Mortgage Services, Inc . as its MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. La Wanda Bragshaw a/k/a NO. 2007-00156 P Lawanda Bagshaw Defendant (s) NOTICE OF SHERIFF' S SALE OF REAL PROPERTY TO: La Wanda Bragshaw a/k/a Lawanda Bagshaw 217 North Baltimore Avenue Mt. Holly Springs, PA 17065 Your house (real estate) at 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 is scheduled to be sold at the . Sheriff ' s Sale on March 6, 2013 , at 10 : 00 am in the Commissioners Hearing Room , 2nd Floor, Courthouse, Carlisle, PA to enforce the court judgment of $133 , 417 . 78 , 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'F, 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 WRIT OF EXECUTION and/or ATTACHMENT • COMMONWEALTH OF PENNSYLVANIA) NO. 07-156 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,NA,as Trustee for FREEMONT INVESTMENT& LOAN SABR 2005-FR1 by: SAXON MORTGAGE SERVICES, INC,as its attorney-in-fact, Plaintiff(s) From LA WANDA BRAGSHAW a/k/a LAWANDA BRAGSHAW (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: $133,417.78 L.L.: Interest from 2/17/07 to 3/6/13 Ongoing per diem of$27.20 to actual date of sale including if sale is held at a later date -- $60,112.00 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $2,876.33 Other Costs: Plaintiff Paid: Date: 10/2/12 David D. Buell,Prothonotary (Seal) if Deputy REQUESTING PARTY: Name: HARRY B. REESE, ESQUIRE TRUE COPY FROM RECORD Address: UDREN LAW OFFICES,PC In Testimony whereof,!here unto set my hand WOODCREST CORPORATE CENTER and the seat of said Court at Carlisle,Pa. This ,2'1`d da od /)CD" 20 /al- 111 WOODCREST ROAD,SUITE 200 (C - 1,4 Prothonotary CHERRY HILL,NJ 08003-3620 l//J Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No.310501 ALL THOSE TWO CERTAIN TRACTS OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATED IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WESTERN SIDE OF BALTIMORE AVENUE AT THE INTERSECTION OF THE SOUTHERN LINE OF THE LAND NOW OR BERNIE SHELLY, FORMERLY OF HARRY A. BUTTORFF AND LANDS NOW OR FORMERLY OF JAMES HOOVER AND SAID BALTIMORE AVENUE; THENCE ALONG SAID ALLEY NORTH 3 DEGREES 15 MINUTES WEST, 58 FEET MORE OR LESS, TO THE INTERSECTION OF THE LAND OF BERNIE SHELLY, FORMERLY OF HARRY A. BUTTORFF, AND LANDS NOW OR FORMERLY OF JULIA J. GOOD AND SAID WOOD ALLEY; THENCE ALONG SAID LAND SOUTH 87 DEGREES 30 MINUTES EAST, THROUGH THE DIVISION WALL OF A DOUBLE BRICK HOUSE ERECTED THERE, A DISTANCE OF 183 FEET, MORE OR LESS; THENCE ALONG THE LINE OF BALTIMORE AVENUE, SOUTH 2 DEGREES 20 MINUTES EAST, 68 FEET MORE OR LESS TO A POINT AT THE INTERSECTION OF THE LAND NOW OF JOSEPH AND JENNIE BRANDS, FORMERLY OF MARTHA E. EARLY, AND SAID BALTIMORE AVENUE; THENCE ALONG SAID LAND, NORTH 86 DEGREES 7 MINUTES WEST, 196 FEET MORE OR LESS TO WOOD ALLEY; TO THE PLACE OF BEGINNING. BEING IMPROVED WITH THE SOUTHERN HALF OF A DOUBLE BRICK DWELLING HOUSE KNOWN AS NO. 215 AND 215A NORTH BALTIMORE AVENUE. UNDER AND SUBJECT TO ANY AND ALL COVENANTS, CONDITIONS, RESTRICTIONS, RIGHT-OF-WAY, EASEMENTS AND AGREEMENTS VISIBLE OR OF RECORD. BEING KNOWN AS: 215-215A North Baltimore Avenue Mt. Holly Springs, PA 17065 PROPERTY ID NO. : 23-32-2336-141 TITLE TO SAID PREMISES IS VESTED IN LAWANDA BAGSHAW, ADULT INDIVIDUAL BY DEED FROM VICKI M. MICHOLA.S, WIDOW DATED 8/31/2004 RECORDED 9/20/2004 IN DEED BOOK 265 PAGE 1507 . - . CUMBERLAND LAW JOURNAL Writ No. 2007-156 Civil BEING KNOWN AS: 215-215A North Baltimore Avenue Mt. Holly Wells Fargo Bank, N.A. Springs, PA 17065. vs. PROPERTY ID NO. :23-32-2336- La Wanda Bragshaw 141. a/k/a Lawanda Bagshaw TITLE TO SAID PREMISES is vested in Lawanda Bagshaw, adult Atty.: Lorraine Doyle individual by Deed from Vicki M. ALL those two certain tracts of Micholas, widow dated 8/31/2004. land with the improvements thereon recorded 9/20/2004 in Deed Book erected situated in the Borough of 265 Page 1507. Mount Holly Springs, Cumberland