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Home My WebLink About02-3192MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Require ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage,Inc f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. ATTORNEY FOR PLAINTIFF -COURT OF COMMON PLEAS :CIVIL DIVISION .Cumberland County Daniel A. Hollingsworth ? Christina L. Hollingsworth = NO. 02 . 3/9.L Lcu ?i.. 709 Erford Road Camp Hill, PA 17011 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IWIEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O 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. LAW OFFICES OF MARK J. UDREN /a/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 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: Broadview Mortgage Company Assignments of Record to: Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. Recording Date: 01/05/99 Book: 599 Page: 573 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: 709 Erford Road f/k/a 639-B Erford Road, East MUNICIPALITY/TOWNSHIP/BOROUGH: Township of East Pennsboro COUNTY: Cumberland DATE EXECUTED: 11/02/98 DATE RECORDED: 11/04/98 BOOK: 1494 PAGE: 1078 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 07/01/02: Principal of debt due and unpaid $74,846.57 Interest at 7.00% from 01/01/02 to 07/01/02 (the per diem interest accruing on this debt is $14.55 and that sum should be added each day after 07/01/02) 2,612.68 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $148.55 and that sum should be added on the first of each month after 07/01/02) (375.48) Late Charges (monthlyy late charge of $26.56 should be added on the fifteenth of each month after 07/01/02) 157.96 Pro Rata MIP/PMI 60.70 Total Fees 74.00 Other Fees 45.00 Attorneys Fees (anticipated and actual to 5% of principal) 3,742.33 TOTAL $81,693.76 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. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has not been sent because the Mortgage is insured by the Federal Housing Administration ("FHA") and the notice is therefore not required. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $81,693.76 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 I ALL THAT CERTAIN tmct or Parcel of land and premises, sitrtate, lying and being in file Township o, East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, arora particularly describers as follows: BEGINNING at a point on the northerly line of Erford Road (East), which point is 1S9.06jeet cast of the northeasterly corner ofMaithew Road and Erford Road (East), and at dividing lire between Lots Nos, 2 and 2X, black 'T r on the hercihr?er mentioned Plan ofLots, thence along said dividing line north 02 degrees 10 minutes west ISO feet to a paint, hence north 87 degrees 50 mumtar cast, 37,S feel to a point, at dividing line between Lots Nos. 2 acrd 3Y, Block "I" on said Plan; thence along sale/ dividing line and through the center afa parthion wall and beyond south 01 dagreas 10 nrhmtes east, 1 S0 feet to a point on the northerly line ofErford Road (cast), aforesaid; hence alongsante south 87 degrees SO minifies west, 37S fret to a point, the place of BEGlNAING. H411ING thereon erected a two-story send-brick dwelling known as and numbered 709 Erford Road O'Ornherly known as 639-B Erford Road, East). BF-ING Lot No. 2' Block "I", fn Plan No. 8, Ridley park, which Plan is recorded in ilia Osice of :he Recorder ofDeeds In and for Cumberland County, Pennsylvania, in Plan Book 16, page 49. • I TOGLTIBU with the rrgin in common in ano ho tnc parn• wal. rrrtr. owrrr, arrL v-rgnr- r f ail airing prunises. SUBINCT to a S foot attity easement at rear ofsaid let. ------------ Goa 28 -Nxi 529 s E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. dren, ESQUIRE MARK J. UDREN & ASSOCIATES it !Wn W At \ k: a N G ?V F q? U 11 r ?i MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, COURT OF COMMON PLEAS Inc., f/k/a Norwest Mortgage, :CIVIL DIVISION Inc. :Cumberland County Plaintiff V. NO. 02-3192 Daniel A. Hollingsworth Christina L. Hollingsworth Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. MARK J. UDREN & ASSOCIATES DATED: August 23, 2002 BY: Mar . Udren, Esquire Attorney for Plaintiff V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: lvaultl: JERRY LEf WAAH Title: ASST.SECRETARY Company: Daniel A. Hollingsworth Christina L. Hollingsworth Loan #5481455 MJU #0233645 O T? 'a ?'i ti ? Tyr' ?°] i°,.'=. l.. C"z N . ? r.? C: ..?,., S" C" _ ''-v'- C. .. 1 -C `v ? " - ? REN & ASSOCIATES ATTORNEY FOR PLAINTIFF MARK J. UD BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, COURT OF COMMON PLEAS Inc., f/k/a Norwest Mortgage, :CIVIL DIVISION Inc. -Cumberland County One Home Campus Des Moines, IA 50328-0001 :MORTGAGE FORECLOSURE Plaintiff V. Daniel A. Hollingsworth :NO. 02-3192 Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND_ASSRSSMENT_O-F--DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) 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 Interest Per Complaint From 7/2/02 to 8/23/02 Late charges per Complaint From 7/2/02 to 8/23/02 Escrow payment per Complaint From 7/2/02 to 8/23/02 $81,693.76 771.15 53.12 148.55 TOTAL $82, 6L-E, 58 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. MARK J. UDREN & ASSOCIATES Atto k Udren, ESQUIRE r ney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS I ATED DATE: PRO PROTHY c? __ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Wells Fargo Home Mortgage, Inc f/k/a Norwest Mortgage, Inc. Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth Defendant(s) DATED: August 12, 2002 TO: Daniel A. Hollingsworth 709 Erford Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3192 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE 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 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Wells Fargo Home Mortgage, Inc f/k/a Norwest Mortgage, Inc. Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth Defendant(s) DATED: August 12, 2002 TO: Christina L. Hollingsworth 209 Enola Road Enola, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3192 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS.FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE 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 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. C M a 'Q t-i7 m fT' ,o -n r. r?; MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill, PA D17011 efendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 02-3192 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NORTH CAORLINA SS COUNTY OF MECKELNBURG THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of as foldlowsst known residence and 1940, as employment of amended, and that Defendant t are age e Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Daniel A. Hollingsworth over 18 As captioned above Unknown Christina L. Over 18 As captioned Unknown Sw rn to and subscribed 2 b ore me this day o ry u is n OFFICirl! AL r AMY S BLiZ AFiQ MECK ENSURGG COUNTY N.C. My Commission Ex ires 1.31-06 Hollingsworth abovi ame: JERRY LEE WASH, AT. SECRETARY Title: Company: c v o c? ? MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 - ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, COURT OF COMMON PLEAS Inc., f/k/a Norwest Mortgage, :CIVIL DIVISION Inc. Cumberland County One Home Campus Des Moines, IA 50328-0001 :MORTGAGE FORECLOSURE Plaintiff v. Daniel A. Hollingsworth Christina L. Hollingsworth :NO. 02-3192 709 Erford Road Camp Hillj5 PA 17011 Defendant(s) _ TO: Christina L. Hollingsworth 209 Enola Road Enola, PA 17025 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered a in li 4t above proceeding as indicated below. d Prot ono ary i) - x Judgment by Default (l 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: 856-482-6900 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, COURT OF COMMON PLEAS Inc., f/k/a Norwest Mortgage, :CIVIL DIVISION Inc. -Cumberland County One Home Campus Des Moines, IA 50328-0001 :MORTGAGE FORECLOSURE Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill,, PA 17011 Defendant(s) TO: Daniel A. Hollingsworth 709 Erford Road Camp Hill, PA 17011 :NO. 02-3192 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered inst yo in t above proceeding as indicated below. Prot ono 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 v ar_ k iT_`_Udren _ $_g_qui ra At this telephone number: s56-a8 -59nn MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Daniel A. Hollingsworth 'NO. 02-3192 Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $82_,566,_58 Interest From August 24. _2002 1,_498,ES to Date of Sale December 4?