County,Pennsylvania,bounded and described as follows: BEGINNING at a point on the western side of Baltimore Avenue at the intersection of the southern line of the land now or Bernie Shelly,for- merly of Harry A.Buttorff and lands now or formerly of James Hoover and said Baltimore Avenue; thence along said alley North 3 degrees 15 minutes West,58 feet more or less,to the intersection of the land of Bernie Shelly,formerly of Harry A.Buttorff, and lands now or formerly of Julia J.Good and said Wood Alley;thence along said land South 87 degrees 30 minutes East, through the division wall of a double brick house erected there, a distance of 183 feet, more or less;thence along the line of Bal- timore Avenue, South 2 degrees 20 minutes East,68 feet more or less to a point at the intersection of the land now of Joseph and Jennie Brands, formerly of Martha E.Early,and said Baltimore Avenue;thence along said land, North 86 degrees 7 minutes West, 196 feet more or less to Wood Alley;to the place of BEGINNING. BEING improved with the south- ern half of a double brick dwelling house known as No. 215 and 215A North Baltimore Avenue. UNDER AND SUBJECT to any and all covenants,conditions,restric- tions, right-of-way, easements and agreements visible or of record. 24 r ,.« • PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 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. CL Lisa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 8 da of February, 2013 . / .4_ Notary tvOiARiAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 , The Patriot-News Co. 2020 Technology Pkwy Q patiiotNews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she 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 =nrl fr,r c&irl r'^i mil/^f^auphin in Miscellaneous Book"M", Volume 14, Page 317. 2007.156 Civil . Wells Fargo Bank,N.A. I W Vs �O3 'La Wand*Bragshaw a I 's This ad ran on the date(s)shown below: Lawanda.Bagsn e/ MI a Atty: Lorraine Doyle 01/22/13 6}} ALL THOSE TWO CERTAIN CTS C' 01/29/13 TTHEREON�ERB�CTED SITUATED , C 02/05/13 THE BOROUGH OF MOUNT HOLLY SPRINGS CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED `AND • • • • . . . . . DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE • WESTERN SIDE OF.BALTIMORE Sworn to and subscribed before me this 14 d:, of February, 2013 A.D. AVENUE AT THE INTERSECTION OF THE SOUTHERN LINE OF THE LAND NOW OR BERNIE �� I I ilk r SHELLY, FORMERLY OF HARRY A. AL BUT>iORFF AND LANDS NOW OR otary Pub i IP FORMERLY OF JAMES HOOVER t AND SAID BALTIMORE AVENUE; THENCE ALONG SAID ALLEY NORTH 3 DEGRINSINUTES COMMONWr PENNSYLVANIA WEST 58 FEET MORE OR LESS,TO Notarial Seal THE INTERSECTION OF THE LAND Holly Lynn Warfel,Notary Public OF BERNIE SHELLY,FORMERLY OF Washington Twp.,Dauphin County HARRY A.BUTTORFF,AND LANDS My Commission Expires Dec.12,2016 NOW OR FORMERLY OF JULIA J. ,GOOD AND SAID WOOD ALLEY; MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES `•HENCE ALONG SAID LAND SOUTH DEGREES 30 MINUTES EAST, fi UGH THE DIVISION WALL OF 1 &, . BRIM iHOUSE ERECTED , 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 Wells Fargo Bank,NA as Trustee for Securitized Asset Back Receivables LLC Trust 2005-FR1 Mortgage Pass Through Certificates Series 2005-FR1 is the grantee the same having been sold to said grantee on the 6th day of November A.D., 2013, under and by virtue of a writ Execution issued on the 2nd day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 156, at the suit of Wells Fargo Bank,NA as Trustee for Freemont Investment& Loan SABR 2005-FR1 by Saxon Mortgage Services Inc. as its Attorney-In-Fact against La Wanda Bragshaw a/k/a Lawanda Bagshaw is duly recorded as Instrument Number 201400299. IN TESTIMONY WHEREOF, I have hereunto set my hand and eal of said office this �. day of /Aiv , A.D. 020 0.. 4.4) 144.1 ‘ Recorder of Deeds R. order o`+ ds,Cumberland County,Carlisle,PA My Commi-.ion Expires the First Monday of Jan.2018