_ _20_02 Per diem @$14-55 (Costs to be added) $ _ MARK J. UDREN & ASSOCIATES h- MaIrk ? Udren, ESQUIRE ,ATTORNEY FOR PLAINTIFF R?r _N . '^J I ? c e C ? 0 ?`7lTI A ?r ;j? L _?__ !-' l N i yC ''l r(i V Ta MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County -MORTGAGE FORECLOSURE V. Daniel A. Hollingsworth NO. 02-3192 Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 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: ( x ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES 0 4rc Udren, ESQUIRE TTORNEY FOR PLAINTIFF C N Zm MIM --i -? V y MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County :MORTGAGE FORECLOSURE NO. 02-3192 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at. 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Daniel A. Hollingsworth 709 Erford Road, Camp Hill, PA 17011 Christina L. Hollingsworth 209 Enola Road, Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address Same as 41 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Chase Manhattan Bank Address to follow Trustee 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 Sq., Carlisle, PA 17013 Domestic Relations Sec tion 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue Harrisburg, PA 17128-0946 Name and address of every other person of whom the plaintiff has 7 . knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 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. MARK J. UDREN & ASSOCIATES DATED: August 23, 2002 0r? Udren, ESQ. f Attorne for Plaintiff n c) C- SV =- V : (, L mu G7 - Z v>? no rn - MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 NO. 02-3192 Defendant(s) NOTICE_OF_SHERIFF'S SALE 07-REAL-PROPERTY TO: Christina L. Hollingsworth 209 Enola Road Enola, PA 17025 Your house (real estate) at 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 is scheduled to be sold at the Sheriff's Sale on December 4, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $82,666.58, 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= PREVENT_THIS-SHERIFELS 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: 1856) ..492-5900.._ 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- STILL_BE_ ABLE TO SAVE- YOUR- PROPERTY- AND YOU HAVEOTHER RIGHTS EVEN_IF -'HE_SHERTFF'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 856-482-6900. 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 856-482-6900. 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 DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 C N , FT I T- -n N p:?1 -'ci MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill" PA 17011 ATTORNEY FOR PLAINTIFF .COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSURE NO. 02-3192 Defendant(s) NOTICE OF SHHFRTFF GALE OF REAL PROPERTY TO: Daniel A. Hollingsworth 709 Erford Road Camp Hill, PA 17011 Your house (real estate) at 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 is scheduled to be sold at the Sheriff's Sale on December 4, 2002, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $82,666.58, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NQTI.QE_OF OMNEZ S_RIGHTS YQU_MAV BF TO REVENT THT - H RTFF G SAT, 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: (E56I-n8 -?gnn 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_ MAX STILL BE_ ABLE-TO-SAVE-OUR-PRQPERTY AND YOU-HAVE_OTHER_RIGHTS EVEN IF THE-.%HERIFF'_!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 856-482-6900. 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 856-482-6900. 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 ,oney will be paid out in accordance with this schedule unless exceptions (reasons why7the 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 DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 N O ''p A ?? i_ '- t : ? N .. "' -, ;? o ,,_ ` ? , r. -1 ,, 7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3192 Civil CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff (s) From DANIEL A. HOLLINGSWORTH AND CHRISTINA L. HOLLINGSWORTH, 709 ERFORD ROAD, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL (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 gamishee(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 $82,666.58 L.L. $.50 Interest FROM 8/24102 TO DATE OF SALE 12/4/02 PER DIEM @ $14.55 - $1,498.65 Any's Comm % Due Prothy $1.00 Arty Paid $152.05 Other Costs Plaintiff Paid Date: AUGUST 26, 2002 CURTIS R. LONG Prothonot (Seal) By Opp _ / r/?fJ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856482-6900 Supreme Court ID No. 04302 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mort ATTORNEY FOR PLAINTIFF Inc., f/k/a Norwest Mortgage COURT OF COMMON PLEAS Inc. g :CIVIL DIVISION One Home Campus :Cumberland County Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road :NO. 02-3192 Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. that: Udren, Esquire, hereby verifies 11• A copy of the Notice of Sheriffs Sale . attached hereto o Exhibit e , a true and correct co every other interested , was sent to every recorded lienholderhand every pe for the Writ of party known as of the date of the filin Certificates of Mailing. Execution, on the date(s) appearin g of the g on the attached 2. A Notice of Sheriff's Sale was sent to Defendant(s) certified mail on the date appearing on the attached Return Receipt was signed for }? by regular mail and on the date Receipt. Copies of Dheesa d Notice and Return Receipt are attached he, which Exhibit ??8?? • the said Return reto as 3. If a Retur service on the ndRece pec fio attathe ched hereto, attached then service was b personal hereto as Exhibit "Bn Return of Service by attached 4. If service was by Order of Court, Order is attached hereto as Exhibit "B". All Notices were served within the tim, 3129. This Affidavit is made subject to tl relating to unsworn falsification to Dated: October 24, 2002 then proof of compliance with said liiEs set forth by Pa Rule C.P. Of 18 Pa.C.S. Section 4904 MARK ;J-_?REN & ASSOCIATES uu1 .en, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF _COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE ]?ORECLOSURE :NO. 02-3192 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. 'Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Daniel A. Hollingsworth 7073 Carlisle Pike Lot 212 Leibys Mobile Home Park, Mechanicsburg, PA Christina L. Hollingsworth 209 Enola Road, Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address Same as #1 above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Chase Manhattan Bank C/O Residential Funding Corp Trustee 1301 Office Center Drive #200 Fort Washington, PA 19034-3227 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, Dept. 280946 Harrisburg, PA 17128-0946 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 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or i? rmation and belief. I understand that false statements herei? mgfd subject to the penalties of 18 Pa.C.S. sec. 4904 relating to un o a -r' to authorities. f/i & ASSOCIATES DATED: October 24, 2002 -marx j. Ualren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. One Home Campus Des Moines, IA 50328-0001 Plaintiff V. Daniel A. Hollingsworth Christina L. Hollingsworth 709 Erford Road Camp Hill, PA 17011 Defendant(s) DATE: August 26, 2002 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3192 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE 07- REAL__PRO-PERTY OWNER(S): DANIEL A. HOLLINGSWORTH & CHRISTINA L. HOLLINGSWORTH PROPERTY: 709 Erford Road f/k/a 639-B Erford Road, East Camp Hill (Twp of East Pennsboro) PA 1.7011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumbe??and County Sheriff's Sale on De-cemlb?er 4.2002, at 10:00 A.M., at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. 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V C. 00 72 m m O W m ?mUN K y , 5 Fy A .4 CO m m f t C 4 m ? E ? m o ? ? m m 0 m < T f ? 1I. JM .' _ C C O m D m C = O mPmmn wm . _ r - pcwo Emm K m. m L m w m E n E o p - E mD qmc _ gE`oa o` I i _ m.. p m m P m L L CCp?f p? °O ? E ?. o?ax . D m p u m I ? m? x 'c'o5 c m -- m wa y_NE p O V' m o D m N E c ?°i?m oDo C? U ? m m c c m c' N ` m E o o W e C ! i0 sEp.°E,S coa V m a 2 m m«¢ m C ` c y m p o m c = o O > moawo c?a H m m o w? o jp m O C C r I m ? a I S ~ a II t ? i d / r * £ G G I I L i 2 O I - U ?,ve Ji (}1• Q? (v _1-j a C)_ ul co Ill:.6U)#1 C7 cc P. c J Z ? o ? C?_n/ l-I cn 3!1 Yo 'j «YY Q I E -?L z a 1 co --t LO CO n ! I I I I ! I I la ? N !Z d II W U I ! I i I? O N m I ? ? is m` n OD Em M ?? E Za o - I?r r° CO r-A in Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. VS Daniel A. Hollingsworth and Christina L. Hollingsworth In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3192 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on September 17, 2002 at 8:57 o'clock PM, he served a true copy of the within Real Estate Writ, Notice an ion, i ove entitled action, upon the within named defendant, to wi aniel A. Hollin sworth, by aking known unto Daniel Hollingsworth, is a eiby's Mobile Home Park, Mechaniosburg;.Ciimberland County,=Pennsylvariia,,its conitents aftd at the.same time" ' handing to him personally the said true and correct copy of the same. xr, Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on September 06, 2002 at 1:14 o'clock PM, he served it true copy of the within Real Estate Writ, N -DE-S-criiptron- ve entitled action, upon the within named defendant, witChristina L. Hollingsworil; aking known unto Christina L. Hollingsworth, at 20nola Road, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 1:16 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Daniel A. Hollingsworth and Christina L. Hollingsworth located at 709 Erford Road, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Daniel A. Hollingsworth, by regular mail to his last known address of 7073 Carlisle Pike, Lot 202, Leiby's Mobile Home Park, Mechanicsburg, PA 17055. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Christina L. Hollingsworth, by regular mail to her last known address of 209 Enola Road, Enola, PA 17025. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriff's Office. Sworn and Subscribed to Before Me This Day of 2002, A.D. Prothonotary So ?? R. Thomas Kline, Sheriff BY4sta-t Reaeputy EXHIBIT SEA, c? . ;' c_ - ? - : ?'= ; . - _ vJ._ ;?? ?,: _ - `?? , < _. _?.- . s=? :., ,- ? ; ..? TH OF PENNSYLVANIA SS: ,iMONWEAL rOUNTY OF CUMBERLAND in and for said County and State do hereby certify that Ziegler, Recorder of Deeds i ,,,tee the same ljj 1, Robed est Mt Inc is the g o Home Mt0 flca Nom the Sheriff's Deed in which W ells aY' the 4th day of Dec A.D., 2002, under and by virtue of a writ hawing been sold to said grantee on of Common pleas of said ued on the 22 day of August, A.D., 22' out of the Court Inc f Exec iss o Home Mt at the suit of W essl ka norwest Mt as of Civil Tee' 2 Number 3192, Fes' Deed Book No. 2, County iel A Rollin sworth & Christina L is duly recorded in Sheriff s Inc against Dan Page l_ IN TESTIMONY WHEREOF, I have hereunto set my hand ?¢ day of and seal of said office this A.D. 2003 Recorder of Dee( Wells Fargo Home Mortgage, Inc. fWa Norwest Mortgage, Inc. VS Daniel A. Hollingsworth and In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3192 Civil Term Christina L. Hollingsworth duly sworn according to law, states that ut Sheriff, who being Y of the within Real Jason Vioral, Dep y he served a true copy on the within named on September 17, 2002 at 8:57 tion° in the above entitled action, up , 2 making known unto Daniel Notice and Writ, d Descrip park, defendant, to wit: Daniel A. Honingsworth by Lei y s Mobile Home sworth, at 7073 CarlislePike, Lot 21 , pennsylvania, its contents and at the same time Holling Mechanicsburg, Cumberland County, of the same. handing personally the said true and correct copy states to him who being duly sworn according of to the law, within Real ed a true copy Richard Smith, Deputy Sheriff, within named that on September 06, 2002 at 1:14 clock the above enti 1 d action, upon the Estate Writ, Notice and Description, making known unto Christina L. its Cum by berland County, Pennsylvania, defendant, to witChristina L. Hollingsworth Hollingsworth, at 209 Enola Road, to her personally the said true and correct copy of contents and at the same time handing states that the same. being duly sworn according to law, Robert Bitner, Deputy Sheriff, who he posted a true copy of the within Real Estate on October 2, 2002 at 1:16 o'clock P.M., u on the property of Writ, Notice, Poster and Description, in the above entitled action, p Daniel A. Hollingsworth and Christina a ; W ollingsworth located at 709 Erford Road, Camp Hill, Pennsylvania, according duly sworn according to law says he served R. Thomas Kline, Sheriff, who being Y 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 one of the within name defendants to wit: Daniel A. Hollingsworth, by regular mail to his last known address of Mechanicsburg, PA 17055. the 7073 Carlisle Pike, Lot 202, Leiby's Mobile Home Park, This letter was mailed under the date of October 1, 2002 and never returned to served Sheriff's Office. dul sworn according to law says he R. Thomas Kline, Sheriff, who being y 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 one of the within named defendants to wit: Christina L. Hollingsworth, by regular mail to her last known address of 209 Enola Road, Enola, PA 17025. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriff's Office. law, R. Thomas Kline, Sheriff, who being duly sworn according to he exposed the Cates that after due and legal notice had been given according to law, Carlisle, Cumberland He sold the same for the sum ennsylvania, on public cember 4, 2002 at 10:00 AM. Ouse, Inc. f/k/a Norwest Cdescribounty,ed Pnnsy or outcry at the of $1.00 to Attorney Leon P. Haller for Wells Fargo Hom e Mortgage, us, Des Moines, ceived for the sam Mortgage, Inc. It being the highest bid g get price rOne Home Camp e, Wells Fargo Home Mortgage, Inc. fWa Norwe 50328, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of IA $962.29, it being costs. Sheriff s Costs: Docketing poundage posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 30.00 18.87 15.00 15.00 30.00 10.00 .50 1.00 24.15 2.07 15.00 30.00 381.65 299.35 25.20 25.00 39.50 $ 962.29 paid by attorney 01/08!03 -7 Sworn and subscribed to before me So R. Thomas Kline, Sheriff i This lc?5dayo B ? Vl 2003, A.D. Real Estate eputy thonotary 3b• &o I' p ct?k Jsk? Ck39 ya/ d", / 3 36 l a- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3192 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff (s) From DANIEL A. HOLLINGSWORTH AND CHRISTINA L. HOLLINGSWORTH, 709 ERFORD ROAD, CAMP HILL, PA 17011 (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 $82,666.58 L.L. $.50 Interest FROM 8/24/02 TO DATE OF SALE 12/4/02 PER DIEM @ $14.55 - $1,498.65 Atty's Comm % Due Prothy $1.00 Atty Paid $152.05 Other Costs Plaintiff Paid Date: AUGUST 26, 2002 CURTIS R. LONG Prothonot y (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 Real Estate Sale # 15 On August 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA known and numbered as 709 Erford Rd. f/k/a 639-B Erford Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 29, 2002 Byt,-10&coMkk , Real Estate Deputy o? 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 Frank J. Epler being duly sworn according to law, deposes and says: under t the of the That he is the Controller of The Patriot e office and place corporation of businesseatc812eto xist81ing8 MarkethStreet in Commonwealth of Pennsylvania, with its principal City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News ands Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the were City, County and State aforesaid; that The Patri -Nall) have nd Ten contdiay Payi pull shed e e est bushed March 4th, 1854, and September 18th, 1949, respectively, a andished the in That the printed notice or publication which cutn the 22nd and 29th printofeOctobed and their regular daily and/or Sunday/ Metro editions which appeared o rested sub in t ct matter of 5th day(s) of November 2002. That neither he nor of said th this statement aseto the t mel? pia eleand characteraof printed notice or advertising, and that all of the allegations publication are true; and empowered verify That he has personal knowledge of aforesaid the facts and pursuan pursuant iresolu on unanimously passed ands statement on behalf of The Patriot-News Co. aforesaid by virtue 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. 14th day of ove a 2002 A.D. tttt PUBLICATION ...................... NOTARY PUBLIC COPY al seal blic SALE LE ll, Notaryt un 7REAL ESTATE SA 3192 .15 rg, Dauph; Writ No PuCo .- xpires June 6, 2006 CIvO ToHome Mortgage, inc. flk/a Member Pennsylvania Association Of Notariy commission expires June 6, 2006 Wells Farg , Norwest Mortgage, Inc. vs CUMBER LAND COUNTY SHERIFFS OFFICE Daniel A. and n9gWOrth CUMBERLAND COUNTY COURTHOUSE Christina L. milingsw°rth CARLISLE, PA. 17013 Atty: Mark Udren DESCRIPTION nship Statement of Advertising Costs ALL WAT CERTAIN t?atorIng Pucelthe ofland of Pennsboro tennsb0o)in the To THE PATRIOT-NEWS CO., Dr. of Ea County of Cumberland and Commonwealth described as For publishing the notice or publication attached Pennsylvania, more particularly 2 9 7.6 0 follows: iErford Road (East), It on the northerly line of hereto on the above stated dates $ 1 .75 BEGINNING at a poi point is 159.06 feet Probating same Notary Fee(s) $ Total $ 299.35 east of the northeasterly coer and°at dividing line and Erford Road (East), between Lots Nos. 2 and 2X, Block "I" on the 10 nce along hereinafter mentioned Plan of Lots the minutes publisher's Receipt for Advertising Cost said dividing line north 02 degrees The Patriot News Co., publisher of The Patriot-News and The Sunday _Patriot- t-News, newspapers of genera circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................. VIM 150 feet to a point; dw" Wrth 87 degrees 37.5 fat to a point, at dividing Leta bba. 2 acid 3Y, Blak "f od said Plan; thence along said dividing line and through the center of a partition wall and beyond south 02 degrees 10 minutes east, 150 feet to a . point on the northerly line of Erford Road (east), afore- said; thence along same south 87 degrees 50 minutes west, 37.5 feet to a point, the place of BEGINNING. HAVING thereon erected a two-story semi-brick dwelling known as and numbered 709 Erford Road (formerly known as 639-B Erford Road, East). BEING Lot No.2, Block ,r', in Plan No-8, Ridley Park, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 16, page 49. TOGETHER with the right in common in and to the patty wall with owner and occupant of adjoining premises. SUBJECT to a 8 foot utility easement at rear of said lot. TITLE TO SAID PREMISE IS VESTED IN Daniel A. Hollingsworth and Christina L. Hollingsworth, husband and wife, by deed from Eddie Hammonds, by his attomey-in-fact, Karyn Maureen Hammonds, and Karyn Maureen Hammonds, husband and wife, and William B. Angeny, Jr, and Loretta V. 2ngeny, husband and wife, dated 10/31/98, recorded 11/04/98, in deed book 188, page 629. PROPERTY ID NO. 09-16-1050-168. BEING KNOWN AS 709 Erford Road FKA 639- B Erford Road, East, Camp Hill, PA 17011. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, 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: OCTOBER 25, NOVEMBER 1, 8, 2002 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. REAL ESTATE SALE NO. 15 Writ No. 2002-3192 Civil Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. vs. Daniel A. Hollingsworth and Christina L. Hollingsworth Atty.: Mark Udren ALL THAT CERTAIN tract or Par- cel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- scribed as follows: BEGINNING at a point on the northerly line of Erford Road (East), which point is 159.06 feet east of the northeasterly corner of Matthew road and Erford Road (East), and at dividing line between Lots Nos. 2 and 2X, Block "I" on the hereinafter mentioned Plan of Lots; thence along said dividing line north 02 degrees 10 minutes vwtrt 150 feet to a point; ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of NOVEMBER. 2002 &a,er? . 'ti' . ?? J& "i NoMry . J lnty EMYC6 ' rz. Ed(C t ? ; . -,s March 5, 2005 qm? thence north 87 degrees 50 min- utes east, 37.5 feet to a point, at dividing line between Lots Nos. 2 and 3Y, Block "I" on said Plan; thence along said dividing line and through the center of a partition wall and beyond south 02 degrees 10 minutes east, 150 feet to a point on the northerly line of Erford Road (east), aforesaid; thence along same south 87 degrees 50 minutes west, 37.5 feet to a point, the place of BEGINNING. HAVING thereon erected a two- story semi-brick dwelling known as and numbered 709 Erford Road (for- merly known as 639-B Erford Road, East). BEING Lot No. 2, Block "I", in Plan No. 8, Ridley Park, which Plan is recorded in the Office of the Re- corder of Deeds in and for Cum- berland County, Pennsylvania, in Plan Book 16, page 49. TOGETHER with the right in com- mon in and to the party wall with owner and occupiers of adjoining premises. SUBJECT to a 8 foot utility ease- ment at rear of said lot. TITLE TO SAID PREMISE IS VESTED IN Daniel A. Hollingsworth and Christina L. Hollingsworth, hus- band and wife, by Deed from Eddie Hammonds, by his Attorney-in-Fact, Kaiyn Maureen Hammonds, and Kar- yn Maureen Hammonds, husband and wife, and William B. Angeny, Jr. and Loretta V. Angeny, husband and wife, dated 10/31/98, recorded 11/04/98, in Deed Book 188, Page 629. PROPERTY ID NO.: 09-16-1050- 168. BEING KNOWN AS 709 ERFORD ROAD FKA 639-B ERFORD ROAD, EAST, CAMP HILL, PA 17011. ?5